Business Continuity Planning

Best Practices
Scarsdale Equities has instituted best practices for business continuity. These best practices have been developed in conjunction with our personnel responsible for internal audit, security, and technology. These best practices provide a guide for creating practical and effective business continuity plans. Scarsdale Equities' processes are built with business continuity in mind, embedding the necessary resources and knowledge into our day-to-day operations.

Organization
Scarsdale Equities has a dedicated Head of Business Continuity, who oversees the Firm's business continuity management strategy, and addresses all business continuity issues.

Response
In the event of an incident rendering a Scarsdale Equities location inaccessible, our strategy for continuing business is to ensure the safety and security of all employees first and second to continue critical business operations at predefined alternate sites.

To this end, Scarsdale Equities has established an incident management team consisting of senior management who will assess and direct The Firm's response to an incident. Employees of The Firm will provide continuity of critical business functions.

Employee awareness, and training is integral to the Firm's business continuity strategy. Employees are aware of their roles and responsibilities when business activities are disrupted.

Incidents of Varying Scope
The impact of a potential future business interruption is impossible to predict. Scarsdale Equities' business continuity plans have been written to account for incidents of varying scope, including building-wide and city-wide disruptions. In all cases, the plans will allow Scarsdale Equities to continue to do business, albeit at a reduced capacity, and meet its client obligations within the business day. Region-wide incidents, however, are far more complex and difficult to plan for. While Scarsdale Equities plans to continue to do business regardless of the nature of the incident, recovery from a significant region-wide business disruption depends not only on the availability of alternate workspace, but also on the survival of telecommunications carrier infrastructure, mass transit capabilities, and firm personnel among other things.

Regulatory Requirements and Industry Standards
Scarsdale Equities maintains regular contact with regulatory bodies such as the SEC, the Federal Reserve, and the Department of the Treasury to ensure that business continuity plans meet industry requirements.

Technology
Scarsdale Equities employs a dual data center strategy to protect all critical client data and access to the data. Critical data is replicated between data center sites to ensure that no data would be lost in the event of a failure.

Scarsdale Equities has implemented a robust telecommunications infrastructure, using multiple vendors feeding circuits from multiple central offices to allow maximum network resiliency. In the event of a complete site failure, telephone numbers can be re-routed to an alternate site.

Implementation, quality assurance and change management procedures are designed to incorporate disaster recovery readiness into our daily operations.

Scarsdale Equities has identified an alternate location for each of its production sites. Should a site become unavailable, the alternate location will provide service to clients who would otherwise be affected.

Disclaimer
Scarsdale Equities asserts that, to the best of its knowledge, all of the information contained in this document is accurate, and that Scarsdale Equities has created business continuity plans that meet industry standards and regulatory requirements. In the event of an actual significant business disruption, Scarsdale Equities will make every reasonable effort to enact these plans as written. However, the plans summarized above are highly dependent upon critical infrastructure and resources that Scarsdale Equities maintains no control over, including, but not limited to: electricity, telecommunications, water, external exchanges, market utilities, and clearing houses. Furthermore, Scarsdale Equities cannot guarantee that it will be able to fully implement the plans summarized herein if a significant business disruption results in substantial loss of life.