Business Continuity

Capstone Partners (“CP”) has a business continuity plan designed to address a significant business disruption affecting CP’s business operations and sets forth CP’s objectives of keeping employees safe, recovering and resuming operations, protecting books and records, and enabling communications with employees, clients, key service providers, and regulators.

Whether you are a client or a business partner, you should be aware that CP is committed to planning for and being prepared for a significant business disruption. CP’s business continuity plan addresses two types of significant business disruptions: “internal” disruptions, such as a fire in a CP building, affecting only CP’s ability to communicate and do business, and “external” disruptions, such as an event that might prevent the operation of the securities markets or a number of firms. In either event, CP’s goal will be to recover its critical business processes with minimal interruption, on the same day, if possible, although the length of the disruption is expected to be longer in the event of an external disruption, particularly one affecting the entire securities industry.

The business continuity plan covers CP’s critical business processes that are essential for CP to continue to conduct business for a temporary period during a business interruption. Every important aspect of CP’s securities business, including communications with clients, is addressed in these processes.

CP’s business continuity plan provides for alternative physical location of employees in the event of a business disruption, which may include employees’ residences, depending on the nature of the disruption and the offices affected by it. The plan further provides for financial and operational assessments, identifies mission-critical systems, and specifies how these systems would continue to operate in the event of a disruption.

In the event of a business disruption, CP has alternate methods of communication, specified in the business continuity plan, that would allow it to communicate with clients, employees, business partners, and regulators. The plan provides for CP’s establishment of alternative financial arrangements if necessary to maintain funding for operations in the event of a disruption.

Information technology is central to CP’s operations. CP has systems in place for the back-up and recovery of information needed to conduct its business. CP’s business continuity plan identifies the arrangements that CP would make to recover records, if necessary.

CP does not have custody of client funds or securities. In the event of an internal or external significant business disruption, if telephone service is available, CP will continue to be able to provide services to clients, unless the disruption is industry wide in scope.

The effects of a disaster are of course difficult to predict and the disruption of systems and processes on an industry-wide basis will pose great business continuity challenges for any firm in the securities industry. There can be no assurance that any plan can address these unforeseen contingencies. However, CP regularly reviews its business plan with a view to ensuring that it takes into account technological developments and changes in its business operations. CP will modify this summary from time to time as it reviews the plan. Clients may obtain a written copy of this summary by contacting Capstone Partners’ Chief Compliance Officer, by mail at 1225 17th Street, Suite 1725, Denver, CO 80202.

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