Disclosures and Disclaimer

PLEASE READ THESE IMPORTANT LEGAL NOTICES AND DISCLOSURES 

COPELAND MARKETS, LLC (DBA NASDAQ PRIVATE MARKET) IS NOT: (A) A REGISTERED EXCHANGE UNDER THE SECURITIES EXCHANGE ACT OF 1934; (B) A REGISTERED INVESTMENT ADVISOR UNDER THE INVESTMENT ADVISORS ACT OF 1940; OR (C) A FINANCIAL OR TAX PLANNER, AND DOES NOT OFFER LEGAL, FINANCIAL, INVESTMENT OR TAX ADVICE.  SECURITIES RELATED SERVICES ARE OFFERED THROUGH NPM SECURITIES, LLC, A WHOLLY OWNED SUBSIDIARY OF NASDAQ PRIVATE MARKET, AND A REGISTERED BROKER-DEALER AND ALTERNATIVE TRADING SYSTEM, WHICH IS A MEMBER FINRA/SIPC.  NASDAQ PRIVATE MARKET IS OPERATIONALLY INDEPENDENT AND DISTINCT FROM THE NASDAQ STOCK MARKET, LLC.  TRANSACTIONS IN SECURITIES CONDUCTED THROUGH NPM SECURITIES, LLC ARE NOT LISTED OR TRADED ON THE NASDAQ STOCK MARKET LLC, NOR ARE THE SECURITIES SUBJECT TO THE SAME LISTING OR QUALIFICATION STANDARDS APPLICABLE TO SECURITIES LISTED OR TRADED ON THE NASDAQ STOCK MARKET LLC, NOR DO TRANSACTIONS IN SECURITIES CONDUCTED THROUGH NPM SECURITIES, LLC AFFECT AN ISSUER’S ELIGIBILITY TO LIST ITS SECURITIES FOR TRADING ON THE NASDAQ STOCK MARKET, LLC.

FUNDS PROCESSED BY NPM SECURITIES, LLC AS PAYING AGENT IN CONNECTION WITH A TRANSACTION MAY BE DEPOSITED IN AN INTEREST-BEARING ACCOUNT ESTABLISHED FOR THE EXCLUSIVE BENEFIT OF NPM SECURITIES’ CUSTOMERS. ANY INTEREST EARNED ON SUCH FUNDS WILL BE RETAINED BY NPM SECURITIES. 

THE INFORMATION CONTAINED HEREIN IS PROVIDED FOR INFORMATIONAL AND EDUCATIONAL PURPOSES ONLY.  NONE OF THE INFORMATION PROVIDED REPRESENTS AN OFFER TO BUY OR SELL, OR THE SOLICITATION OF AN OFFER TO BUY OR SELL, ANY SECURITY, NOR DOES IT CONSTITUTE AN OFFER TO PROVIDE LEGAL, TAX, FINANCIAL OR INVESTMENT ADVICE OR SERVICE. 

INVESTING IN PRIVATE COMPANY STOCKS IS SPECULATIVE AND INVOLVES A HIGH DEGREE OF RISK. YOU MUST BE PREPARED TO WITHSTAND A TOTAL LOSS OF YOUR INVESTMENT. YOU ARE STRONGLY ENCOURAGED TO COMPLETE YOUR OWN INDEPENDENT DUE DILIGENCE BEFORE INVESTING IN PRIVATE COMPANY STOCK, INCLUDING OBTAINING ADDITIONAL INFORMATION, OPINIONS, FINANCIAL PROJECTIONS, AND LEGAL OR OTHER INVESTMENT ADVICE.

Important Information You Need to Know About Onboarding

U.S.A. PATRIOT ACT

In order to help the government fight the funding of terrorism and money laundering activities, U.S. federal law requires all financial institutions to obtain, verify, and record information that identifies each person or entity that opens an account. In addition to asking you for your name and address and other identifying information, NPM Securities, LLC (“the Firm”) may also request other identifying information and documentation.

BUSINESS CONTINUITY STATEMENT

The Firm has created a Business Continuity Plan (“BCP”) that provides for the Firm to continue its services to its customers and subscribers within a reasonable amount of time, given the scope and severity of a significant business disruption (“SBD”).

The BCP anticipates responding to both internal and external SBDs.  An internal SBD, such as the loss of our telephone system, affects only the Firm.   The Firm will respond to internal SBDs by re-routing calls to secondary numbers, and/or relocating its primary office to a secondary location, and/or, recovering data from a back-up storage media and/or a back-up site.  The Firm expects to recover from an internal SBD within one hour.

An external SBD, such as a power outage or flood, affects multiple businesses and can be local, regional, national, or global.   The Firm’s response to an external SBD relies more heavily on other organizations.  The Firm expects to recover from an external SBD within six hours. 

In the event a SBD prevents customers or subscribers from contacting the Firm through their usual methods, the following alternative methods can be utilized:

Operations Team Contact Number: (+1) 646-968-7040
Operations Email: operations@npm.com
Legal Team Contact Number: (+1) 646-968-7039
Legal Team Email: legal@npm.com

If a SBD disrupts both the primary and secondary methods of contacting the Firm will, to the best of its ability, provide alternative contact information on our website.   

The Firm does not receive, acquire, hold or maintain funds or securities for its customers or the customers of its subscribers.  All notification requirements pertaining to the accessing of such funds and securities are the responsibility of the bank or broker/dealer with which the customer or subscriber maintains a securities account.

While no contingency plan can eliminate all risk of service interruption or temporarily impeded account access, the Firm continually assesses and updates its BCP to mitigate all reasonable risk.

This disclosure is subject to modification.

PRIVACY NOTICE

Please visit www.nasdaqprivatemarket.com/privacy-policy/ for the Nasdaq Private Market Privacy Policy.

FINRA’S PUBLIC DISCLOSURE PROGRAM

The Board of Governors of the Financial Industry Regulatory Authority (“FINRA”) has adopted a ‘Public Disclosure Program’ that provides investors with disciplinary information on FINRA member firms and their associated persons via FINRA’s BrokerCheck website (http://brokercheck.finra.org/) or via FINRA’s toll-free number (800) 289-9999. 

The primary purpose of this Public Disclosure Program is to help investors make informed choices about FINRA member firms and their associated persons when determining whether to conduct business with the firm.  To obtain a free brochure describing the FINRA Public Disclosure Program you can call the toll-free number listed above or visit FINRA’s website (www.finra.org).

SECURITIES INVESTOR PROTECTION CORPORATION

NPM Securities, LLC is a member of the Securities Investor Protection Corporation (“SIPC”).  SIPC is a non-profit, membership corporation, funded by its member securities broker-dealers.  SIPC was created to protect investor assets that are in the hands of bankrupt and otherwise financially troubled brokerage firms.  For more information about SIPC, including the SIPC brochure, please use the contact details below:

Securities Investor Protection Corporation

1667 K St. N.W., Suite 1000

Washington, D.C. 20006-1620

Telephone: (202) 371-8300

Fax: (202) 223-1679

Email: asksipc@sipc.org

In addition, you may also visit the SIPC website at www.sipc.org.