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GRANT THORNTON CORPORATE FINANCE, L.L.C.
SUMMARY OF
BUSINESS CONTINUITY PLAN
Grant Thornton Corporate Finance, LLC (the “Firm”) maintains this Business
Continuity Plan, describing in our policy used in responding to a Significant Business
Disruption (“SBD”). Our response is directed to 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, we will assure customers prompt access to their funds and securities.
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs
affect 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.
1. Emergency Contact Persons
Our firm’s two emergency contact persons are: Ian Cookson,
ICookson@gt.com, (617) 848-4982 and George Shaw, (617) 848-4890
GShaw@gt.com. These names will be updated in the event of a material change, and
our Executive Representative will review them within 17 business days of the end of each
quarter. Customers should direct their emergency contacts to the above persons.
2. Business Description
Our firm primarily provides investment related securities clients considering
business combinations, acquisitions or divestitures. Our firm has no clearing relationship
with any firm. We do not hold customer funds or securities, nor do we accept and enter
orders. Our firm services primarily institutional clients. Our private placement activity is
limited to advising issuers with respect to private offerings.
3. Office Locations
Our Office Location is 226 Causeway Street, Boston, Massachusetts 02114. Its
main telephone number is (617) 723-7900. Our employees may travel to that office by
means of subway or car. We engage our business activity at this location.
4. Alternative Physical Location of Employees
If our primary site is inoperable, we will continue operations from employees’
homes. We anticipate that employees may access the Grant Thornton network, which is
maintained at facilities in Chicago and New York.
5. 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, and regulators. Although the effects of an SBD will determine the means of
alternative communication, the communications options we will employ will include our
Web site and telephone voice mail.
B. Financial and Credit Risk
In the event of an SBD, we will determine the value and liquidity of our assets to
evaluate our ability to continue to remain in capital compliance. We will contact critical
banks and Grant Thornton to apprise them of our financial status.
6. Mission Critical Systems
Our firm’s “mission critical systems” are those that ensure communications with
clients.
We have primary responsibility for establishing and maintaining our business
relationships with our customers and have sole responsibility for our mission critical
functions of communications.
In the event of an internal or external SBD, we will contact clients by the best
alternative means available, which include fax or e-mail.
7. Alternate Communications Between the Firm and Clients, Employees, and
Regulators
We now communicate with our Clients using the telephone, e-mail, our Web site,
fax, U.S. mail, and in person visits at our firm or at the other’s location. 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 e-mail 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.
8. Disclosure of Business Continuity Plan
This BCP disclosure statement is provided to customers at account opening,
posted on our Web site and mailed to customers upon request.
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