BUSINESS CONTINUITY PLAN

Summary of Dragonfly Capital's Business Continuity Plan

Dragonfly Capital has developed a business continuity plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us - If after a significant business disruption you cannot contact us as you usually do by either email or at the telephone number of the office with which you normally communicate, you should call 1.704.488.7712 for further information.

Our Business Continuity Plan - We plan to recover and resume business operations after a significant business disruption as promptly as practicable and to safeguard our employees and property, make a financial and operational assessment, protect the firm's books and records, and allow our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counterparty impact; and regulatory reporting if we are unable to continue our business.

Varying Disruptions - Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to another location when needed. In a disruption affecting our business district, city, or region, we will transfer our operations to a location outside of the affected area, and recover and resume business operations. In either situation, our goal is to recover and resume business operations as promptly as practicable in the circumstances.

For more information - If you have questions about our business continuity planning, you can contact us at 704.342.3491 and request to speak to Don Millen.

Disclaimer - Our business continuity plan and this disclosure are intended to comply with the rules promulgated by the National Association of Securities Dealers. While our business continuity plan is designed to address various circumstances that could result from a significant business disruption, such an event is, by its nature, unpredictable and it is impossible to anticipate every scenario that could cause, and circumstance that could result from, a significant business disruption. In addition, we have no control over various entities, including our clearing firm and other service providers, upon which we will rely in the event of an emergency. Our business continuity plan is subject to change without notice. This disclosure will be updated promptly on our website to reflect any material changes to the information contained herein. The information contained in this disclosure is provided for informational purposes only.

ACHIEVING SUPERIOR OUTCOMES

At Dragonfly Capital, we are entrepreneurs who have chosen to serve other entrepreneurs. We operate by the same principles that have guided us successfully since day one.