Themis Trading LLC’s (Themis) Business Continuity Planning (BCP)
November 2007
** Please note that this BCP summary is based on the template provided by the NASD as a guide to small introducing firms. The template recognizes that many small introducing firms rely on parts of a clearing firm’s BCP for many of the mission critical functions of the introducing firm.
Themis has developed a BCP on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our BCP.
Contacting Us
If after a significant business disruption you cannot contact us as you usually do via phone, instant messaging, Bloomberg, FIX connections, or email, you should call our emergency contact persons via their cell phones 973-615-8880 or 917-359-6174. If you cannot access us through either of those means, you should contact our clearing firm, Goldman Sachs Execution & Clearing, L.P. (GSEC, see contact information below). Themis or GSEC contacts will provide instructions on how it may provide order comparison, order allocation, and the maintenance of customer accounts, delivery of funds and securities, order execution, and access to customer accounts.
Goldman Sachs Execution & Clearing, L.P.
Global Clearing and Execution
30 Hudson Street
Jersey City, N.J. 07302
Neil Burtos (212) 357-6236
Christian Meyer (212) 357-7326
Our Business Continuity Plan
We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our BCP is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Our clearing firm, GSEC has developed their own BCP in order to provide reasonable assurance of business continuity in the event that there are disruptions of normal operation at the firm’s critical facilities. As part of the plan, GSEC backs up its important Themis related records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within as soon as practical. Your orders and requests for funds and securities could be delayed during this period that GSEC implements its business continuity plans.
Varying Disruptions
Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within one hour. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within one business day. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our customer emergency numbers provided above in the “Contacting Us” section. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.
For more information
If you have questions about our business continuity planning, please contact us as follows.
Themis Trading LLC
Paul Zajac, Partner
973-665-9600 phone
pzajac@ThemisTrading.com
Themis Website: www.ThemisTrading.com
