Business Continuity Plan (BCP)

Transcription

1 Business Continuity Plan (BCP) 1

2 I. Emergency Contact Persons Our firm s two Emergency Contact Persons designated under Rule 3520 are Steve Chmielewski and Will Geyer. Their contact information is: Steve Chmielewski Office Phone Office Fax [email protected] Mobile Phone Home Phone Will Geyer Office Phone Office Fax [email protected] Mobile Phone Home Phone These names will be updated in the event of a material change, and our Executive Representative will review them annually or within 17 business days of the end of each quarter if there is a material change. II. 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, protecting all of the firm s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, our customers will be directed to Pershing LLC (Pershing), JonesTrading s clearing firm for instructions on access to the customers 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 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, especially on the capabilities of our clearing firm. Our policy is to provide uninterrupted service to our customers and uninterrupted access to customer s funds or securities. JonesTrading does not maintain custody of customer s funds or securities. JTIS and JTIL clear all transactions through Pershing LLC ( Pershing ). JTC clears all transactions through Penson Financial Services Canada Inc. ( Penson ) The Contacts for Pershing are listed in Appendix 4, and the contacts for Penson are listed in Appendix 5. B. Approval and Execution Authority 2

3 Lawrence Harasym, Chief Compliance Officer, a registered principal, is responsible for approving the plan and for conducting the required annual review. Steve Chmielewski, Chief Operating Officer 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: \\newbudjones\bigdrive\dept shared\business_continuity_plan III. Business Description By way of background, the JonesTrading Group of companies consists of JonesTrading Institutional Services LLC ( JTIS ), JonesTrading International Limited ( JTIL ), and JonesTrading Canada Inc. ( JTC ) (herein the JonesTrading Group or the Group ). The JonesTrading Group specializes in agency executions and crossing blocks of equities, debt, and options for our customer base, which is primarily comprised of institutional money managers and corporate accounts. JonesTrading Institutional Services LLC has an Investment Banking/Capital Markets Department that engages in underwritings, private placements and corporate advisory activities. The JonesTrading Group of companies are introducing firms and do not perform any type of clearing function for itself or others. The JonesTrading Group does not hold customer funds or securities, our focus is the execution of orders. All transactions are compared and allocated by JonesTrading operations. Our clearing firms Pershing and Penson clear and settle the trades. Pershing and Penson maintain our customers accounts, can grant customers access to them, and delivers funds and securities. Contact information for Pershing personnel is located in Appendix 4 to this BCP. Pershing has posted its Business Contingency Plan at The contact information for Penson personnel is located in Appendix 5 and has posted its Business Continuity Plan at IV. Office Locations The Group currently has 12 offices locations: Main Office: Westlake Village, CA Our Main Office is located at Lindero Canyon Road, Suite 208, Westlake Village, CA Its main telephone number is or Books and records for JTIS, JTC, and JTIL are maintained at this office. Our employees may travel to that office by means of foot, car or bicycle. We engage in order taking and entry, trade reporting, settlement and operations, Information Technology, Accounting and Finance, and Human Resources at this location. Mill Valley Branch Office Our Mill Valley Branch Office is located at 655 Redwood Highway, Suite 101, Mill Valley, CA Its main telephone number is or Our employees may travel to that office by means of foot, car or bicycle. We engage in order taking and entry at this location. 3

4 Portsmouth Branch Office Our Portsmouth Branch Office is located at 28 Deer Street, Suite 401, Portsmouth, NH Its main telephone number is or Our employees may travel to that office by means of foot, car or bicycle. We engage in order taking and entry at this location. Heathrow (Orlando) Branch Office Our Heathrow Branch Office is located at 250 International Parkway, Suite 208, Heathrow, FL Its main telephone number is or Our employees may travel to that office by means of foot, car or bicycle. We engage in order taking and entry at this location. New York Branch Office Our New York Branch Office is located at 780 Third Avenue, 3 rd Floor New York, NY Its main phone number is or The office is the primary location for JTIS s Capital Markets, Convertible Trading and Debt Trading. Our employees may travel to that office by means of foot, car, bicycle, train, boat, or bus. We engage in order taking and entry at this location, administrative functions, and our Investment Banking/Capital Markets business is located here. Dallas Branch Office Our Dallas Branch Office is located at 300 Crescent Court, Suite 150, Dallas, TX Its main telephone number is or Our employees may travel to that office by means of foot, car or bicycle. We engage in order taking and entry at this location. Boston Branch Office Our Boston Branch Office is located at 265 Franklin St. 18 th Floor, Boston, MA Its main telephone number is or Our employees may travel to that office by means of foot, train, car or bicycle. We engage in order taking and entry at this location as well as administrative functions. Atlanta Branch Office Our Atlanta Branch Office is located at 3290 Northside Parkway, Suite 325, Atlanta, GA Its main telephone number is or Our employees may travel to that office by means of foot, car or bicycle. We engage in order taking and entry at this location. Aspen Branch Office Our Aspen Branch Office Location is located at 602 E Cooper Avenue, Suite 201, Aspen, CO Its main telephone number is or Our employees may travel to that office by means of foot, car or bicycle. We engage in order taking and entry at this location. Greenwich Branch Office Our Greenwich Branch Office Location is located at One Fawcett Place, Suite 290, Greenwich, CT Its main telephone number is or Our employees may travel to that office by means of foot, car, train, or bicycle. We engage in order taking and entry at this location. 4

5 Chicago Branch Office Our Chicago Branch Office Location is located at 223 West Erie St., Suite 4SW, Chicago, IL Its main telephone number is or This office is the primary location of the JTIS Derivatives Department. Our employees may travel to that office by means of foot, train, car, or bicycle. We engage in order taking and entry at this location. Charleston Branch Office Our Charleston Branch Office Location is located at 360, Concord Street, Suite 202, Charleston, South Carolina Its main telephone number is or Our employees may travel to that office by means of foot, car, or bicycle. We engage in order taking and entry at this location London Office Our wholly owned subsidiary JonesTrading International Limited has its registered office at 1 Liverpool Street, London, England EC2M 7QD. Its main telephone number is (001) For purposes of this BCP JonesTrading International will be treated as a branch office for the Group. The operations for the JonesTrading International are conducted at 38 Belchamps Way, Hawkwell, Essex United Kingdom SS5 4NU. Toronto Office This is the Main office for JonesTrading Canada Inc. (JonesTrading Canada or JTC) and its registered office at 148 Yorkville Avenue York Square 2 nd Floor, Suite 5, Toronto, ON M5R 1C2. Its main telephone number is or Our employees may travel to that office by means of foot, train, car, or bicycle. We engage in order taking and entry at this location. V. Alternative Physical Location(s) of Employees In the event of an SBD in which we do not have either access or working access to one of our offices, we will evaluate the anticipated amount of down time for that office. If necessary we can move our Trading personnel from affected office(s) to the closest of our unaffected office locations. Key operational staff members are equipped with laptop computers so that they can connect to the company network from their homes or any place with an Internet connection including another JonesTrading office. VI. Customers Access to Funds and Securities The Group of companies does not maintain custody of customers funds or securities, which are maintained at our clearing firms Pershing and Penson. In the event of an internal or external SBD, if telephone service is available we will conduct business as usual, executing customer orders or and taking instructions for Pershing on their behalf. If our Web access is available, we will post on our Web site that customers may access their funds and securities by contacting Pershing at and Penson at JonesTrading will make this information available to customers through our disclosure policy. 5

6 If SIPC determines that JTIS is unable to meet its obligations to its customers or its liabilities exceed its assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers. JTIS will assist SIPC and the trustee by providing its books and records identifying customer accounts subject to SIPC regulation. VII. Data Back-Up and Recovery (Hard Copy and Electronic) JTIS, JTIL, and JTC maintain its primary hard copy books and records and its electronic records at the Main Office: Lindero Canyon Road, Suite 208, Westlake Village, CA CCO Lawrence Harasym is responsible for the maintenance of the following records relating to orders, transactions, account documentation, customer positions, customer correspondence, employee registrations, i.e. 17a-3(1), (3), (4), (5), (6), (7), (8), (9), (10), (12), (13), (14), (15), (16); 17a-4(4), (6), (7), and (11). JTIS, JTIL, and JTC maintain the following books and records that are not transmitted to their clearing firm: 1. Order and transaction records 2. New Accounts Database and documentation 3. and IM 4. Bank Wire instructions CCO Lawrence Harasym has instituted with CIO Adam Graves the following procedures for backing up electronic data. At the end of each month CDs of the above listed books and records are sent to the offices of Simpson & Associates CPA located at 1155 North Central Avenue, Suite 211, Glendale, CA and the JonesTrading Boston office. An additional copy of and IM messages are stored with Global Relay Communications, Inc. A firm approved by the FINRA, SEC and the NYSE, for electronic retention services, and Business Continuity. (SEC rule 17a-4; NASD rules 3110, 3010, and 3510; NYSE rules 440, 342, and 472. JonesTrading has established a co-location facility SBC at 2681 Kelvin, Irvine, California. Access to the facility is for authorized JonesTrading personnel only: Adam Graves (CIO) David Feng (Technology Manager) Jeff Veis (IT Technician) Justin Need (IT Technician) Anthony Thompson (IT Technician) The address is: 2681 Kelvin St. Irvine, CA JonesTrading will keep its primary servers at the Irvine facilities with backup servers at the Westlake Village office and each night the following servers are incrementally backed up. Then once a week the full tape back up is made for the Library unit. Once a month a full tape back up is taken off premises by an Iron Mountain storage secure service. 6

