Wainwright Investment Counsel, LLC, WFS, LLC and Wainwright Capital Partners, LLC (collectively, “Wainwright”) have developed and adopted a Business Continuity and Disaster Recovery Plan (the “BCDR Plan”) which addresses how Wainwright will respond in the event of an emergency or significant business disruption (“SBD”). Due to the vast number of possibilities that could result in an SBD, the BCDR Plan focuses on the nature of the interruption itself and not the cause of the interruption. With this in mind, we are providing you with this information about our BCDR Plan.
Our Business Continuity and Disaster Recovery Plan
The primary objectives of the BCDR Plan are to both minimize the impact of an SBD and continue with, or return to, normal business operations as quickly and efficiently as possible. Wainwright shall make a financial and operational assessment and respond in a manner that ensures the health and safety of its employees while securing its property, safeguarding confidential client information, protecting the Firm’s books and records, and continuing to provide the highest level of investment advisory (WIC), broker-dealer related (WFS), or commodity pool operator related (WCAP) client services, as the case may be.
Wainwright’s business continuity plan addresses: data back-up/redundancy and recovery; financial and operational assessments; mission critical systems; alternate physical locations of employees; alternate communications with customers, employees, and regulators; critical vendor, contractor, banking relationships; regulatory reporting; and assuring our customers prompt access to information regarding their business relationship with Wainwright.
Significant business disruptions can vary in scope, such as affecting a single organization, physical address, business district, the city where we are located, or the entire region or beyond. Further, the severity of a disruption can vary from minimal to severe. For disruptions affecting only Wainwright or our office building, Wainwright will conduct business operations from pre-determined alternate locations. Wainwright’s recovery time objective for business continuity, including those involving a relocation of personnel or technology, is generally one business day. This recovery objective may be negatively affected by the unavailability of external resources and circumstances beyond our control. Various external factors surrounding a disruption, such as time of day, scope of the disruption, and status of critical infrastructure – particularly Internet connectivity and telecommunications – can affect actual recovery times.
Maintaining a Secure Environment
Throughout an SBD, Wainwright will make every effort to maintain physical, technical, and administrative safeguards for the protection of confidential client information, personnel records, and other personal, confidential or proprietary information.