Business Continuity Plan
The firm’s two emergency contact persons are as follows:
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. In the event that we determine we are unable to continue our business, we will contact all affected parties.
Our plan anticipates two kinds of Significant Business Disruptions (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 prevent the operation of the securities markets or a number of firms, 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.
Our firm does not maintain customer accounts or carry out any transactions on behalf of its customers, therefore, no disruption to customer trading or customers receiving their assets will be affected by a firm SBD. However, in the event of an internal or external SBD, if telephone service is available, our registered persons will try to contact the hedge funds on behalf of its customers.
The firm backs up its electronic records daily with a backup service and weekly on a flash drive and keeps a copy of its records off site. Additionally, hard copies of some records are kept off site.