BUSINESS CONTINUITY PLAN (BCP) Version Revised 10/2013

Transcription

1 EMERGENCY CONTACT PERSONS BUSINESS CONTINUITY PLAN (BCP) Version Revised 10/2013 Panoptic Fund Administration, LLC ( Panoptic or the Firm ) has designated two emergency contact persons. Such persons will be members of senior management and principals of the Firm. Primary Contact Name: Jeff Lambert, Senior Partner jeff.lambert@panopticadmin.com Phone: Office Cell Home Secondary Contact Name: Kraig Kupiec, Partner kraig.kupiec@panopticadmin.com Phone: Office Cell Home Other Contacts FIRM POLICY Name: Georgia Goodman, Operations Manager georgia.goodman@panopticadmin.com Phone: Office Cell Home Name: Michael Waldron, IT Consultant mike@waldron.net Phone: Office Cell This 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, protecting the Firm s books and records, and allowing our clients to transact business. In the event that we determine we are unable to continue our business, we will assure clients prompt access to their data. Significant Business Disruptions Our plan anticipates two kinds of SBDs: internal and external. Internal SBDs affect only our Firm s ability to communicate and do business. Examples of internal SBDs include office floods, fires, or the inability of the partners/principals to perform their professional duties. External SBDs affect our Firm and/or any number of

2 firms in the industry. Examples of external SBDs include city floods, earthquakes, flu pandemics, terrorist attacks or regional disruptions, such as city- wide power outages. Our response to an external SBD relies heavily on other organizations and systems, including the capabilities of our associated firms. Approval and Execution Authority Jeff Lambert, the Senior Partner, is responsible for approving and executing the plan. Kraig Kupiec, a Partner, is the secondary contact for executing the plan. Georgia Goodman, Director of Operations, is responsible for conducting the required annual review of the plan. Plan Location and Access Our Firm maintains hard and electronic copies of the BCP in the main office. Annual reviews and a record of any changes made to the BCP are kept in hard copy in the main office. The BCP is also distributed to all employees when revised. The emergency contact persons, the Director of Operations, and the IT Consultant also maintain hard copies in their homes. BUSINESS DESCRIPTION Panoptic is a hedge fund administration and accounting firm. OFFICE LOCATIONS Panoptic has two office locations: 2400 Broadway Suite 220 Santa Monica, CA Rosecrans Ave Suite 4195 El Segundo, CA Main Phone: Our employees generally live approximately 1-30 miles from each office location. While automobile is the primary method of travel to the office, employees would be able to, in an emergency situation and where reasonable, work from home, take public transportation if available (i.e. light rail trains, buses), walk, or ride a bicycle. Fund accounting, operations, administrative functions, and record retention occur in the Santa Monica office. Internal accounting occurs in the El Segundo office. If the Firm s personnel and guests are required to exit the building in an emergency situation, the Firm s standard evacuation route will be the closer of the three (3) main emergency exits on the floor of each office. Santa Monica location: Once evacuated, all employees should proceed directly to the off- site location (basketball courts east of the building) and await further aid and instructions. El Segundo location: Once evacuated, all employees should proceed directly to the off- site location (the east side of Douglas St. where Park Place ends, in front of the Hyatt House parking lot near the stop sign) and await further aid and instructions. 2

3 ALTERNATIVE PHYSICAL LOCATIONS Rarely do we have visitors to our office, so it is important to note that our business model does not include clients physically visiting our location. Communications are typically via regular mail, overnight courier, , and telephone. Further, our website is hosted off- site subject to external redundancies and back- up procedures. If there is an SBD in the El Segundo or Santa Monica areas and one or more of the offices are inaccessible, then we will determine whether operations should move to a temporary location in the region. Should one of the two locations be accessible and operational, operations will be moved to this location. Based on the type of SBD and other factors, senior management will decide on what type of temporary location is the most convenient, practical, and accessible. The first and most likely location would be a virtual location, with employees working out of their homes. Senior management have access to vital systems from their homes. All other employees have the ability to communicate and work from their homes, using telephones and home computers that have internet access. Depending on the circumstances and whether the SBD is local or regional or even more widespread, the other choices for a temporary location are: 1) office space that can be quickly and temporarily leased; 2) the home of Jeff Lambert, Senior Partner; 3) the home of Kraig Kupiec, Partner. PHYSICAL RECORDS Besides the technology and data within the Firm s computer systems and software, the Firm also has many vital physical records and assets that are stored in the Santa Monica office, such as: - An inventory listing of all information technology systems, including hardware and software; - Firm financial and insurance records; - Contracts; - Agreements; - Client files; - Compliance- related documents and files; and - Other paper- based documents that must be protected. Although preserving these records is necessary and important, they are not critical in restoring operations during an emergency. DATA BACK- UP AND RECOVERY Critical firm and client data is maintained electronically on our and our custodians computer network/storage systems. Such networks are subject to Data Back- up and Recovery policies and procedures which are consistent with requirements for firms which engage in the business of hedge fund accounting and administration. This data alone is sufficient to provide mission critical information to each of our clients. VMware (Virtual Machine/Virtualization Platform) runs on the firm s data servers and is copied nightly to a backup device in the main office. On a weekly basis, the virtual machines are copied onto an external hard drive and are taken offsite for safekeeping (2 revolving backups). Georgia Goodman is responsible for safekeeping the external hard drive at a secure location in her home. The Firm s e- mail accounts are hosted with Microsoft Office 365 and are cloud- based; in the event of a SBD e- mail would be unaffected. Client statements and accounting generation data is stored at Office 365 in Sharepoint, also a cloud- based system. All local storage documents and user files required for operation are backed up nightly to the cloud service Mozy. The accounting system, Peachtree, and other financial data can 3