7 The servers are located as follows: Primary Server Backup Server Contains APP-SQL-1-P Irvine APP-SQL-1-B WLV JonesTrading Database, Broker FIX Database, ACT Database, Cold Call Database APP-SQL-2-P Irvine APP-SQL-2-B WLV New Accounts Database, FaceTime, Trader Portal, Trackplus APP-SQL-3-P APP-SQL-3-B FIX Drop copy for the NOW system Irvine NEWBUDJONES Irvine WL- FILESERVER1 Irvine WLV P Irvine JOURNALING Irvine WEB-IIS-1-P Irvine IM-MONITOR Irvine BOSQL Irvine PRODBOSQL Irvine FINANCE WLV DocumentServer Irvine WLV BUNEWBUDJONES WLV Irvine B WLV WEB-IIS-1-B WLV BUFINANCE Irvine BUDocumentServer WLV File server, Time Server File Server Servers Journaling Internal web server FaceTime Server Servicedesk MS Queue, backup server to Facetime MAS90 Accounting system New Account scanned documentation, P&S scanned documentation JTIS, JTIL and JTC store hard copy account documentation and bank wire instructions received from Customers at the Westlake Village office. These documents are scanned and stored on DocumentServer via the LaserFiche application in an electronic format. For the loss of electronic records, we will either physically recover the storage media or electronically recover data from our back-up records, or, if our primary site is inoperable, operations will continue from the nearest unaffected alternate branch office location. CFO Alan Hill is responsible for the maintenance of the company s financial records, i.e. 17a-3(2), (11); 17a-4(2), (3), (5), (8), and (10). 7

8 JTIS maintains the following books and records that are not transmitted to our clearing firm: 1. General Ledger 2. Trial Balance 3. Soft dollar paperwork 3. Bank Statements 5. Clearing Firm statements 6. Bills payable 7. Billing contracts CFO Alan Hill has instituted with CIO Adam Graves the following procedures for backing up electronic data. The Server below is backed up to a server in the Irvine facility and each night the following servers are incrementally backed up. Then once a week a full tape back up is made for the Library unit. Once a month a full tape back up is taken off premises by an Iron Mountain storage secure service. Primary Server Backup Server Contains FINANCE WLV BUFINANCE Irvine MAS90 files (general ledger, trial balance, vendor lists), Trader blotter files, soft dollar paperwork Hard copy account documents include: bank statements, clearing firm statements, bills payable and billing contracts. In the event of an internal or external SBD that causes the loss of our paper records, we will be able to request duplicate documentation from the vendor or counter party through internet access. If our Main Office is inoperable, we will continue operations from an alternate branch office location. For the loss of electronic records, we will either physically recover the storage media or electronically recover data from our back-up records, or, if our primary site is inoperable, operations will continue from the nearest unaffected alternate branch office location. JTIL has a contract for off site storage with Secure Data Management Ltd. The premises are known as Data Centre F1, Kemble Business Park, Kemble Gloucestershire GL7 6BA. JTIL keeps the following at this location: Office Bills, Stationary, Disaster Recovery Disks, Compliance Monitoring Programme, and old Client Files. VIII. Financial and Operational Assessments A. Operational Risk In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, critical counter-parties, and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include our public website located at an alternate website at telephone, and secure . In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic). 8

9 B. Financial and Credit Risk In the event of an SBD, Management will determine the value and liquidity of our investments and other assets to evaluate our ability to continue to fund our operations and remain in capital compliance. We will contact our clearing firms, critical banks, and investors to apprise them of our financial status. If we determine that we may be unable to meet our obligations to those counter-parties or otherwise continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps, including informing customers that we will no longer accept orders and referring customers to Pershing for information regarding access to funds as well as order and trade processing. IX. Mission Critical Systems Our firm s mission critical systems are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. We have the primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of order taking, entry, and execution. Our clearing firms provide, through contract, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. Our clearing firms maintain a business continuity plan and the capacity to execute that plan. Our clearing firms represent that they will advise us of any material changes to its plan that might affect our ability to maintain our business and have presented us with an executive summary of its plan, which is attached to this BCP as an Appendix. In the event our clearing firms execute their plan, they represent that they will notify us of such execution and provide us equal access to services as its other customers. If we reasonably determine that our clearing firms have not or cannot put its plan in place quickly enough to meet our needs, or is otherwise unable to provide access to such services, our clearing firms represent that they will assist us in seeking services from an alternative source. Our clearing firms represent that they back up our records at an out of region site. Our clearing firms represents that they operates a back-up operating facility in a geographically separate area with the capability to conduct the same volume of business as its primary site. Our clearing firms have also confirmed the effectiveness of its back-up arrangements to recover from a wide scale disruption by testing and have confirmed that theytest back-up arrangements annually. 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. Recovery refers to the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process new transactions and payments after a wide-scale disruption. Our clearing firms have the following SBD recovery time and resumption objectives: recovery time period of 24 hours and resumption time defined as soon as possible depending on the scope and magnitude of the SBD. 9

10 Our Firm s Mission Critical Systems Trading Department System Usage Contingency Fidessa Order Management and execution Each Branch has redundant direct connections to Fidessa s primary and redundant site. For FIX orders, customers will be instructed to send in order telephonically or through . Orders can be entered directly into DMA or Algorithmic services Bloomberg MIXIT Quotation and news vendor Order Management and executions Each office has redundant direct connections Each office has Bloomberg connections. Connectivity is also available via the internet. Each Branch has redundant direct connections to MIXIT s primary and redundant site. For FIX orders, customers will be instructed to send in order telephonically or through . Orders can be entered directly into applicable exchanges ACT Weblink ACT reporting If the SBD is only affecting the Westlake Office the functions will be performed in the Portsmouth Office. The Fidessa OMS has some NW II functions built in. If the SBD has taken down all connectivity to ACT Weblink, paper records will be made and input when ACT Weblink is functional. JTIS has an agreement with CSFB whereby JTIS can all in orders to their desk ( ).CSFB will print the trades in compliance with Reg NMS. TRACE Weblink TRACE Reporting If the SBD is only affecting the New York Office the functions will be performed in the Wesltake Office. The Operations Manager and CCO have access to report to TRACE. Internet access Internet access Instant Messenger Each office has redundant lines Customers can be contacted through voice services or Communication Each office is connected to the primary and back up server Customers can be contacted by voice services or Instant Messenger Customer FIX connections Electronic orders Customers can communicate orders through voice services, , or Instant Messenger Voice Services General communication Each office has redundant services Inbound calls can be forwarded to another office Electricity Computer usage Each office has battery UPS back ups The Main Office has a back up generator 10

11 Currently, JTIS, JTC, and JTIL receive orders from customers via FIX, telephone, and Instant Message. During an SBD, either internal or external, we will continue to take orders through any of these methods that are available and reliable, and in addition, as communications permit, we will inform our customers when communications become available to tell them what alternatives they have to send their orders to us. Customers will be informed of alternatives by calling our Customer Business Continuity Information line or visiting our public website at As soon as an office becomes unavailable the following steps will be taken: Phone traffic will be routed to another office. The Agency Desk in the Main office will handle automated order flow. The affected Office Manager and Executive Staff will determine whether to relocate staff to other offices. If the Main office becomes unavailable the following steps will be taken: Phone traffic will be routed to another office. The Portsmouth Office will be responsible for ACT reporting A branch office will be designated to handle automated order flow. All Traders have access to execution services in Fidessa. DOT execution limits will be increased to limits used by the Agency Desk. The Executive Staff will determine whether to relocate staff to other offices. Operations Department System Usage Contingency Fidessa Trade processing The Main Office has redundant direct connections to Fidessa s primary and redundant site. Trades can be processed through Net Exchange Pro Net Exchange Pro Pershing Trade processing system The Main Office has redundant direct connections to Pershing Net Exchange Pro can be accessed via internet Oasys Trade allocation Trades can be processed manually Global Oasys Trade allocations Trades can be processed manually Arrowlite Trade status update Penson will provide updates Penson IBM Trade status update Penson will provide updates Mixit Allocator Trade allocations Trades can be processed manually MS Office All computers have MS office installed Voice Services General communication The Main Office has redundant services Inbound calls can be forwarded to another office or site that Operations Staff is relocated to. Key personnel can be contacted by cell phone. Each office is connected to the primary and back up server Communication can be conducted through voice services or Instant Messenger Key personnel can be contacted by cell phone Electricity Computer usage Each office has battery UPS back ups The Main Office has a backup generator. In the event of an SBD that results in the Main Office not being available, the following steps will be taken: 11

12 Phone traffic will be routed to another office. The Pershing and Penson operations staff will be notified. The Executive Staff will determine whether to relocate staff to other offices. Even if the Operations Staff is unable to complete their regular work on a given day, an automated process is in place whereby transaction records are sent from Royal Blue to Pershing. The Operations staff will need to process breaks on the day following the unavailability of the Main Office or customers will be directed to speak to Pershing s and Penson s Operations directly. If Royal Blue is affected by an SBD, they will initiate their BCP plan. If all communications are lost with the OMS system, all executions will be retrieved from the executing venues by recovery of the electronic file that will be imported into the JonesTrading database. These real time execution files are received daily. Finance Department System Usage Contingency MAS90 All back up computers for finance personnel are installed with MAS 90 MS Office All backup computers for finance personnel are installed with MS Office Voice Services The Main Office has redundant services Inbound calls can be forwarded to another office or site that Finance Staff is relocated to Key personnel can be contacted by cell phone Each office is connected to the primary and back up server Communication can be conducted through voice services or Instant Messenger Key personnel can be contacted by cell phone Electricity Computer usage Each office has battery UPS back ups The Main Office has a backup generator. In the event of an SBD that results in the Main Office not being available, the following steps will be taken: Phone traffic will be routed to another office or location where the Finance staff is located. The Executive Staff will decide determine whether to relocate staff to other offices. IT System Usage Contingency Voice Services The Main Office has redundant services Inbound calls can be forwarded to another office or site that IT Staff is relocated to. Key personnel can be contacted by cell phone. Electricity Computer usage Each office has battery UPS back ups The Main Office has a backup generator Each office is connected to the primary and back up server Communication can be conducted through voice services or Instant Messenger Key personnel can be contacted by cell phone 12

