Business Continuity Plan

BUSINESS CONTINUITY PLAN SUMMARY

Walthausen & Co., LLC has developed a disaster recovery and business continuity plan (BCP) to meet its responsibilities to clients, staff, business associates and others who may be affected by a disruption in the firm’s business. This document is intended to provide our customers and other interested parties with information regarding our BCP.

Contacting Us – If after a significant business disruption you cannot contact us at our main number, (518) 371-3450, you should call our alternative numbers:

If you cannot access us through either of those means, visit our website at www.walthausenco.com.

Our Business Continuity Plan – The firm’s policy is to respond to a significant business disruption (SBD) in an effort to safeguard employees’ lives and firm property, make a financial and operational assessment, quickly recover and resume operations as can be reasonably expected based on the circumstances, to protect the firm’s most critical books and records, and allow clients to continue to transact business.

Our Business Continuity Plan addresses: all mission critical systems; data and back-up recovery; financial and operational assessment; alternative communications with clients, employees and regulators; alternate physical location of employees; critical third party vendors, bank and custodian impact and regulatory reporting. The BCP includes redundant data centers and alternate facilities to protect its business processes and technology environment.

Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire or power outage in our building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, earthquake, or a wide-scale regional disruption. Our response to an external SBD relies more heavily on other organizations and systems.

The Management Committee of the firm must approve the plan and any amendments. It must also be updated at least annually or as soon as possible in the event of a material change in operations, structure, business and/or location.

The plan also includes a list, in hard copy and electronic form, of associated persons’ emergency telephone numbers, email addresses, and physical addresses to facilitate communication during a SBD.

Varying Disruptions – Disruptions can vary in their scope, such as a single building housing the firm, the business district where the firm is located, the city where the firm is located, or the whole region. In the event of an office disruption in our primary Malta office location, we will conduct our physical operations at an offsite location which will become the interim primary office if needed. Details will be communicated to critical contacts and posted on the firm’s website. We plan to continue regular business activities within a few hours of a disruption or as quickly as conditions allow us to resume communications.

Plan Procedures – The chief compliance officer (CCO) will conduct training or will assign training such that the firm’s employees are informed of components of the BCP. No less than annually, the CCO shall re-evaluate the efficacy of the plan, and shall amend the plan according if required.

If you have questions regarding our firm’s BCP, please feel free to contact us at (518) 371-3450.