4 also be accessed remotely by the two partners. Other data is kept in hard- copy form only. These documents, however, are not critical to operations and are maintained in the office by authorized personnel. KEY PERSONNEL The Firm acknowledges that the successful implementation of its hedge fund administration and accounting duties have historically been based on the efforts of certain Key Personnel. The Firm relies on various partners, officers, staff, and service providers in the successful implementation of its operations and reporting cycles. We believe we have cross- trained our staff such that in the event of an occurrence rendering a responsible person incapable of fulfilling his or her duties, operations and reporting may be delayed but will not produce inaccurate results. In the event of a material occurrence rendering a responsible person incapable of fulfilling his or her duties, the Firm will not authorize the release of clients NAV, statements, and accounting data until such time all remaining officers of the Firm have been satisfied that critical capital and computational reconciliations have been performed. FINANCIAL REPORTING AND OPERATIONAL ASSESSMENTS Operational Risk In the event of an SBD in the Los Angeles area, financial reporting and operational requirements will require a situational analysis as to moving to a new/temporary location in the region. Pre- established means of communication are critical to operations. Connections to the required WANs are redundant via the Internet and are, therefore, easily reproducible from various locations. Critical historical and current client files, books and records and other data is available via VMware which can be restored utilizing commonly available tools and systems. Any paper- based documents that are lost are not critical to operations and most can be replaced. MISSION CRITICAL SYSTEMS The Firm s mission critical systems are listed below: Communication systems: Connections to Internet Internet browser Avaya telephone system Applications residing on Panoptic s systems: Peachtree accounting system Quickbooks accounting system FIXQ portfolio reporting system Web- based reporting system for fund statements Microsoft Office Applications residing on Microsoft Office 365: E- mail system Sharepoint internal document database 4

5 ALTERNATIVE COMMUNICATIONS BETWEEN THE FIRM AND CUSTOMERS AND EMPLOYEES Clients The Firm now communicates with clients using the telephone, e- mail, website, fax, U.S. mail, overnight mail and in person. In the event of an SBD, the Firm will assess which means of communication are still available and use the means closest in speed and form (written or oral) to the means used in the past to communicate with our clients. Employees We now communicate with our employees using the telephone, e- mail, IM, and in person. 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 (using either phone or text messages, whichever is available) so that senior management can reach all employees quickly during an SBD. The call tree includes all staff home and office phone numbers. The person to invoke use of the call tree is: Jeff Lambert, Senior Partner. Caller Senior Partner Partner Operations Manager Call Recipients Partner Operations Manager Other employees We also have identified persons, noted below, who live near each other and may reach each other in person if other means of communication are not available: South Bay area: Santa Monica area: Kraig Kupiec, Partner Manhattan Beach Jeff Lambert, Senior Partner Manhattan Beach Georgia Goodman, Director or Operations Malibu Matt Pringle, Account Executive Santa Monica CRITICAL BUSINESS CONSTITUENTS Business constituents We will quickly establish alternative arrangements if a business constituent (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services) can no longer provide the needed goods or services when we need them because of an SBD to them or our Firm. Our major suppliers include the following: building property management, Premier Business Bank, Peachtree, e- mail provider, land- line telephone systems and service, cell phone service providers, and our internet service provider. Banks 5

6 In the case of an internal or external SBD, we will contact our banks and lenders to determine whether they can provide any financing that we may need. The bank maintaining our main operating account is Premier Business Bank. DISCLOSURE OF BUSINESS CONTINUITY PLAN Panoptic s BCP disclosure statement is posted on the Firm s web site ( where clients can view or print it. Our disclosure statement: Panoptic Management is committed to taking responsible steps to provide protection for essential activities and critical support services should a significant business disruption result from events such as power outages, natural disasters, or other situations. Panoptic Management established a Business Continuity Plan intended to protect processes and client data while enabling continued operation of critical functions during or immediately following a disruption. In the case of a significant business disruption, please visit our website at for updates and additional information. Our Business Continuity Plan is tested annually and includes consideration for communication critical processes, personnel, technology, functions, and associated recovery times. Panoptic Management continually assesses and updates our Business Continuity Plans. However, no contingency plan can eliminate all risk of service disruption. Our ability to resume critical functions is also dependent upon the Business Continuity Plans established by third parties, including custodians, vendors and utilities. Because we constantly upgrade our ability to recover, our Business Continuity Plan is subject to modification without notification. UPDATES AND ANNUAL REVIEW The policies and procedures contained in this Plan will be updated whenever there is a material change to the Firm s operations, structure, business or location or to those of our custodian firms. In addition, the Plan will be reviewed on an annual basis. TEST AND MAINTENANCE OF PLAN Annually, the Director of Operations or an independent 3rd party will test the plan to make sure that it is sufficient to meet the Firm s needs against potential disasters. 6

7 SENIOR MANAGEMENT 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. Signed: Jeff Lambert, Senior Partner Date: Signed: Kraig Kupiec, Partner Date: 7