13 In the event of an SBD that results in the Main Office not being available, the following steps will be taken: Phone traffic will be routed to another office or location where the Finance staff is located. The Executive Staff will decide determine whether to relocate staff to other offices. Automated processes will ensure critical system availability. Royal Blue Help Desk will support Jones users Pershing and Penson Help desks will support clearing and operations systems. Administration System Usage Contingency Voice systems General communication The Main Office has redundant services Inbound calls can be forwarded to another office or site that Administration Staff is relocated to. Key personnel can be contacted by cell phone. Electricity Computer usage Each office has battery UPS back ups The Main Office has a backup generator General communication Each office is connected to the primary and back up server Communication can be conducted through voice services or Instant Messenger Key personnel can be contacted by cell phone In the event of an SBD that results in the Main Office not being available, the following steps will be taken: Phone traffic will be routed to another office. The Executive Staff will decide determine whether to relocate staff to other offices. A. Mission Critical Systems Provided by Our Clearing Firms Our firm relies, by contract, on our clearing firms to provide the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts. X. Alternate Communications between JonesTrading and Customers, Employees, and Regulators A. Customers We now communicate with our customers using the telephone, , instant message, our public website, fax, U.S. mail, and in person visits at our firm or at the other branch locations. 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 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 U.S. mail. Customer Business Continuity Information Line: Password: See Appendix 1 13

14 You ve reached the JonesTrading Customer Business Continuity Information Line. All offices and operations are functioning according to normal business practices. Please do not leave any account or trading instructions on this line. In the event that an office is closed because of a SBD, the office s main telephone numbers will be forwarded to another office. The 8XX numbers automatically follow the local number. See Appendix 2 for Call Forwarding procedures. B. Employees We now communicate with our employees using the telephone, , 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 have also distributed a business card to all employees containing a toll free number for all employees to call in the event of a SBD that will contain a message with updated instructions from senior management. Employee Business Continuity Information Line: Password: See Appendix 1 The following message will be left under normal business conditions. You ve reached the JonesTrading Employee Business Continuity Information Line. All offices and operations are functioning according to normal business practices. Employees are able to coordinate during an SBD by using the Employee Business Continuity Conference Call: or (international) Access Code: PIN: 1980 All Managing Directors and Executive Board members contact information is located in Appendix 3. C. Regulators JonesTrading Institutional Services LLC is registered with the SEC and the Ontario Securities Commission and is currently a member of FINRA, the NASDAQ Stock Market. We communicate with our regulators using the telephone, , fax, U.S. mail, 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. JonesTrading Canada Inc. is a member of the Investment Industry Regulatory Organization of Canada ( IIROC ). We communicate with our regulators using the telephone, , fax, U.S. mail, 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. 14

15 JonesTrading International Limited is currently a member of the Financial Services Authority ( FSA ). We communicate with our regulators using the telephone, , fax, U.S. mail, 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. XI. Critical Business Constituents, Banks, and Counter-Parties A. Business constituents We have contacted our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm. Our major suppliers are: Pershing LLC One Pershing Plaza Jersey City, New Jersey Penson Financial Services Canada 330 Bay Street, Suite 711 Toronto, Ontario M5H 2S8 Nasdaq Stock Market 80 Merritt Blvd. Trumbell, CT Fidessa 17 State Street New York, NY or Mixit, Inc RealTick CS First Boston

16 Instinet 30 Hudson Street, 9 th Floor Jersey City, NJ INET Technologies Inc. 3 Times Square New York, NY Archipelago (ARCA) 100 South Wacker Suite 2000 Chicago, IL Thompson Financial (ILX) San Vicente Blvd., Suite 710 Los Angeles, CA Bloomberg 731 Lexington Avenue New York, NY Omgeo (Oasys/Alert) 55 Thomson Place Boston, MA TelePacific 515 South Flower Street, 47 th Floor Los Angeles, CA G2 (long distance telecommunications) 1475 Powell Street, Suite 202 Emeryville, CA Southern California Edison P.O. Box 900 Rosemead, CA

17 AT&T P.O. Box Austin, TX Savvis Communications (data lines) One Savvis Parkway Town and Country, MO Bell South 1155 Peach Tree Street Atlanta, GA IPC Network Services LTD. 1 State Street Plaza, 12 th Floor New York, NY B. Banks We have contacted our banks and lenders to determine if they can continue to provide the financing that we will need in light of the internal or external SBD. If our bank is unable to provide financing we will seek alternative financing from Pershing as well as our shareholders. The banks maintaining our operating accounts are: Wells Fargo 3965 E Thousand Oaks Blvd Westlake Village, CA Primary contact: Nancy Buckle ( ). Canadian Imperial Bank of Commerce Commerce Court Toronto, Ontario M5L 1G Lloyd s TSB Threadneedle Street Branch 39 Threadneedle Street London, EC2R 8AU

18 The clearing firm maintaining our Proprietary Account of Introducing Brokers/Dealer (PAIB accounts) is: Pershing LLC One Pershing Plaza Jersey City, New Jersey Penson Financial Services Canada 330 Bay Street, Suite 711 Toronto, Ontario M5H 2S C. Counter-Parties We have contacted our critical counter-parties, such as other ECN s, broker-dealers and institutional customers, to determine if we will be able to carry out our transactions with them in light of the 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 those transactions as soon as possible. XII. Regulatory Reporting JTIS is subject to regulation by: FINRA, SEC, OSC, and various state jurisdictions. JTIS now files FOCUS reports with its regulator using electronic submission and a Certified Annual Audit using paper copies in the US mail. In the event of an SBD, JTIS 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 electronic) 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. FINRA 300 South Grand Avenue, Suite 1600 Los Angeles, CA FINRA 9509 Key West Avenue Rockville, MD United States Securities and Exchange Commission 5670 Wilshire Boulevard, 11 th Floor Los Angeles, CA United States Securities and Exchange Commission th Street, NW Mail Stop 5-I Washington, DC

19 The Ontario Securities Commission 20 Queen Street West, Suite 1903 Toronto, ON M5H 3S JonesTrading International Limited is authorized and regulated by the Financial Services Authority. Financial Services Authority The Financial Services Authority 25 The North Colonnade Canary Wharf London England E14 5HS JonesTrading Canada Inc. is regulated by the Investment Industry Regulatory Organization of Canada IIROC Suite 1600, 121 King Street West Toronto, Ontario, M5H 3T9 Tel: (416) Fax: (416) XIII. Disclosure of Business Continuity Plan JonesTrading discloses in writing a summary of its BCP to customers at account opening. JonesTrading also posts the summary on and mails it to customers upon request. The BCP summary states that instead of attempting to plan for every possible situation that could occur, JonesTrading has established baseline requirements and strategies to keep our business operating during a variety of emergencies. The BCP summary discloses the existence of back-up facilities and arrangements. XIV. Updates and Annual Review JonesTrading will update this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm. In addition, our firm will review this BCP annually, on January 1 to modify it for any changes in our operations, structure, business, or location or those of our clearing firms. 19

20 XV. 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. Signed: Title: Chief Operating Officer Date: September 16,

21 APPENDIX 1 Telephone PINs Customer Business Continuity Information Line: Enter: * then Password: (JONESBCP) Employee Business Continuity Information Line: Enter: * then Password: (JONESBCP) Conference Call.com (readycall.com) or (international) Note: *0 - gets operator Business Interruption (all personnel) Access Code: # PIN: 1980# Branch Managers II (all trading personnel) Access Code: # PIN: 6552# 21

22 APPENDIX 2 Office Telephone Forwarding Procedures Westlake Village Activating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the (main trading number) followed by #, i.e.: #. 3. If this is correct, dial the Personal Identification Number 1234 (see note 1). 4. Dial the Call Forwarding activation code: 72#. 5. Dial 1# to confirm that you want to activate the call forwarding activation feature. 6. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an Area Code to reach this number from your office, then you will need to dial 1 plus the area code and number the calls are to be forwarded to, i.e.: XXX.XXXX or 1.XXX.XXX.XXXX. 7. The forward-to telephone number dialed will be repeated (to allow for correction if dialed incorrectly). 8. If this is correct, dial 1# confirming that the repeated number is the number to which you want your calls forwarded. 9. You will be advised that you have activated the call forwarding feature (see note 2) (see note 3). 10. Hang up, and Call Forwarding is now active. 11. From a line other than the one calls are forwarded to, dial , the call should ring to the forwarded number. 12. Hang up, you have verified that Call Forwarding service is now forwarding calls correctly. Activating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature ( ). 2. Dial the Call Forwarding Activation code 72# 3. You will hear a new dial tone. 4. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an Area Code to reach this number from your office, then you will need to dial 1 plus the area code and the number the calls are to be forwarded to, i.e.: XXX.XXXX or 1.XXX.XXX.XXXX. 5. You will hear two (2) short tones followed by ringing. a. The call will be answered by the person at the forward-to number,, which indicates that Call Forwarding has been activated successfully (see note 2) (see note 3); or b. The call will continue to ring, in which case, you will need to: i. Hang up. ii. Pick up the phone and access the same main incoming line button, i.e.: the line with the Call Forwarding feature. iii. Dial the Call Forwarding activation code 72#. iv. You will hear two (2) short tones followed by a new dial tone, indicating that Call Forwarding has been activated. 6. Hang up, and Call Forwarding is now active (see note 2) (see note 3). 7. From a line other than the one calls are forwarded to, dial to ensure calls are being forwarded. 22

