Enclave respects the privacy of our customer relationships and maintains the highest standards of confidentiality. We provide this Privacy Notice to our individual customers who obtain financial products and services from us for personal, family or household purposes to inform them of the personal information we obtain and we how we maintain the confidentiality of that information.

When we conduct business with you, we will collect certain personal information, such as your name, social security number, assets, income, tax bracket and transactions you have entered with us and others, from forms and other documents you complete and provide to us. We also may receive information from consumer reporting agencies which may be used to verify the information you provide to us, for general risk management decisions and for other legitimate business purposes. We limit the collection of personal information to that which is necessary to conduct our business and to deliver products and services to you.

We consider our obligation to protect the privacy of your information as one of our primary concerns. Accordingly, we have instituted physical, electronic and procedural safeguards to protect the personal information you entrust to us.

Your personal information is utilized strictly for the purpose of conducting business with you. Enclave never sells your information and does not share it with third parties except in limited circumstances where we believe in good faith that disclosure is required under law to cooperate with regulators or law enforcement authorities, perform necessary credit checks, collect or report debts owed to us, protect Enclave’s rights or property, or upon the reasonable request of a sponsor or provider of a transaction in which you have chosen to invest. We will provide you with prior notice of any sharing of information with third parties.

We maintain your personal information under your name in Enclave’s confidential files. We have adopted procedures that prohibit our employees from accessing customer information other than on a “need-to-know” basis for legitimate business purposes. Access to each customer’s information is password protected and the data systems utilized by Enclave employ encryption and other well-established technologies to avoid unauthorized disclosure of that information. Employees with access to personal information may not use or disclose that information except in strict compliance with our privacy policy. We train our employees to understand and comply with the security standards and procedures we have adopted to safeguard customer information, and to recognize that they will be subject to disciplinary action if they fail to adhere to them.

If you choose to end your customer relationship with Enclave, we will continue to adhere to the foregoing privacy policies. Should you have additional questions about our policy, please speak directly with your Enclave representative.

For more information about our privacy policy, please contact us at compliance@enclavecapital.com.

ENCLAVE CAPITAL LLC BUSINESS CONTINUITY PLAN 2024

1. Emergency Contact Persons

The Firm’s two emergency contact persons are listed below:

Name: Robert Mazzeo

Title: Chief Executive Officer

Phone number: (917) 459-7906

E-mail: rmazzeo@enclavecapital.com

Name: Andrew Ing

Title: Office Manager

Phone number: (646) 454-8600

E-mail: aing@enclavecapital.com

These names will be updated in the event of a material change, and our Executive Representative will review them within 17 business days of the end of each calendar year or within 30 days of determining a need for a change.

Rule: FINRA Rule 4370(f); FINRA Rule 4517

2. Firm Policy

Our Firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and Firm property, making a financial and operational assessment, quickly recovering and resuming operations and protecting all of the Firm’s books and records with the goal of allowing any transactions in progress to continue. In the event that we determine we are unable to continue our business; we will work with our counterparties to complete or unwind any open transactions as soon as possible and we will assist our customers’ prompt access to their funds and securities.

A. Significant Business Disruptions (SBDs)

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 in our building. External SBDs, such as a terrorist attack, a city flood, or a wide- scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our Clearing Firm, if applicable.

B. Approval and Execution Authority"

Joel Mathews, Chief Compliance Officer and a registered principal, is responsible for approving our business continuity plan (BCP) and for conducting the required annual review. See Section 14 below. He has the authority to execute this BCP.

C. Plan Location and Access

Our Firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is located on the Firm’s cloud-based Dropbox folder. The file will be saved as Enclave Capital Business Continuity Plan. A hard copy will be kept at the Firm’s main office at 301 Yamato Road, Suite 2198, Boca Raton, FL 33431.

3. Business Description

The Firm’s principal businesses consist of (i) providing a “chaperoning” platform for foreign brokers who wish to solicit U.S. institutional investors for brokerage trades and capital markets transactions and (ii) investment banking services, including private placements of securities, general strategic advice concerning mergers and acquisitions, and public offerings on a best-efforts basis or as a member of a selling group.

4. Office Locations

We have two branch locations. Our main office is located at 301 Yamato Road, Suite 2198, Boca Raton, FL 33431 (telephone number: 646-454-8600). We maintain an OSJ branch office at 600 Alexander Road, Princeton, NJ, 08540 (telephone number: 609-452- 2888). Our employees may travel to these locations by foot, car, train or bus.

5. Alternative Physical Locations of Employees

In the event of an SBD, the principal members of the Firm will work from their homes using private internet and cellular phone systems. In the event that internet and phone service is unavailable due to the SBD, principals of the Firm will seek alternate temporary space or suspend business until such systems are reinstituted.

