Business Continuity Plan Disclosure
In accordance with applicable regulations, Battenkill Capital, Inc. has developed and implemented a Business Continuity Plan to assist the firm in appropriately responding to a significant business disruption (SBD) as promptly as possible under prevailing conditions. Among other things, Battenkills Business Continuity Plan:
Identifies Emergency Contact Personnel to the firms regulators;
Describes the systems infrastructure protections that the firm has established in an effort to minimize the potential adverse effects of a SBD (for example, redundancy of telecommunications and power generation, fire protection and building security);
Describes the firms daily back-up of specified data and records and maintenance of back-up media at secure off-site locations;
Identifies the firms Disaster Recovery Site(s) and the methods that the firm would use to recover particular data and operations at the site;
Identifies important firm operations and where applicable, describes how those operations could be re-established in the event of a SBD;
Identifies the means by which Battenkill will provide customers prompt access to their accounts at their clearing firm, Broadcort Clearing Division, Merrill Lynch; and
Describes the means by which Battenkill will communicate with its customers, employees, business constituents and regulators in the event of a SBD.
In the event of a SBD, Battenkill intends to continue its operations to the extent it feels is reasonable and practical under the circumstances and will place utmost priority in re-establishing the data and operational systems necessary to provide its customers with prompt access to their trade data and accounts.
Battenkill intends to respond to disruptions of particular scope as follows:
Branch Office Disruption
Basic Access to Accounts: As Battenkill is an introducing Broker/Dealer and does not custody client accounts or securities or funds, critical systems and personnel necessary to provide customers with access to their funds and securities generally are not dependent on operation of Battenkills branch offices (Vermont & New Orleans, LA). Thus, Battenkill does not anticipate that even a significant disruption to the operations of a single Battenkill branch office would have more than a temporary impact (if any) on customers basic access to their accounts at Broadcort.
Other Branch Office Functions: Most important operations performed in Battenkills branch offices, such as customer service, account application processing, compliance, etc. are also performed in other Battenkill branch offices and could be migrated to similarly trained personnel in the other branch office promptly. Accordingly, Battenkill does not anticipate that localized failures in a branch office would have a substantial negative impact on the firms ability to respond to customer issues. Recovery time would be minimal.
Access to Trading Personnel: Should the business disruption only effect one of Battenkills offices, Battenkills unaffected office will stand ready to function in full capacity for all Battenkill customers through the course of the disruption. Trades may be routed through the unaffected office without impact. Alternately, Broadcort may be contacted to provide trading support and executions directly should both offices be incapacitated.
Contacting Us
| Battenkill Capital, Inc. (Vermont) | Shawn Harrington Grigsby Markham |
(802) 549-5402 (802) 558 5080c (802) 549-5404 o |
| Battenkill Capital, Inc. (New Orleans) | Lee Schlesinger |
(504) 299-3025 o
|
| Battenkill Capital, Inc. (NYSE Floor) | Patrick Armstrong (non-registered location) |
(866) 901-2282 (212) 810-0818 c |
| Broadcort Clearing Division, Merrill Lynch | Ralph Posimato | (201) 557-4405 |
Important Disclaimers
Battenkill will adhere to the procedures set forth in its Business Continuity Plan as described in this disclosure to the extent reasonable and practicable under prevailing conditions. However, there are innumerable potential causes of a SBD. In addition, disruptions (and the events that caused them) may vary significantly in nature, size, scope, severity, duration, and geographic location and will result in distinct degrees of harm to human life, firm assets, the banks, exchanges, clearing houses, and depositories with which Battenkill conducts business, and local, regional and national systems infrastructure (e.g. telecommunications, Internet connectivity, power generation and transportation) that could affect the firms recovery in vastly disparate ways. In recognition of this, Battenkill reserves the right to flexibly respond to particular emergencies and business disruptions in a situation-specific manner which the firm deems prudent in its sole discretion. Nothing in this document should be perceived as providing a guarantee or warranty regarding the actions or performance of Battenkill Capital, Inc., its systems, or its personnel in the event of a significant business disruption.
Battenkill may modify its Business Continuity Plan and this disclosure at any time. Battenkill will post updates to its Business Continuity Plan on its website, www.battencap.com. Should you wish to receive a copy of an updated disclosure by mail, please contact Battenkill Capital, Inc. at info@battencap.com.