23 Activating Call Redirect for (this is the general office number) from inside or outside the office: 1. Contact TelePacific Customer Service at and advise the TelePacific representative that: a. You are calling regarding and , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name) b. You have a temporary situation and require TelePacific to either: i. Busy-out the four (4) PRI s so that all inbound calls follow the Redirect Plan on file with TelePacific (i.e.: in the event of a PRI failure) or ii. Redirect all your inbound calls from the above two (2) numbers to as soon as possible c. The representative will then provide you an Order Confirmation Number and timeframe when the Redirect will be activated 2. At the time the representative quoted, do the following to confirm that the calls are redirecting to correctly: a. From a line other than the one calls are forwarded to, dial (1.818) , the call should ring in to, and be answered Jones b. Hang up, you have verified that the calls are being redirected correctly Activating Call Redirect for and and the other twenty-six (26) 8XX s from inside or outside the office: 1. Contact G2 Customer Service at and request to speak to Sally or Mannie, and advise the that: a. You are calling regarding and , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name) b. You have a temporary situation and require G2/Qwest to either: i. Busy-out the T1 so that all inbound 8XX calls follow the Redirect Plan on file with G2 (i.e.: in the event of a T1 failure) or ii. Redirect all your inbound 8XX calls to as soon as possible The representative will then provide you an Order Confirmation Number and timeframe when the Redirect will be activated. At the time the representative quoted, do the following to confirm that the calls are redirecting to correctly: a. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. b. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. Deactivating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number Dial the 10-digit office telephone number that you previously activated call forwarding on followed by #, i.e.: #. 3. If this is correct, dial the Personal Identification Number 1234 (see note 1). 4. Dial the Call Forwarding deactivation code 73#. 5. Dial 1# to confirm that you want to deactivate the call forwarding feature. 6. Your call forwarding service has been deactivated. 7. Hang up, and test to ensure calls are ringing in the office. Deactivating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e., the line with the Call Forwarding feature 23

24 2. Dial the Call Forwarding deactivation code 73# 3. You will hear two (2) short tones confirming that you have deactivated the feature 4. Hang up, and test to ensure calls are ringing in the office. Deactivating Call Redirect for from inside or outside the office: 1. Contact TelePacific Customer Service at and advise the TelePacific representative that: a. You are calling regarding and , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name) b. The temporary situation has been resolved and you require TelePacific to place the four (4) PRI s back in service so that all inbound calls ring in as they did before the Redirect request c. The representative will then provide you an Order Confirmation Number and timeframe when the four (4) PRI s services will be restored to normal. 2. At the time the representative quoted, do the following to confirm that the calls are now ringing in normally: a. From a line other than the one calls are forwarded to, dial (1.818) , the call should ring in the office Deactivating Call Redirect for and and the other twenty-six (26) 8XX s from inside or outside the office: 1. Contact G2 Customer Service at and request to speak to Sally or Mannie, and advise the that: a. You are calling regarding and , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name) b. The temporary situation has been resolved and you require G2/Qwest to place the T1 back in service so that all inbound calls ring in as they did before the Redirect request c. The representative will then provide you an Order Confirmation Number and timeframe when the T1 services will be restored to normal 2. At the time the representative quoted, do the following to confirm that the calls are redirecting to correctly: a. From a line other than the one calls are forwarded to, dial , the call should ring in the office b. From a line other than the one calls are forwarded to, dial , the call should ring in the office. NOTE 1: You have three chances to enter the correct telephone number that has Remote Access to Call Forwarding Variable and the Personal Identification Number. After three attempts, you will be disconnected from the Remote Access to Call Forwarding Variable. You must hang up and try again. NOTE 2: In the instance where your office normally receives inbound DID and/or 8XX calls via a T1 or PRI, if the Remote Access To Relay Service has been activated or there is a power failure in the building, all inbound calls will now ring into the forward-to number. Mill Valley: Activating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the 10-digit (out of area) office telephone number ( ) that you want to forward, followed by the Personal Identification Number : 6353 (see note 1). 24

25 3. Dial the Call Forwarding activation code 72# 4. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an Area Code to reach this number from your office, then you will need to dial 1 plus the area code and number the calls are to be forwarded to, i.e.: XXX.XXXX or 1.XXX.XXX.XXXX 5. The forward-to telephone number dialed will be repeated (to allow for correction if dialed incorrectly) 6. If this is correct, dial 1 confirming that the repeated number is the number to which you want your calls forwarded. 7. You will hear two (2) short tones confirming that you have activated the call forwarding feature (see note 2) (see note 3). 8. Hang up, and Call Forwarding is now active for all calls to and the 8XX number. 9. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. 10. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. Activating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Activation code 72#. You will hear a new dial tone. 3. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an Area Code to reach this number from your office, then you will need to dial 1 plus the area code and the number the calls are to be forwarded to, i.e.: XXX.XXXX or 1-XXX.XXX.XXXX. 4. You will hear two (2) short tones followed by ringing and the call ring at the forwarded number Call Forwarding is active (see note 2 and note 3). The call will be answered by the person at the forward-to number, i.e.:, which indicates that Call Forwarding has been activated successfully (see note 2) (see note 3); or the call will continue to ring, in which case, you will need to: a. Hang up. b. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. c. Dial the Call Forwarding Activation code 72#. d. You will hear two (2) short tones followed by a new dial tone. e. Hang up, and Call Forwarding is now active (see note 2) (see note 3). 5. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 6. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. Deactivating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the 10-digit (out of area) office telephone number that you want to forward, followed by the Personal Identification Number : (see note 1). 3. Dial the Call Forwarding deactivation code 73# 4. You will hear two (2) short tones confirming that you have deactivated the feature. 5. Hang up, and calls will now ring in the office. Deactivating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature 25

26 2. Dial the Call Forwarding Deactivation code 73# 3. You will hear two (2) short tones confirming that you have deactivated the feature 4. Hang up, and calls will now ring in the office NOTE 1: You have three chances to enter the correct telephone number that has Remote Access to Call Forwarding Variable and the Personal Identification Number. After three attempts, you will be disconnected from the Remote Access to Call Forwarding Variable. You must hang up and try again. NOTE 2: In the instance where your office normally receives inbound DID calls via a T1 or PRI, if the Remote Access To Relay Service has been activated or there is a power failure in the building, all inbound calls will now ring into the forward-to number. Portsmouth: Activating Call Forwarding from outside the office: 1. Contact Verizon Customer Service at and advise the Verizon representative that: a. You are calling regarding , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name) b. You are currently unable to access your offices to activate Call Forwarding and need Call Forwarding activated immediately. c. You require Verizon to activate the Call Forwarding on your behalf as soon as possible d. Provide the number to which you want your calls forwarded to. If you must dial "1" plus an Area Code to reach this number from your office, then you will need to include 1 plus the area code and the number the calls are to be forwarded to, i.e.: 1.XXX.XXX.XXXX (1) e. Be sure that the Verizon representative repeats the forward-to number to insure it is the same number you just gave them f. The Verizon representative will then provide you an Order Confirmation Number and timeframe when the Call Forwarding will be activated 2. At the time the Verizon representative quoted, do the following to confirm that the Call Forwarding is functioning correctly: a. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. b. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. c. Hang up, you have verified that Call Forwarding is now forwarding calls correctly Activating Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature 2. Dial the Call Forwarding Activation code 72# 3. You will hear a new dial tone 4. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an Area Code to reach this number from your office, then you will need to dial 1 plus the area code and the number the calls are to be forwarded to, i.e.: 1.XXX.XXX.XXXX 5. You will hear two (2) short tones followed by ringing, then one of two scenarios will occur: a. The call will be answered by the person at the forwarded number which indicates that Call Forwarding has been activated successfully; or 26

27 b. The call will continue to ring, in which case, you will need to: i. Hang up ii. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature iii. Dial the Call Forwarding Activation code 72# iv. You will hear two (2) short tones followed by a new dial tone v. Hang up, and Call Forwarding is now active 6. From a line other than the one calls are forwarded to, dial (1.603) , the call should ring in to, and be answered at the forwarded number. 7. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. 8. Hang up, you have verified that Call Forwarding is now forwarding calls correctly Deactivating Call Forwarding from outside the office: 1. Contact Verizon Customer Service at and advise the Verizon representative that: a. You are calling regarding , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name) b. You are now ready for them to deactivate Call Forwarding and need them to deactivate Call Forwarding immediately. c. Be sure that the Verizon representative confirms that they will deactivate Call Forwarding. d. The Verizon representative will then provide you an Order Confirmation Number and timeframe when the Call Forwarding will be deactivated. 2. At the time the Verizon representative quoted, do the following to confirm that the Call Forwarding has been deactivated: a. From a line other than the one calls were forwarded to, dial (1.603) , the call should ring in the office. b. From a line other than the one calls were forwarded to, dial , the call should ring in the office. c. Hang up, you have verified that Call Forwarding is now deactivated. Deactivating Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Deactivation code 73#. 3. You will hear two (2) short tones confirming that you have deactivated the feature. 4. Hang up, and calls will now ring in the office. Heathrow: Activating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the Personal Identification Number 0507 (see note 1). 2. Dial the Call Forwarding Activation code 72#. 3. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e.: 1.XXX.XXX.XXXX 4. The forwarded to telephone number dialed will be repeated to allow for correction if dialed incorrectly (see note 2) 5. Dial 1 if the repeated number to which you want your calls forwarded to is correct. 27

