Prometheum Ember Capital LLC (“ProCap) has 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 ProCap 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. ProCap believes that through its BCP, it will be able to conduct a securities business during periods of business disruption ranging from disruptions that only affect ProCap to disruptions that have regional impact. However, the ProCap 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, ProCap has developed a plan designed to allow ProCap to continue operating during business emergencies, as permitted by conditions on the ground.
ProCap’s 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 ProCap and its customers;
Alternate means of communication between ProCap and its 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, ProCap has arranged for an alternate local physical location, for both employees and key technology infrastructure. ProCap believes that in the event of a disruption, this alternate location will allow the firm to promptly relocate its key employees and critical information technology systems in order to provide services for its clients. The ProCap 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, ProCap will contact and follow the instructions of FINRA, the SEC, and state and national authorities.
Please be advised that business continuity plans are subject to change and modification. ProCap intends to update and test its business continuity plan as business conditions and technology change. Material changes to the ProCap BCP will be posted to the firm’s website located at www.prometheum.com/disclosures. A copy of the firm’s complete BCP can be obtained by contacting ProCap at: [email protected].