Business Continuity Plan Summary

ProATS and ProCap Business Continuity Plan Summary

Prometheum Ember ATS Inc. (“ProATS”) and Prometheum Capital (“ProCap) (collectively “we”, “us”, “our”) have developed a Business Continuity Plan (the “BCP”) to provide procedures for response and recovery in the event of a significant business disruption. Our goal is to ensure our continued ability to serve our customers and to protect their assets and information and the people and assets of our firm.Events creating a disruption of business may vary in nature, and the BCP has been developed to provide commercially reasonable assurance of business continuity in the event that there are disruptions of normal operations at the firm’s critical facilities. The timing and impact of disasters is unpredictable and the BCP emphasizes a flexible approach.

The BCP addresses interruptions that are either localized or regional in scope, whether short or long term, regardless of the cause. We believe that through its BCP, it will be able to conduct a securities business during periods of business disruption ranging from disruptions that only affect ProATS and or ProCap to disruptions that have regional impact. However, our BCP is not a guarantee that the firm will be able to conduct securities business during every business disruption.

The BCP is reviewed and tested annually and has been approved by senior management.

Business Continuity Plan ‐ Overview

FINRA Rule 4370 requires each member firm to create and maintain a business continuity plan. In accordance with this rule, we have developed a plan designed to allow us to continue operating during business emergencies, as permitted by conditions on the ground.

Our plan is designed to address key areas of concern including, but not limited to, the following:

• Books and records recovery;
• All mission-critical systems;
• Financial and operational assessments;
• Alternate means of communication between us  and our customers;
• Alternate means of communication between us and our employees;
• Alternate physical locations of employees;
• Critical business constituent, bank and counterparty impact;
• Regulatory reporting; and
• Communications with regulators.

For example, to address potential disruptions, the BCP is designed to facilitate our employees’ ability to work remotely from a non-impacted, internet-connected site and to maintain operations and communications with customers and regulators. In the event of a national disruption, we will contact and follow the instructions of FINRA, the SEC, and state and national authorities.
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Please be advised that business continuity plans are subject to change and modification. We intend to update and test its business continuity plan as business conditions and technology change.A copy of the firm’s complete BCP can be obtained by contacting ProATS at: customersupport@emberats.com or customersupport@procustody.com.