28 6. You will hear two (2) short tones confirming that you have activated the feature. 7. Hang up, and Call Forwarding is now active. 8. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. 9. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. 10. Hang up, you have verified that Call Forwarding is now forwarding calls correctly Activating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature 2. Dial the Call Forwarding Activation code 72# 3. You will hear a new dial tone 4. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e.: 1.XXX.XXX.XXXX 5. You will hear two (2) short tones followed by ringing, then one of two scenarios will occur: a. The call will be answered by the person at the forward-to number. b. The call will continue to ring, in which case, you will need to: i. Hang up ii. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. iii. Dial the Call Forwarding Activation code 72#. iv. You will hear two (2) short tones followed by a new dial tone. 6. Hang up, and Call Forwarding is now active 7. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. 8. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. 9. Hang up, you have verified that Call Forwarding is now forwarding calls correctly Deactivating Remote Access to Call Forwarding Variable from outside the office:. 1. Dial the Special Access Number: Dial the 10-digit office telephone number that you want to deactivate Dial the Personal Identification Number 0507 (see note 1) 4. Dial the Call Forwarding Deactivation code 73# 5. You will hear two (2) short tones confirming that you have deactivated the feature 6. Hang up, and calls will now ring in normally Deactivating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature 2. Dial the Call Forwarding Deactivation code 73# 3. You will hear two (2) short tones confirming that you have deactivated the feature 4. Hang up, and calls will now ring in normally 28

29 NOTE 1: You have three chances to enter the correct telephone number that has Remote Access to Call Forwarding Variable and the Personal Identification Number. After three attempts, you will be disconnected from the Remote Access to Call Forwarding Variable. You must hang up and try again. New York: Activating Call Forwarding from outside the office: 1. Contact Verizon Customer Service at and advise the Verizon representative that: a. You are calling regarding , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name) b. You are currently unable to access your offices to activate Call Forwarding and need Call Forwarding activated immediately c. You require Verizon to activate the Call Forwarding on your behalf as soon as possible. To initialize remote call forwarding you need to call this number one time only from New York office d. To activate call forwarding features access from any touch-tone phone i. The service will welcome you and ask you to enter a 10 digit phone # ii. Then you will need to enter your 4 digit password 8585 iii. Once you have been confirmed as a call forward customer, you may follow the prompts to activate, deactivate, change your password, or utilize all call forwarding features from the main menu. e. Provide the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e.: 1.XXX.XXX.XXXX. f. Be sure that the Verizon representative repeats the forward-to number to insure it is the same number you just gave them. g. The Verizon representative will then provide you an Order Confirmation Number and timeframe when the Call Forwarding will be activated 2. At the time the Verizon representative quoted, do the following to confirm that the Call Forwarding is functioning correctly: a. From a line other than the one calls are forwarded to, dial (1.212) , the call should ring in to, and be answered at the forwarded number. b. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. c. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. d. Hang up, you have verified that Call Forwarding is now forwarding calls correctly Activating Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature 2. Dial the Call Forwarding Activation code 72# 3. You will hear a new dial tone 4. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e.: 1.XXX.XXX.XXXX ) 5. You will hear two (2) short tones followed by ringing. : 29

30 a. The call will be answered by the person at the forward-to number, i.e.: which indicates that Call Forwarding has been activated successfully; or b. The call will continue to ring, in which case, you will need to: i. Hang up ii. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature iii. Dial the Call Forwarding Activation code 72# iv. You will hear two (2) short tones followed by a new dial tone v. Hang up, and Call Forwarding is now active 6. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. 7. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. 8. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. 9. Hang up, you have verified that Call Forwarding is now forwarding calls correctly Activating Call Redirect for and from inside or outside the office: 1. Contact Focal Customer Service at and advise the Focal representative that: a. You are calling regarding and , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name) b. You have a temporary situation and require Focal to either: i. Busy-out the T1 so that all inbound calls follow the Redirect Plan on file with Focal (i.e.: in the event of a T1 failure) or ii. Redirect all your inbound calls from the above two (2) numbers to as soon as possible. The Focal representative will then provide you an Order Confirmation Number and timeframe when the Redirect will be activated 2. At the time the Focal representative quoted, do the following to confirm that the calls are redirecting to correctly: a. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. b. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. c. From a line other than the one calls are forwarded to, dial , the call should ring in to, and be answered at the forwarded number. d. Hang up, you have verified that the calls have been redirected correctly Deactivating Call Forwarding from outside the office: 1. Contact Verizon Customer Service at and advise the Verizon representative that: a. You are calling regarding , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name) b. You are now ready for them to deactivate Call Forwarding and need them to deactivate Call Forwarding immediately c. Be sure that the Verizon representative confirms that they will deactivate Call Forwarding d. The Verizon representative will then provide you an Order Confirmation Number and timeframe when the Call Forwarding will be deactivated 30

31 2. At the time the Verizon representative quoted, do the following to confirm that the Call Forwarding has been deactivated: a. From a line other than the one calls were forwarded to, dial , the call should ring in the office. b. From a line other than the one calls were forwarded to, dial , the call should ring in the office. c. From a line other than the one calls are forwarded to, dial , the call should ring in the office. d. Hang up, you have verified that Call Forwarding is now deactivated. Deactivating Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Deactivation code 73#. 3. You will hear two (2) short tones confirming that you have deactivated the feature. 4. Hang up, and calls will now ring in normally. Deactivating Call Redirect from inside or outside the office: 1. Contact Focal Customer Service at and advise the Focal representative that: a. You are calling regarding and , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name) b. You require Focal to restore the T1 service to normal as soon as possible, thus, cancel the Redirect of all inbound calls, i.e.: restore the service as it was before they made the temporary changes you requested c. The Focal representative will then provide you an Order Confirmation Number and timeframe when the services will be restored to normal 2. At the time the Focal representative quoted, do the following to confirm that the calls are ringing in normally: a. From a line other than the one calls are forwarded to, dial , the call should ring in the office. b. From a line other than the one calls are forwarded to, dial , the call should ring in the office. c. From a line other than the one calls are forwarded to, dial , the call should ring in the office. d. Hang up, You have verified that the calls are now ringing in normally. Dallas: Activating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the 10- digit (out of area) office telephone number that you want to forward If this number is correct, dial the Personal Identification Number 5400 (see note 1). 4. Dial the Call Forwarding Activation code 72#. 5. Dial 1 to confirm this feature. 6. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e.: 1.XXX.XXX.XXXX. 7. The forwarded to telephone number dialed will be repeated to allow for correction if dialed incorrectly (see note 2). 8. Dial 1 if the repeated number to which you want your calls forwarded to is correct. 31

32 9. Your Call Forwarding service is now activated. 10. Hang up, and Call Forwarding is now active. 11. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 12. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 13. Hang up, you have verified that Call Forwarding is now forwarding calls correctly Activating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Activation code 72#. 3. You will hear a new dial tone. 4. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e.: 1.XXX.XXX.XXXX. 5. You will hear two (2) short tones followed by ringing, then one of two scenarios will occur: a. The call will be answered by the person at the forward-to number; or b. The call will continue to ring, in which case, you will need to: i. Hang up ii. Pick up the phone and access the main incoming line button, ie: the line with the Call Forwarding feature. iii. Dial the Call Forwarding Activation code 72#. iv. You will hear two (2) short tones followed by a new dial tone. 6. Hang up, and Call Forwarding is now active 7. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 8. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 9. Hang up, you have verified that Call Forwarding is now forwarding calls correctly Deactivating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the 10-digit (out of area) office telephone number that you want to forward If this number is correct, dial the Personal Identification Number 5400 (see note 1). 4. Dial the Call Forwarding Deactivation code 73#. 5. Dial 1 to confirm this feature. 6. Call Forwarding service is now deactivated. 7. Hang up, and calls will now ring in normally. Deactivating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Deactivation code 73#. 3. You will hear two (2) short tones confirming that you have deactivated the feature. 4. Hang up, and calls will now ring in the office. 32

33 NOTE 1: You have three chances to enter the correct telephone number that has Remote Access to Call Forwarding Variable and the Personal Identification Number. After three attempts, you will be disconnected from the Remote Access to Call Forwarding Variable. You must hang up and try again. Atlanta: Activating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the 10-digit (out of area) office telephone number that you want to forward Dial the Personal Identification Number 0423 (see note 1). 4. Dial the Call Forwarding Activation code 72#. 5. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e.: 1.XXX.XXX.XXXX. 6. The forwarded to telephone number dialed will be repeated to allow for correction if dialed incorrectly (see note 2). 7. Dial 1 if the repeated number to which you want your calls forwarded to is correct. 8. You will hear two (2) short tones confirming that you have activated the feature 9. Hang up, and Call Forwarding is now active. 10. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 11. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 12. Hang up, you have verified that Call Forwarding is now forwarding calls correctly. Activating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Activation code 72#. 3. You will hear a new dial tone. 4. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e. 1XXX.XXX.XXXX. 5. You will hear two (2) short tones followed by ringing, then one of two scenarios will occur: a. The call will be answered by the person at the forward-to number, which indicates that Call Forwarding has been activated successfully; or b. The call will continue to ring, in which case, you will need to: i. Hang up. ii. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. iii. Dial the Call Forwarding Activation code 72#. iv. You will hear two (2) short tones followed by a new dial tone. 6. Hang up, and Call Forwarding is now active 7. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 8. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 9. Hang up, you have verified that Call Forwarding is now forwarding calls correctly. 33

