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Business Continuity Disclosure Policy

Hadley Partners, Incorporated (the “Firm”) is a FINRA-registered broker/dealer providing investment banking services to its customers.  Accordingly, the Firm is furnishing this document to provide information about its efforts to ensure that the Firm’s operations will not be significantly impacted as a result of an emergency or significant business disruption.

Securities industry regulations require each member firm to create and maintain a business continuity plan reasonably designed to meet its obligations to its clients or other counterparties.  In accordance with these requirements, the Firm has designed a business continuity plan to address possible scenarios to minimize any service impact to our clients.

In keeping with the regulatory requirements, the business continuity plan of the Firm is designed to address key areas of concern, including but not limited to the following:

  • Data back-up and recovery
  • All mission-critical systems
  • Financial and operational assessments
  • Alternate means of communication between the Firm and its customers
  • Alternate means of communication between the Firm and its personnel
  • Alternate physical location of personnel
  • Critical business constituent, bank and counterparty impact
  • Regulatory reporting
  • Communications with regulators; and
  • How the Firm will ensure that customers have access to their funds and securities in the event that the Firm determines it is unable to continue its business.

 

Since events creating business disruptions may vary in nature and scope, the Firm has anticipated scenarios in which the following occur:

  • A disruption to the Firm’s primary or main office location
  • A disruption to a single building in which the Firm’s main office is located
  • A disruption to the business district or city where the Firm’s primary systems are located
  • A disruption to the region where the Firm’s primary systems are located

 

Regardless of the scope of potential disruption, the Firm intends to continue to provide services to its clients.

A Disruption to the Firm and/or a Single Building

In the event that there is a significant business disruption to the Firm and/or the building in which the Firm is located, the Firm has duplicative systems that will be operated from a separate back-up (“alternate”) site.  This disruption may be caused by physical damage, technology problems, or an inability to have personnel arrive at the office.  As such, the Firm will transfer its operations to one or more designated alternate site(s) located in the same city or in adjoining cities that are sufficiently separated from the Firm’s main operations.  The alternate site will be used to restore internal operations as well as electronic access and communications as soon as key personnel are relocated to the designated sites.  In this process, Clients may experience a minor delay in reaching the Firm due to increased telephone calls, technology delays or other minor difficulties arising from the transfer of operations.  The Firm expects that any delay will be less than 12 hours.  Nevertheless, the unlikely failure of the telephone or other ancillary communications systems could result in a delay of up to 24 hours.

A Business-District, Citywide or Regional Disruption

In the event that there is a significant business disruption that affects the business district or city where any of the Firm’s primary systems are located, the Firm will transfer operations to its designated back-up site located in a separate and distinct business district and city from its main operations.  The alternate site will be used to restore internal operations, electronic access and communications as soon as key personnel are relocated to the site.

In the event of a significant business disruption to the region where the Firm’s primary systems are located, the Firm would intend to take advantage of any available branch or other facilities that may be located in other geographical regions to use in a limited capacity to resume operations temporarily.  As a secondary back-up, the Firm may enter into a “BCP Joint Pact” with another broker/dealer or similar firm that currently operates in an adjoining region that will effectively leverage the use of technology and infrastructure to continue operations.  Under the BCP Joint Pact, the selected firm will be determined as sufficiently capable to operate as a designated back-up facility.  In this process, clients may experience delays in reaching the Firm due to increased telephone calls, technology delays or other difficulties arising from the transfer of operations.  The Firm expects that any delay will be less than 24 hours.

Nevertheless, please be aware that due to the unpredictability of events, there can be no assurance that service will continue without interruption in certain circumstances, such as a regional blackout, a natural disaster or a terrorist attack.  However, in the unlikely event that the Firm has determined that it cannot resume operations within a reasonable amount of time, it will provide as much advance notice as possible regarding its ongoing operations.

Please be advised that the Firm’s business continuity plan is reviewed and updated on an annual basis and subject to change and modification.  Therefore, any changes and updated information will be promptly posted on the Firm’s web site at www.hadleypartners.com.  Alternatively, customers may obtain a copy of the Firm’s business continuity plan by requesting a written copy in writing.