Rule: FINRA Rule 4370(c)(6).

6. Customers’ Access to Funds and Securities

Our Firm does not maintain custody of customers’ funds or securities. All funds or securities are maintained at a customer’s bank, custodian or other broker-dealer.

Rules: FINRA Rule 4370(a); Securities Exchange Act Rule 15c3-1; 15 U.S.C. 78eee (2003).

7. Data Back-Up and Recovery (Hard Copy and Electronic)

Our Firm maintains its primary books and records in electronic form online within its DropBox account. Some records are also available at the address set forth in Section 4. Greg Vittor, the Firm’s Financial and Operations Principal (FINOP), is responsible for the maintenance of the financial books and records, which are maintained electronically within Quick Books online.

In the event of an internal or external SBD that causes the loss of any paper records, we will physically recover the duplicate copy from our DropBox cloud account. If our primary site is inoperable, we will continue operations from our Princeton location, and vice versa.

All emails are captured and retained by SECCAS. Disks are maintained by SECCAS and the Firm.

Rule: FINRA Rule 4370(c)(1).

8. Financial and Operational Assessments

A. Operational Risk

In the event of an SBD, we will promptly identify the means by which we will communicate with our customers, employees, critical business constituents, critical banks and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include e-mail and telephone (land line and cellular). In addition, we will retrieve our key records as described in Section 7.

Rules: FINRA Rules 4370(c)(3),(c)(4), (c)(5), (c)(7), (c)(9 & (g)(2)).

B. Financial and Credit Risk

In the event of an SBD, we will determine the value and liquidity of our assets to evaluate our ability to continue to fund our operations and remain in capital compliance. Greg Vittor, the Firm’s FINOP, will contact our Clearing Firm (if applicable), any critical banks and counterparties in ongoing transactions to apprise them of our financial status.

If we determine that we may be unable to meet our obligations to counterparties or continue to fund our operations, we will request additional financing from our existing equity holders or other credit sources to fund our operations. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately cease operations including any transactions in progress.

Rules: FINRA Rules 4370(c)(3), (c)(8) & (f)(2).

9. Mission Critical Systems

The Firm’s “mission critical systems” are those that are material to ensuring prompt and accurate processing of securities transactions described in Section 3 above. More specifically, these systems include telephone service, computer/email systems, and Dropbox access.

We have primary responsibility for establishing and maintaining our business relationships with our customers.

Recovery-time objectives provide concrete goals to plan for and test against. They are not, however, hard and fast deadlines that must be met in every emergency situation, and various external factors surrounding a disruption, such as time of day, scope of disruption, and status of critical infrastructure—particularly telecommunications—can affect actual recovery times.

Enclave does not currently have a Clearing Firm; however, if and when a Clearing Firm is recognized, we will rely on our Clearing Firm to provide cashiering functions including ensuring delivery of funds and securities on a DVP/RVP basis and to develop and maintain its own BCP in the event of an SBD.

Rules: FINRA Rules 3510(c)(2) & (g)(1).

10. Alternate Communications Between the Firm and Customers, Employees and Regulators

A. Customers

We now communicate with our customers using regular mail, overnight delivery service, telephone and e-mail. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by e-mail but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the regular mail.

Rule: FINRA Rule 4370(c)(4).

B. Employees

We now communicate with our employees using telephone and e-mail. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. We will also employ a call tree so that senior management can reach all employees quickly during an SBD. The call tree includes all staff home and office phone numbers.

Rule: FINRA Rule 4370(c)(5).

C. Regulators

We are a member firm of FINRA. We communicate with our regulators using regular mail, overnight delivery service, telephone, fax and e-mail. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.

Rule: FINRA Rule 4370(c)(9)

11. Critical Business Constituents, Banks, and Counter-Parties

A. Business constituents

Enclave regularly evaluates the reliability of its critical business constituents (businesses with which the Firm has an on-going commercial relationship in support of its operating activities, such as vendors providing critical services), in order to determine the extent to which the Firm may be able to continue its business relationship with each vendor during any possible internal or external SBD occurring to that vendor. Where possible, the Firm will establish alternate arrangements to mitigate the effect of an SBD rendering a business constituent unable to provide needed goods or services.

Enclave considers the following vendors to be major suppliers and is developing alternatives to these suppliers, some of whom are listed as well:

Message Archiving: SECCAS, 2 Penn Plaza, Suite 1990, New York, New York 10121, Brian Park; Phone: 212-242-9308; Fax: 212-242-9355

Accounting/FINOP: Greg Vittor, 19 Swinton Ave, Delray Beach, Florida, 33444, 561-901-0050

Audit:

Rules: FINRA Rule 4370(c)(7).