34 Deactivating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the 10-digit (out of area) office telephone number that you want to forward Dial the Personal Identification Number 0423 (see note 1). 4. Dial the Call Forwarding Deactivation code 73#. 5. You will hear two (2) short tones confirming that you have deactivated the feature. 6. Hang up, and calls will now ring in the office. Deactivating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Deactivation code 73#. 3. You will hear two (2) short tones confirming that you have deactivated the feature. 4. Hang up, and calls will now ring in normally. NOTE 1: You have three chances to enter the correct telephone number that has Remote Access to Call Forwarding Variable and the Personal Identification Number. After three attempts, you will be disconnected from the Remote Access to Call Forwarding Variable. You must hang up and try again. Greenwich: Activating Call Forwarding from outside the office: 1. Contact Verizon Customer Service at and advise the Verizon representative that: a. You are calling regarding , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name). b. You are currently unable to access your offices to activate Call Forwarding and need Call Forwarding activated immediately. a. You require Verizon to activate the Call Forwarding on your behalf as soon as possible. b. Provide the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e.: 1.XXX.XXX.XXXX. c. Be sure that the Verizon representative repeats the forward-to number to insure it is the same number you just gave them d. The Verizon representative will then provide you an Order Confirmation Number and timeframe when the Call Forwarding will be activated 2. At the time the Verizon representative quoted, do the following to confirm that the Call Forwarding is functioning correctly: a. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. b. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. c. Hang up, you have verified that Call Forwarding is now forwarding calls correctly. Activating Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature 2. Dial the Call Forwarding Activation code 72# 3. You will hear a new dial tone 34

35 4. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e.: 1.XXX.XXX.XXXX ) 5. You will hear two (2) short tones followed by ringing, then one of two scenarios will occur: a. The call will be answered by the person at the forward-to number, which indicates that Call Forwarding has been activated successfully; or b. The call will continue to ring, in which case, you will need to: i. Hang up. ii. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. iii. Dial the Call Forwarding Activation code 72#. iv. You will hear two (2) short tones followed by a new dial tone. v. Hang up, and Call Forwarding is now active. 6. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 7. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 8. Hang up, you have verified that Call Forwarding is now forwarding calls correctly. Deactivating Call Forwarding from outside the office: 1. Contact Verizon Customer Service at and advise the Verizon representative that: a. You are calling regarding , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name). b. You are now ready for them to deactivate Call Forwarding and need them to deactivate Call Forwarding immediately. c. Be sure that the Verizon representative confirms that they will deactivate Call Forwarding. d. The Verizon representative will then provide you an Order Confirmation Number and timeframe when the Call Forwarding will be deactivated. 2. At the time the Verizon representative quoted, do the following to confirm that the Call Forwarding has been deactivated: a. From a line other than the one calls were forwarded to, dial (1.203) , the call should ring in the office. b. From a line other than the one calls were forwarded to, dial , the call should ring in the office. c. Hang up, you have verified that Call Forwarding is now deactivated Deactivating Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature 2. Dial the Call Forwarding Deactivation code 73# 3. You will hear two (2) short tones confirming that you have deactivated the feature 4. Hang up, and calls will now ring in normally Aspen: Activating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: (from any area code). 2. Dial the 10-digit office telephone number that you want to forward followed by #, i.e.: #. 35

36 3. Dial the Personal Identification Number (Security Code): 1234 followed by #, (see note 1). 4. Dial 1 for Remote Access to Call Forwarding. 5. Dial 1 to forward calls. 6. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an Area Code to reach this number from your office, then you will need to dial 1 plus the area code and the number the calls are to be forwarded to followed by #, i.e.: 1.XXX.XXX.XXXX#. 7. Within 30 seconds your calls will be forwarded to (telephone number dialed will be repeated) (see note 2). 8. Hang up, and Call Forwarding is now active. 9. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 10. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 11. Hang up, you have verified that Call Forwarding is now forwarding calls correctly. Activating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Activation code 72#. 3. You will hear a new dial tone. 4. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an Area Code to reach this number from your office, then you will need to dial 1 plus the area code and the number the calls are to be forwarded to, i.e.: 1.XXX.XXX.XXXX. 5. You will hear two (2) short tones followed by ringing, then one of two scenarios will occur: a. The call will be answered by the person at the forward-to number, i.e.: which indicates that Call Forwarding has been activated successfully; or b. The call will continue to ring, in which case, you will need to: i. Hang up. ii. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. iii. Dial the Call Forwarding Activation code 72#. iv. You will hear two (2) short tones followed by a new dial tone. 6. Hang up, and Call Forwarding is now active. 7. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 8. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. 9. Hang up, you have verified that Call Forwarding is now forwarding calls correctly. Deactivating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the 10-digit office telephone number that you want to forward followed by #, i.e.: # 3. Dial the Personal Identification Number (Security Code): 1234 followed by #, i.e. (see note 1) 4. Dial 1 for Remote Access to Call Forwarding. 5. The telephone number dialed will be repeated. 6. Dial 1 to cancel call forwarding. 36

37 7. Within 30 seconds your forwarding will be cancelled. 8. Hang up, and calls will now ring in normally. Deactivating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Deactivation code 73#. 3. You will hear two (2) short tones confirming that you have deactivated the feature. 4. Hang up, and calls will now ring in the office. NOTE 1: You have three chances to enter the correct telephone number that has Remote Access to Call Forwarding Variable and the Personal Identification Number. After three attempts, you will be disconnected from the Remote Access to Call Forwarding Variable. You must hang up and try again. Chicago: Activating Call Forwarding from outside the office: 1. Contact SBC Customer Service at and advise the SBC representative that: a. You are calling regarding , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name). b. You are currently unable to access your offices to activate Call Forwarding and need Call Forwarding activated immediately. c. You require SBC to activate the Call Forwarding on your behalf as soon as possible. d. Provide the number to which you want your calls forwarded to. If you must dial "1" plus an Area Code to reach this number from your office, then you will need to include 1 plus the area code and the number the calls are to be forwarded to, i.e.: 1.XXX.XXX.XXXX. e. Be sure that the SBC representative repeats the forward-to number to insure it is the same number you just gave them. f. The SBC representative will then provide you an Order Confirmation Number and timeframe when the Call Forwarding will be activated. Activating Remote Access to Call Forwarding Variable from inside the office: 1. To activate; from touch-tone phone equipment with Touch-Tone service, push 72 then # wait 5 seconds for dial tone. 2. Dial the number that will be accepting the calls. You will hear 2 short tones then normal ringing when the call forwarding is in effect. 3. If the line is busy or there is no answer, hang up and repeat the first two steps. Deactivating Call Forwarding from outside the office: 1. Contact SBC Customer Service at and advise the Verizon representative that: a. You are calling regarding, JonesTrading/Jones & Associates (not all business offices have updated their records with the new name). b. You are now ready for them to deactivate Call Forwarding and need them to deactivate Call Forwarding immediately. 37

38 c. Be sure that the SBC representative confirms that they will deactivate Call Forwarding. c. The SBC representative will then provide you an Order Confirmation Number and timeframe when the Call Forwarding will be deactivated. 2. At the time the SBC representative quoted, do the following to confirm that the Call Forwarding has been deactivated: a. From a line other than the one calls were forwarded to, dial , the call should ring in the office. Deactivating Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Deactivation code 73#. 3. You will hear two (2) short tones confirming that you have deactivated the feature. 4. Hang up, and calls will now ring in the office. Boston: Activating Call Forwarding from outside the office: 1. Contact Verizon Customer Service at and advise the Verizon representative that: a. You are calling regarding , JonesTrading/Jones & Associates (not all business offices have updated their records with the new name). b. You are currently unable to access your offices to activate Call Forwarding and need Call Forwarding activated immediately. i. You require Verizon to activate the Call Forwarding on your behalf as soon as possible. ii. Provide the number to which you want your calls forwarded to. If you must dial "1" plus an area code, i.e.: 1.XXX.XXX.XXXX. iii. Be sure that the Verizon representative repeats the forward-to number to insure it is the same number you just gave them. iv. The Verizon representative will then provide you an Order Confirmation Number and timeframe when the Call Forwarding will be activated. 3. At the time the Verizon representative quoted, do the following to confirm that the Call Forwarding is functioning correctly: a. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. b. From a line other than the one calls are forwarded to, dial , the call should ring at the forwarded number. c. Hang up, you have verified that Call Forwarding is now forwarding calls correctly. Activating Remote Access to Call Forwarding Variable from inside the office: 1. To activate; from touch-tone phone equipment with Touch-Tone service, push 72 then # wait 5 seconds for dial tone. 2. Dial the number that will be accepting the calls. You will hear 2 short tones then normal ringing when the call forwarding is in effect. 3. If the line is busy or there is no answer, hang up and repeat the first two steps. Deactivating Call Forwarding from outside the office: 1. Contact Verizon Customer Service at and advise the Verizon representative that: 38

