Business Continuity Plan Summary

Winslow Capital Management, LLC (“Winslow Capital”, the “Firm”) has a formal Business Continuity/Disaster and Data recovery plan (the “Plan”) in place. The Firm understands that every crisis could result in one or more of the following: 1) loss of access to information; 2) loss of information; 3) loss of access to facilities; and 4) loss of people. The purpose of the Plan is to minimize the impact of a system failure or business continuity incident to Winslow Capital, its clients, employees, and suppliers.

Winslow Capital monitors and tests its Plan and makes changes or improvements to the Plan as the business and business systems evolve and/or when issues are identified, annually at minimum. Additionally, all personnel receive training on the Firm’s Plan at least annually. The Plan identifies responsible parties, critical functions, and recovery time objectives for both short- and long-term scenarios and contemplates disruptive events such as climate change to ensure operational resiliency. Other aspects of the Plan include: a) an emergency communication system utilized to disseminate critical information and monitor employee safety, b) arrangements in place to work at alternative locations, c) production and back-up servers housed at separate secure data center locations, d) all employees work with company-issued laptops allowing access to all Winslow Capital applications remotely, e) records are stored electronically, and f) additional redundancy related to certain critical applications.

Updated: January 2023