B. Bank

We have contacted our bank to determine if it will make financing available if necessary in light of the internal or external SBD. The bank maintaining our operating account is:

Signature Bank

300 Park Avenue

New York, NY 10022

Chris Efstratiou

646-822-1500

Rules: FINRA Rule 4370(c)(7).

C. Counter-Parties

We will contact our critical counter-parties, including other broker-dealers and institutional customers, to determine if we will be able to carry out our transactions with them in light of an internal or external SBD. Where the transactions cannot be completed, we will work with our Clearing Firm or contact those counter-parties directly to make alternative arrangements to complete transactions as soon as possible.

Rules: FINRA Rules 4370(a) &(c)(7).

12. Regulatory Reporting

Our Firm is subject to regulation by FINRA and the SEC. We now file reports with our regulators using paper copies in the regular mail or an overnight delivery service and electronically using fax, e-mail, and the Internet. In the event of an SBD, we will check with the SEC, FINRA and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.

Rule: FINRA Rule 4370(c)(8).

13. Disclosure of Business Continuity Plan

We will provide in writing a BCP disclosure statement by mail or attach by email to customers upon request.

Rule: FINRA Rule 4370(e).

14. Updates and Annual Review

Our Firm will update this plan whenever we have a material change to our operations, structure, business or location. In addition, our Firm will review this BCP annually, by December of each year, to modify it for any changes in our operations, structure, business, or location.

Rule: FINRA Rule 4370(b).

15. Senior Manager Approval

I have approved this Business Continuity Plan as reasonably designed to enable our Firm to meet its obligations to customers in the event of an SBD."

Rule: FINRA Rule 4370(d).

Signed: Joel Mathews

Title: Chief Compliance Officer

Date: April 4, 2024"

EXHIBIT A - Business Continuity Plan (BCP) Summary Disclosure

Overview

Enclave Capital LLC (“Enclave”; “the Firm”) has created and implemented a business continuity plan (“BCP”) in an effort to mitigate the effects related to unforeseen business interruptions. This BCP is designed to enable the Firm to continue or resume trading operations in the event of an emergency or significant business disruption (“SBD”).

Communications and locations of Employees during a disruption

In the event of a SBD, Enclave will communicate with its employees in several different ways. The Firm will employ a calling tree, which would be implemented by management in the event of an SBD. The BCP also addresses the relocation of staff to an alternative back-up location, which would be immediately available with all of the equipment needed to run the Firm’s client order receipt and transmission operations for an interim period of time. Recovery time for most of the applications and relocation to the alternate location is expected to range from immediate to 24 hours.

Communications with Customers

Enclave currently communicates with its customers using the telephone, email, and the US Mail. In the event of an SBD, Enclave will assess which means of communication are still available and use the means closest in speed to the means used in the past. Additionally, if traditional communications are not available, Enclave representatives will use the best available means to contact its clients in order to make contingent plans for the duration of the SBD.

Contacting Us

If after a significant business disruption, you cannot contact us as you usually do at 646-454-8600 or aing@enclavecapital.com, you should call our alternative number 917-459-7906.

Books & Records

Enclave maintains its hard copy books and records and electronic records primarily at its Main Office and back-up books and records at alternate locations. If records are lost as the result of a business disruption, Enclave has the means to physically recover data from both physical and electronic back-up locations.

Vendors and Counterparties

Enclave’s BCP may need to rely upon the recovery and restoration of services provided by various critical business constituents and counterparties both at its primary and alternate locations. Enclave has considered the extent to which the Firm may be able to depend upon these business relationships during an SBD as a part of its decision to do business with the constituents. Where possible the Firm has engaged and/or vetted alternate arrangements in order to avoid business disruptions in the case of a business constituent not being able to provide needed goods or services in an emergency.

Disclosure

Enclave’s BCP is designed to address the continued operation of the Firm in the event of an emergency situation or SBD. However, all risks of business interruption cannot be eliminated and Enclave cannot guarantee that systems will always be available or recoverable following an SBD. Furthermore, Enclave has no control over and must rely upon the disaster recovery plans of its various critical business constituents, vendors, clearing firms and counterparties. In the event that material changes are made to this BCP, Enclave will send an updated copy to all of its clients.

___________________

The information contained in this disclosure is provided by Enclave for informational purposes only, and nothing contained herein shall be construed to amend, supplement or otherwise modify any f the terms and conditions set forth in any customer agreement between you and Enclave.