39 a. You are calling regarding, JonesTrading/Jones & Associates (not all business offices have updated their records with the new name). b. You are now ready for them to deactivate Call Forwarding and need them to deactivate Call Forwarding immediately. c. Be sure that the Verizon representative confirms that they will deactivate Call Forwarding. i. The Verizon representative will then provide you an Order Confirmation Number and timeframe when the Call Forwarding will be deactivated. 2. At the time the Verizon representative quoted, do the following to confirm that the Call Forwarding has been deactivated: a. From a line other than the one calls were forwarded to, dial , the call should ring at the forwarded number. b. From a line other than the one calls were forwarded to, dial , the call should ring at the forwarded number. c. Hang up, you have verified that Call Forwarding is now deactivated Deactivating Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. 2. Dial the Call Forwarding Deactivation code 73#. 3. You will hear two (2) short tones confirming that you have deactivated the feature. 4. Hang up, and calls will now ring in normally. Charleston: AT&T CUSTOMER SERVICE or Activating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line button, i.e.: the line with the Call Forwarding feature. ( ). 2. Dial the Call Forwarding Activation code 72#. 3. You will hear a new dial tone. 4. Dial the number to which you want your calls forwarded to. If you must dial "1" plus an area code to reach this number from your office, then you will need to dial 1 plus the area code and the number the calls are to be forwarded to, i.e.: XXX.XXXX or 1-XXX.XXX.XXXX. 5. You will hear two (2) short tones followed by ringing. 6. Test by calling the main number and ensure the call is answered by someone at the forwarded number. De-activating Remote Access to Call Forwarding Variable from inside the office: 1. Dial the Call Forwarding deactivation code 73# 2. You will hear two (2) short tones confirming that you have deactivated the feature 3. Test by calling the main number rings in the office. Activating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the: office telephone number , followed by the Personal Identification Number:

40 3. Dial the 10-digit telephone number that you want to forward, followed by the Personal Identification Number: (1 XXX.XXX.XXXX ) Test by calling the main number and ensure the call is answered by someone at the forwarded number. De-activating Remote Access to Call Forwarding Variable from outside the office: 1. Dial the Special Access Number: Dial the: office telephone number , followed by the Personal Identification Number: Dial the 10-digit telephone number that you want to forward, followed by the Personal Identification Number: ( ) Test by calling the main number and ensure the call rings in the office. Toronto: Activating Remote Access to Call Forwarding Variable from inside the office: 1. Pick up the phone and access the main incoming line that has Call Forwarding feature ( ) and dial the Call Forwarding Activation Code *72 and wait for a dial tone. 2. Dial the number to forward the calls to using 1 plus the area code 1.xxx.xxx.xxxx. You will hear 2 short tones then normal ringing.. 3. Test by calling the main number and ensure that the phone is answered by someone at the forwarded number. Deactivating Call Forwarding from inside the office: 1. Pick up the phone and access the main incoming line that has Call Forwarding feature ( ) and dial the Call Forwarding De-Activation Code * You will hear 2 short tones. 3. Test by calling the main number and ensure that the phone rings in the office. Activating Call Forwarding from outside the office: 1. Contact Bell Canada at and advise as to what number the main number should be forwarded. 2. Test by calling the main number and ensure that the phone is answered by someone at the forwarded number. Deactivating Call Forwarding Variable from outside the office: 1. Contact Bell Canada at and request call forwarding be turned off. 2. Test by calling the main number and ensure that the phone rings in the office. London: Activating Call Forwarding: Contact AMERITEL Customer services at Request that the Customer Service Representative forward ( 877 JONES UK ) which is on the Westlake Village T1with DEENACE 375 to the required telephone number. 40

41 Deactivating Call Forwarding: Contact AMERITEL Customer services at Request that the Customer Service Representative forward ( 877 JONES UK ) which is on the Westlake Village T1with DEENACE 375 to the JTIL mobile phone number ( ) maintained by Stephen Ponto. 41

42 APPENDIX 3 Andrews, Rick Office Phone Office Fax [email protected] Mobile Phone Home Phone Bell, Jeremy Office Phone Office Fax [email protected] Mobile Phone Home Phone Brown, Clint Office Phone Office Fax [email protected] Mobile Phone Home Phone Carter, Tom Office Phone Office Fax [email protected] Mobile Phone Home Phone Chen, William Office Phone Office Fax [email protected] Mobile Phone Home Phone Chmielewski, Steve Office Phone Office Fax [email protected] Mobile Phone Home Phone Cohen, Moe Office Phone Office Fax [email protected] 42

43 Mobile Phone Home Phone DiChiacchio, Joe Office Phone Office Fax Mobile Phone Home Phone Farrington, Paul Office Phone Office Fax Mobile Phone Home Phone Fouladian, Fred Office Phone Office Fax Mobile Phone Home Phone none Geyer, Will Office Phone Office Fax Mobile Phone Home Phone Gibbs, Elly Office Phone Office Fax Mobile Phone Home Phone Graves, Adam Office Phone Office Fax Mobile Phone Home Phone Harasym, Lawrence Office Phone Office Fax

44 Mobile Phone Home Phone Harrington, George Office Phone Office Fax Mobile Phone Home Phone Hill, Alan Office Phone Office Fax Mobile Phone Home Phone Hirshorn, Scott Office Phone or Office Fax Mobile Phone Home Phone none Hutcherson, Van Office Phone Office Fax Mobile Phone Home Phone Jones, Packy Office Phone Office Fax Mobile Phone Home Phone Mattoon, David Office Phone Office Fax Mobile Phone Home Phone Mazzullo, David Office Phone

45 Office Fax Mobile Phone Home Phone McBride, Charlie Office Phone Office Fax Mobile Phone Home Phone McKnight, Robert Office Phone None Office Fax None None Mobile Phone Miller, Patti Office Phone Office Fax Mobile Phone Home Phone O'Neil, Tim Office Phone Office Fax Mobile Phone Home Phone Pears, Brian Office Phone Office Fax Mobile Phone Home Phone Piscitello, Frank Office Phone Office Fax Mobile Phone Home Phone Ponto, Stephen 45

46 Office Phone Office Fax Mobile Phone Home Phone Spaeth, Ron Office Phone Office Fax Mobile Phone Home Phone Steen, Tom Office Phone Office Fax Mobile Phone Home Phone Stein, Kerry Office Phone Office Fax Mobile Phone Home Phone Tesoro, Phil Office Phone Office Fax none Mobile Phone Home Phone Tesoro, Tony Office Phone none Office Fax none Mobile Phone Home phone: Tullar, Chris Office Phone Office Fax Mobile Phone Home Phone

47 Tullar, Steve Office Phone Office Fax Mobile Phone Home Phone

48 APPENDIX 4 Department Contact Phone No. Cell phone Home Fax Number Rich Brueckner [email protected] Frank LaSalla [email protected] Craig Messenger [email protected] Jim Crowley [email protected] Suresh Kumaar [email protected] Joe Dattolo [email protected] Legal Tres Arnett [email protected] Relationship Gina Jurecki Manager [email protected] Neal Berry [email protected] Dan O'Brien [email protected] Account Manager Susan Kelly [email protected] Sumit Mahay [email protected] Technology Michael Turner [email protected] John Butcher [email protected] Pat Difeo [email protected] Imaging Fax Server Money Desk Banking & Funds Recon (Retail) Check Processing & Wired Funds Check Processing (LA) Treasury Issues Clearance Buy-Ins (DVP/RVP) Deliveries DTC Recieves/Physicals Government/GNMA Syndicates COD/ID Customer Service (DVP/RVP) Jim Brennan (AVP) COD Assocaite Johanna Flores Corporate Actions Voluntary Reorganization Santos Ortiz (Voluntary Manager) James Ciccolella (Voluntary *call to confirm fax received Manager) Lou Santiago (Voluntary Manager) Mandatory Redemptions Joseph LaVara (Mgr.) Proxy

49 Margin George Quiroz (Mgr.) Associate: Mark C Martinez Manager: David Chabolla x x Firm Trading Margin Related issues Kathy Liano N/A Reporting Related issues Jeff Kugler N/A P & S Martin Dolaldson (VP) N/A (DVP/RVP) Bernadette Selby (VP) N/A William Carroll (VP) N/A Municipal Bonds option2 N/A Corporates Bonds and UIT's option 3 N/A Government Bonds option 5 N/A Equity Exclearing option 1 N/A Customer Corrections (Equities, Listed/Regionals/OTC) iption 1 N/A Security Master (for setting up new cusips) Tax Information Options N/A All Bonds(including Municipals) Equity / Symbols Options Pricing General Inquiries Vilma King (Mgr.) N/A N/A or N/A Stock Loan N/A Tech. Cust. Svc. Prep Reloads/Reports N/A Help Desk- Computers,Printers etc N/A Net Exchange Help Desk or N/A TRADING Marty Rogan DESKS [email protected] Listed Equities- (support) Retail Orders (options, listed equitites) Options (support) Equites-OTC Equites-OTC (support) Options - Exercise/Assignment / PNS Fixed Income Sales Corporate Bonds Gov't Muni

