Business Continuity Plan
I. Statement of Policy
This Business Continuity and Disaster Recovery Plan (the â€śContinuity Planâ€ť) of the Adviser aims to provide its employees and clients with procedures to follow in an emergency. These procedures should outline the types of disasters that could occur and the potential impact on operations of each such disaster (including, without limitation, interruptions due to fire, flood, earthquakes, power outages, elements of nature and acts of God, acts of war, terrorism, riots, civil disorders, rebellions and/or revolutions).Â These procedures are designed to ensure that business will resume and continue as quickly and efficiently as possible in the event of any short-term or long-term significant business disruption.
A. Adviser-Staff Communications
The Adviser has created the following procedures to accommodate communications between the Adviser and its personnel:
Current Contact Information
- A readily available list of contact information (including home, work, cellular and e-mail contact information) of all personnel will be actively maintained and on file with the Compliance Officer for the purpose of locating and communicating with staff.
Alternate Communications Plan
- A phone â€śchainâ€ť will be put into use at the direction of the Compliance Officer or a designated â€śhotlineâ€ť will be established for personnel for the purpose of locating and communicating with staff.
B. Adviser-Client Communications
The Adviser has created the following procedures to accommodate communications between the Adviser and its clients:
- In the event of an emergency, the Adviser will contact its clients as considered necessary with instructions as to how it will continue with transactions and services.Â Client communications will be conducted under the primary direction of the Managing Member of the Adviser, who will review and/or approve all communications with clients regarding the interruption and continuation of services.Â In the absence of the Managing Member of the Adviser, the Compliance Officer will perform this responsibility.
C. Business Constituent, Bank, and Counter-Party Communications
The Compliance Officer will maintain a readily available list of contact information (including work and e-mail contact information) of senior personnel for clearance and settlement organizations, banks, administrators, prime brokers, counterparties, regulators and other key business relationships.
- In the event of an emergency, the Compliance Officer will oversee the process of contacting these companies with information regarding the interruption and continuation of services.
III. Relocation and Out-of-Office Emergency Plan
In the event that personnel are unable or advised not to come to the Adviserâ€™s offices, all personnel should be prepared to attempt to accomplish their roles under the Continuity Plan from their home or other safe location.
IV. Data Management
- Adviser specific procedures are tailored to the firm — including information regarding continuation of trading and settling capability, etc.
B. Data back-up and recovery (hard copy and electronic)
- Data and systems information is stored daily at a back-up location geographically separate from the primary systems and records.
- All critical computer equipment (including PCs, servers, communication and telephone equipment) is protected by a local and central Uninterrupted Power Supply (UPS).Â Our critical systems have [hot swappable disk drives in a RAID (Redundant Array of Independent Disks) configuration in the event of a disk drive failure].Â Our database is stored on [a clustered server that provides automatic fail-over to a parallel server should any aspect of the primary server fail.
- All workstations and servers are backed up nightly by a third party service provider. The provide checks daily that the backups have been performed correctly.
- Back-up facilities are able to handle the same volume of trading as the primary facility.
V. Testing Procedures
A. Financial and Operational Assessments
- The Adviser will periodically, at least annually, evaluate its Continuity Plan to assess whether its operations can continue without significant disruption in the event of an emergency.
B. Third Party Assessments
- The Adviser will consider the impact of business interruptions encountered by third parties and will identify ways to minimize that impact on the business of the Adviser.
- The Adviser will monitor and analyze the impact of a third partyâ€™s business and continuity plan and how such operations will affect the Adviser.
VI. Regulatory Reporting
The Compliance Officer will, if requested, provide the SEC with a copy of the Adviserâ€™s Continuity Plan.
VII. Critical Employee Provisions
All critical employees have the same access to all systems and data.
VIII. Long-Term Planning / Recovery
The Adviser will evaluate the adequacy of the procedures set forth above to assess whether its operations can continue without significant disruption over the long-term in the event of an extended emergency of unknown duration.