Business Continuity Plan

As part of our ongoing commitment to inform and engage our clients, our business continuity plan summarizes the company’s effort to mitigate risks inherent with unforeseen business interruptions and enable the company to meet existing obligations to its clients, employees, regulators and key service providers.

The company’s policy is to respond to a Significant Business Disruption (SBD) and allow our clients to transact business normally, safeguard the lives of our employee’s and company property, make effective financial and operational assessments, quickly recover and resume operations, and protect all of the company’s books and records.

Since the timing and impact of disasters and disruptions are unpredictable, the company must be flexible in responding to actual events as they occur. The plan is designed to work in many different emergency situations; but these events are, by their nature, unpredictable and it is impossible to anticipate every scenario that could cause a business disruption. Furthermore, although we are confident in our own preparedness, vCap FX has no control over the various entities that we must rely upon in the event of an emergency.

The key elements of our BCP include the following:

Significant Business Disruptions (SBDs)

Our BCP plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the company’s ability to communicate and do business. External SBDs prevent the operation of the company as well as its service providers, such as a terrorist attack, or a wide-scale regional disruption. The company’s response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of the company’s service providers such as FCMs and other IIBs, with whom the company conducts business.

Employee Awareness

All employees are continually made aware of their responsibilities and know how to remain in contact and what to do in the event of a crisis and are responsible for understanding the Employee Awareness Plan as well as any updates to the company’s BCP. Such awareness is conducted on an annual basis through the company’s required Annual Ethics Training Program.

Emergency Contact Information

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* Our plans are subject to modification at any time.

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