Business Continuity plan summary

BUSINESS CONTINUITY PLAN: SUMMARY PLAN DISCLOSURE

Overview:

BARCLAY INVESTMENTS, INC. has developed a Business Continuity Plan (“BCP”) in an effort to mitigate the effects of unforeseen business interruptions. The timing and impact of a significant business disruptions (“SBD”) is unpredictable, therefore, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with the below information on our business continuity plan.

Communications:

In the event of an SBD, you cannot contact us at our office at 212-421-8901 or at info@barclayi.com, you should call our emergency number 212-421-9317 or go to our web site at www.barclayi.com. If you cannot access us through those means, you should contact our clearing firm, Industrial and Commercial Bank of China (“ICBC”) at the emergency contact number,1-888-528-1402 or disaster recovery site number, 212-729-9000, for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions for our customers.

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 business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our BCP 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.

Clearing Operations:

Our clearing firm, ICBC backs up our important 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 as soon as possible. Your orders and requests for funds and securities could be delayed during this period.

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 our 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, employees will work from home or the firm will transfer operations to a local site when needed and expect to recover and resume business within 48 hours. 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 72 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site www.barclayi.com or from our customer emergency number, 212-421-9317. If the SBD 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, you can contact us by phone at 212-421-8901 or by email at info@barclayi.com.

Disclosure:

The current BCP is designed to address the continued operation of the firm in the event of an emergency situation or SBD; however, all risks of business interruption cannot be eliminated and the firm cannot guarantee that systems will always be available or recoverable following a SBD. Furthermore, BARCLAY INVESTMENTS, INC. has no control over critical business constituents and vendors, and must rely upon their disaster recovery plans. In the event that material changes are made to this BCP, the firm will post the updated summary on this web site.

The information contained in this disclosure is provided by the firm for informational purposes only, and nothing contained herein shall be construed to amend, supplement or otherwise modify any of the terms and conditions set forth in any customer agreement between you and BARCLAY INVESTMENTS, INC.