Business Continuity & Disaster Recovery Plan Summary
Semita Asset Management (“Semita”) has developed a Business Continuity/Disaster Recovery (BC/DR) Plan (the “Plan”) that addresses its response to various events that could significantly disrupt its business, such as natural disasters, power outages and other extraordinary events. Since the timing and the impact of such disruptions are unpredictable, the Plan has been designed to be flexible as its designated Team Members react and respond to events as they occur. However, in the event of a significant regional disruption or a disruption of the country’s securities markets’ operations, the firm’s ability to continue to operate its business will be dependent upon the survival and dependability of telecommunication carrier infrastructure, the availability of predetermined alternative worksites for the firm, and the availability of the firm’s key personnel.
Semita Asset Management LLC. is a registered investment advisory firm with operations atin One Riverway, Suite 2000, Houston, TX 77056. The firm has a designated Business Continuity/Disaster Recovery (BC/DR) Team that has developed a set of operating policies and procedures that guide how the firm will manage client relationships, employees, facilities, mission critical systems and data files, and private and confidential data in the event of a significant business disruption or disaster occurring. In the event of a significant business disruption that would render our current location inaccessible or inoperable, our BC/DR Plan directs the Team to first ensure the safety and security of all employees, to protect sensitive, private and confidential information regarding our clients, to protect other property and equipment that are critical to conducting the firm’s business, and then to restore business operations to normal at either one of several predetermined alternative sites or in the firm’s office suite once it is appropriate to do so. The firm’s BC/DR Plan is maintained at its main office location. A printed copy of the summary of the Plan is provided to clients and to business constituents upon request. Additionally, a copy of the Plan Summary is available on the firm’s website (www.semita-am.com).
Varying Business Disruptions
Significant business disruptions can vary in their scope, such as those affecting:
- Only a single building housing the firm’s operations in Houston, TX,
- The business district or city sector (Galleria /Post Oak /UpTown/ Riverway areas)
- The entire City of Houston, or Harris County Texas or the entire metropolitan area where the firm is located
Within each of these areas, the severity of the disruption can also vary from minimal to severe. In the event of a significant business disruption, whether local or regional, the firm may transfer operations to alternative sites as necessary to recover and resume business operations as quickly as possible, in most cases within twenty-four (24) hours. In the event that business operations are being relocated due to such business disruptions at our current site, we will post notices on our website (www.semita-am.com) or by voicemail at our business telephone number (+1.832.956.1000) regarding the status of our recovery process and how you may contact us.
The firm intends 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 firms’ books and records
Taking appropriate steps to allow us to continue to transact business on our clients’ behalf
The Plan Addresses:
Business Impact Analysis
- Identifying mission critical systems
- Evaluating targeted recovery time objectives
Operational Risk Assessments
- Outlining the functions and processes that are critical to the firm’s mission
BC/DR Team Membership and Responsibilities
- Plan development and maintenance
- Employee training
- Plan testing
Risk Management Practices
- Computer workstations/servers/LAN – back-up and redundancies
- Security of private and confidential client data files
- Insurance coverage
- Succession planning in the event of the absence of key personnel
- Alternative locations for remotely operating the business, if necessary
Crisis Management Actions
- Early preparedness, when possible
- Emergency phase
- When to and how to enact or execute the Plan
- Action priorities
- Communications with employees, clients, and key business constituents
- Date recovery plans
- Systems recovery plans
- Facilities recovery plans
After a significant business disruption, if you cannot contact us through normal channels, such as by telephone (+1.832.956.1000), you may access the Semita Asset Management website – www.semita-am.com – for the status of our business recovery efforts and to send emails to our personnel.
If you are unable to contact Semita by any of the above methods, contact your other service providers with respect to your investments as follows:
SEPARATELY MANAGED ACCOUNTS
You should contact the brokerage/custodian firm that has possession of your investment account for trading purposes when making inquiries about your investment holdings, account balances, money transfers, etc. The contact information for your brokerage/custodian firm should appear on the periodic statements sent to you by the custodian firm.
PRIVATE INVESTMENT FUNDS
You should contact the private fund’s administrator when making inquiries about your investment holdings, account balances, etc.