Enclave Capital LLC

Form CRS (Customer Relationship Summary)

April 2024

Enclave Capital LLC (“Enclave”) is registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer and is a member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). We primarily provide investment banking and other services to you.

Brokerage and investment advisory services and fees differ. It is important for you to understand these differences. Free and simple tools are available to research firms and financial professionals at www.investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers and investing.

WHAT INVESTMENT SERVICES AND ADVICE CAN YOU PROVIDE ME?

Enclave offers brokerage services to individual (or “retail”) investors consisting of introductions to investment banking transactions, where capital is raised for operating companies or investment entities. We do not open accounts, buy or sell securities on behalf of our retail customers, accept discretionary authority, hold customer securities or funds, clear trades or monitor investments. Brokerage firms other than Enclave provide a wider range of services for the average retail investor and consideration should be given to contacting those brokerage firms.

We introduce investments in securities transactions to retail investors who qualify as accredited investors. Most of these securities are exempt from registration with the SEC and therefore are not freely tradeable on any stock exchange or other securities market. These securities can carry significant risks, including loss of some or all of your investment, the inability to sell your investment and a lack of publicly available information concerning the issuer.

Enclave does not maintain custody of our clients’ funds or securities; instead, all funds and securities are held at the investor’s account with a bank, custodian or investment adviser. We will not monitor your account; however, we do review your existing investments in light of any transactions we introduce to you to ensure those transactions are in your best interests.

In a typical investment banking transaction, you will pay the purchase price for the securities being acquired directly to the issuer or to an escrow account set up by the issuer. The issuer will accept your funds and, upon receipt, provide evidence of your investment, which may take the form of an executed copy of a subscription agreement, an electronic book entry on the issuer’s stock records or through the delivery of paper certificates.

You do not pay a separate fee when entering into an investment banking transaction; rather, the issuer pays a fee to Enclave for raising the capital. While Enclave does not charge you a fee, the fee payable by the issuer reduces the capital available to the issuer from the capital raise. In addition, Enclave’s receipt of a fee for raising capital creates a conflict of interest in that Enclave will benefit economically as a result of your investment in a transaction we introduce to you.

Please see our website at www.enclavecapital.com for a more detailed explanation of the products and services we offer.

Conversation Starters.

Ask your financial professional -

Given my financial situation, should I choose a brokerage service? Should I choose an investment advisory service? Should I choose both types of services? Why or why not?

How will you choose investments to recommend to me?

What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean?

WHAT FEES WILL I PAY?

You do not pay a fee to Enclave when entering into an investment banking transaction; rather, the issuer pays a fee to Enclave for raising the capital. The fee is typically in the range of 5-8% of the amount raised, and may include warrants to purchase the issuer’s shares at or around the current price. While Enclave does not charge you a fee, the fee payable by the issuer reduces the capital available to the issuer from the capital raise, and any warrants granted by the issuer might dilute the value of the issuer’s outstanding shares. In addition, Enclave’s receipt of a fee for raising capital creates a conflict of interest in that Enclave will benefit economically as a result of your investment in a transaction we introduce to you.

For additional information regarding fees, please contact your Enclave Representative.

Conversation Starters.

Ask your financial professional -

Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?

In an investment banking transaction, the entire $10,000 will be invested in the issuer’s securities. As described above, the issuer will pay a fee to Enclave for raising the capital you invest.

What are your legal obligations to me when providing recommendations? How else does your firm make money and what conflicts of interest to you have?

We are required always to act in your best interests in connection with introducing you to a potential transaction. We do not provide recommendations. We make money by charging fees to issuers for which we raise capital. These fees create conflicts of interest in that Enclave will benefit economically from your investment.

Conversation Starters.

Ask your financial professional -

How might your conflicts of interest affect me, and how will you address them?

For additional information about our conflicts of interest, please contact our office at (646) 454-8600.

HOW DO YOUR FINANCIAL PROFESSIONALS MAKE MONEY?

Enclave’s Registered Representatives do not make recommendations. They are generally paid a percentage of the fee paid to Enclave by the issuer of securities in an investment banking transaction.

DO YOU OR YOUR FINANCIAL PROFESSIONALS HAVE LEGAL OR DISCIPLINARY HISTORY?

No. Visit www.investor.gov/CRS for a free and simple search tool to research us and our financial professionals.

Conversation Starters.

Ask your financial professional -

As a financial professional, do you have any disciplinary history? For what type of conduct?

For additional questions about our firm, services, background, to request a free, current copy of our Form CRS or if you have any concerns with how you are being treated by an employee of our firm, please call (646) 454-8600 or look up our firm on brokercheck.org.

Conversation Starters.

Ask your financial professional -

Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?