50 CD Mutual Fund Trading UIT Foreign Exchange

51 APPENDIX 5 PENSON S TEAM FINANCE Name Title Telephone # François Gervais Senior Vice-President & CFO (514) Daniel Girardeau Controller (514) Marie-Andrée Deziel Accounting Clerk (514) Mariette Godbout Team Leader, Payroll and Accounts Payable (514) Tel.: (514) Fax: (514) Chantal Zotti Accounts Payable Clerk (514) Luc Southiere Chief Financial Accounting (514) Josée Brouillette Supervisor Billing (514) Jacques Madzou Billing Administrator (514) Zhi-Dan Shao Billing Administrator (514) Jordan Lamaire Accounting Clerk (514) Carole Robichaud Reconciliation (514) Marie-Claude Garant Financial Analyst (514) Sylvain Lambert Financial Analyst (514) BANKING Name Title Telephone # Tel.: (514) / Vu Tran Manager (416) (416) Alain Coulombe Administrator (514) Fax: (514) / Denise Black Reconciliation (514) (514) Robert Miller Administrator (416) [email protected] Beatrice Inarukundo Banking Clerk (514) CLIENT RELATIONS FOR INTRODUCING BROKERS AND PENSONPRIME Name Title Telephone Sanam Raza Manager, Client Account Management (416) Patrizia Greco Manager (514) CLIENT PRODUCT Rosie Martino Implementation Specialist (514) MANAGEMENT Chelsea Barrett- Tel.: (514) Dunford Implementation Specialist (514) Fax: (514) Jessica Beckett- Campbell Administrator (514) [email protected] Ben Wu Administrator (514) Account Manager(Maternity Han Tran Leave) (514) Connie Chin Account Manager (514) Jacqueline Gordon Account Manager (416) ACCOUNT MANAGEMENT Amy Fang Chen Account Manager Lise Catterall Account Manager (Calgary) cell Mimi Cheng Account Manager (Vancouver) Theresa Blonde Account Manager (416) Scott Gordon Account Manager (416)

52 52

53 COMMUNICATION AND INFORMATION SERVICES Name Title Telephone # Ray Hori Senior VP, CTO (416) INFORMATION TECHNOLOGY Tel.: (514) Toll Free: 1 (866) Fax: (514) [email protected] Eric Sauve Manager, IT (514) Simon Benzekri Manager, IS (514) Christine Rolland Manager, Application Development (514) INFORMATION SYSTEMS Tel.: (514) Fax: (514) Denis Vadnais Stephane Auger François Drainville Manager Core Processing & Infrastructure (514) Team Leader, Core Processing & Infrastructure (514) Team Leader, Client Applications & Integration (514) COMPLIANCE Name Title Telephone # Senior Vice President & Chief Susie Rafael Compliance Officer (514) Tel.: (514) Fax: (514) Linda Fortin V-P, Compliance (514) Jean Luc Nguyen Compliance Officer (514) Sophie Tremblay V-P, Sales Compliance (514) Neil Morton Compliance Officer (514) NAME & ADDRESS Name Title Telephone # Daisy Thierry Manager(Maternity Leave) (514) Tel.: (514) Fax: (514) name&[email protected] Nancy Brien Team Leader (514) Manon Généreux Administrator (514) Geneviève Campeau Administrator (514) Christine Morin Administrator (514) Jessica Lamy Administrator (514) Jason White Administrator (514) Danielle Croteau Filing Clerk (514) RISK MANAGEMENT Name Title Telephone # Tel.: (416) Fax: (514) [email protected] Sylvain Racine Kostas Dapolias V-P, Integrated Risk Management Manager (514) (514) OPERATIONS Name Title Telephone # Robert McPherson Senior Vice President, National Operations (416) Mark Robinson Vice-President, Montreal Operations (514) Deborah Ferguson Senior Manager of Operations, Toronto (416)

54 OPERATIONS Name Title Telephone # Annie Lebel Manager (514) Robert Stangle Supervisor (514) Connie Roccaro Administrator, In (514) ACCOUNT TRANSFERS Tel.: (514) Fax: (514) [email protected] CREDIT [email protected] DIVIDEND & INTEREST AND DPP Tel.: (514) Fax: (514) div&[email protected] MAILING SERVICES Tel.: (514) Fax: (514) / (514) MUTUAL FUNDS Tel.: (514) Fax: (514) [email protected] PHYSICAL CERTIFICATES Tel.: (514) Fax: (514) [email protected] PURCHASE & SALES Tel.: (514) Fax: (514) p&[email protected] Daphne Briffault Administrator, In (514) Johanne Sage Administrator, Out (514) Amanda Papadopoli Administrator, In (514) Lise Brossard Administrator, In (514) Lucy Blanch Administrator (514) Ronald Bonheur Administrator, Out (514) Jean-Sebastien (514) Trudeau GIC Administrator Paul Milton Administrator (514) Richard Hughes Filling Clerk (514) (514) Jeffrey Barron Supervisor, Credit and Risk x.320 Louis-Phillipe Cantin Risk Analyst (416) (514) Jessica Boudreau Senior Risk Analyst x.303 Nathalie Charette Manager (514) Carole Joe Team Leader (514) Maryse Jutras Analyst (514) Cheryl Downie Administrator (514) Javier Aracena Administrator (514) Damien Canovas Administrator (514) Sara Pelletier Administrator (514) Supervisor, Montreal Mailroom Thomas Watson and Archives (514) Alexander Yoanidis Messenger Toronto (416) Darren Rankine Messenger Toronto (416) Sebastien Gonzalez Messenger Montreal (514) Vickie Normandeau Manager (514) Marie-Helene Martin Team Leader (514) Nadia Tapia Administrator (514) Mélanie Morin Administrator (514) Richard Lacroix Administrator (514) Frederic Lussier Administrator (514) Aicha Zampalegre Administrator (514) Steve Desroches- Ranco Administrator (514) Mario Benoit Manager (514) Brent Carter Team Leader (514) Beatrice Guerrera Administrator (514) Elaine Walter Administrator (514) Susan Farrow Administrator (514) Rita Marks-Gagnon Administrator (514) Sidney Collett Administrator (514) Hélène Tremblay Manager (514) Josie Rizzo Team Leader (514) Pim Manirath Reconciliation Administrator (514) Donna Fiorilli Administrator (514) Frédéric Pruneau Administrator (514) Keith Fisher Administrator (514) Mathieu Desrochers Administrator (514) Michel Monette Administrator (514)

55 OPERATIONS Name Title Telephone # Stephen Hislop Manager, Global Reconciliation (416) RECONCILIATION Patricia Jewell-Larsen Supervisor (416) Fax: (514) Ana Domingos Administrator (416) Deborah Walters Administrator (416) [email protected] REGISTERED PLANS Tel.: (514) Fax: (514) [email protected] REORGANIZATION Tel.: (514) / (514) Fax: (514) [email protected] SEGREGATION AND BUY-INS [email protected] Nancy Kolodzie Administrator (416) Mario Benoit Manager (514) Suzanne de Jonge Supervisor (514) Josée Lavoie Analyst (514) Joanne Vermette RIF Agent (514) Guillaume Sauvé RIF Agent (514) Evelyne Latraverse RRSP Agent (514) Sonia Sonny RRSP Administrator (514) Monica Livingstone Manager (on Maternity Leave) (514) Marie-France Dorais Team Leader (514) Caroline Corbin Administrator (514) Geneviève Bégin Administrator (514) Jacqueline Richer Administrator (514) Lorraine Guerin Administrator (514) Marc Bouchard Administrator (514) Nicole Fraser Administrator (514) Angela Navarole Administrator (514) Trevor Hill Supervisor (514) Freddy Huynh Administrator (514) Sarah Quesnel Administrator (514) Ian Sinclair Administrator (416) Rachel Chartrand Adminsitrator (416) Maria Ong Administrator (416) Ivan Chavez Team Leader (416) Heather Richards Administrator (416) SETTLEMENTS (US) Fax: (416) [email protected] Julie Bourne DTC Administrator (416) SETTLEMENTS Ana Domingos Administrator (416) (INTERNATIONAL) Jennifer Kowalyshen Administrator (416) Fax: (416) [email protected] Ben Koeslag Sharon Aliry Administrator Administrator (416) (416) YEAR END Tel.: (514) Fax: (514) [email protected] Jean-François Blouin Stephane Perreault Supervisor Analyst (514) (514)

56 SALES Name Title Telephone # Kevin Vanderheyden SVP, Canadian Business 1 (877) Stephen Cosburn VP, Business Development (416) Chris Chen VP, Business Development (416) Shelly Blum Administrative Assistant 1 (877) Peadar Duignan VP, Product Development (416) TRADING & TREASURY SERVICES Name Title Telephone # BOND DESK Yves Therrien Manager (514) Tel.: (514) / Anna Cosentini Trading Assistant (514) (866) Debbie Cisowski Assistant (514) Fax: (514) [email protected] Claude Cyrenne Mathieu Cousineau Trader Trader (514) (514) Equity, options, Trading Desk EXECUTION SERVICES Kelly Chong Manager Tel.: (416) / Farah Kamal Trader (416) (866) Joseph Skaf Trader (416) Fax: (514) (416) Carol Trieu Trading Administrator #515 [email protected] Rolando Garcia Trading Analyst (416) Vincent Joe Trading Analyst (416) FOREIGN EXCHANGE DESK Jean-François Giguère Senior Trader (514) Tel.: (514) / Philip Perenne Junior Trader (514) (866) Dmitry Evseev Trader (514) Fax: (514) Alexandre Beauregard Assistant Trader (514) [email protected] Guillaume Payment Assistant Trader (514) INTERNATIONAL EQUITY Jean Quesnel VP, International Equity Sales (514) SALES AND TRADING Tel.: (514) Thierry Carrenard Trader (Global Execution and Integration) (514) Fax: (514) Alexei Arias Trader (Global Execution) (514) NEW ISSUES Tel.: (416) Fax: (514) Deborah Ferguson Manager, Toronto Operations SECURITIES LENDING Tel.: (416) Fax: (514) [email protected] Steve Harvison David Jeffrey Manager Manager (416) (416) SYNDICATION Fax: (514) Ginette Vadnais Syndication Coordinator (416)