Imperial Capital SIM S.p.A.
LEGAL

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Imperial Capital – Società di Intermediazione Mobiliare S.p.A.
Sede Sociale e Direzione Generale: Via Torino, 49 – 20123 – Milano
Capitale Sociale Euro 610.000,00 interamente versato
Codice Fiscale, P. IVA e Iscrizione al Registro delle Imprese di Milano-Monza-Brianza-Lodi n. 11366920962
Società soggetta all’attività di direzione e coordinamento da parte di Imperial Capital (Holdings) Ltd
Aderente al Fondo Nazionale di Garanzia
Società autorizzata da CONSOB, sentita Banca d’Italia, e iscritta all’albo delle SIM, al n. 308

CONTENTS
TITLE I – INTRODUCTION
Introduction 
TITLE II – DESIGNATED OWNER 
Article 1. Designated Owner 
TITLE III – RISK ASSESSMENT
Article 2. Risk Assessment
TITLE IV – BUSINESS CONTINUITY PLAN
Article 3. Access to the office and other threats to the premises
Article 4. Power failure
Article 5. Computer failure or breakdown
Article 6. Failure of telephone landlines
Article 7. Loss or damage to hard copy files and records
Article 8. Recovery Site/ Rebuild
Article 9. BCP Awareness & Training
Article 10. Pre-Planned Testing 
Article 11. Emergency Contact List

TITLE I – INTRODUCTION

Introduction

This Business Continuity Plan (BCP) exists to ensure that the Firm is able to continue with its normal day to day operations in the event of a breakdown in systems, disablement of building/office and/or a temporary or permanent loss of power and to ensure the restoration and recovery of all necessary records. The plan applies to all personnel and departments.

The BCP includes contingency arrangements for the recovery from an event affecting business continuity and also preventative actions to minimise the likelihood of the occurrence of such an event.

This BCP will be reviewed, updated and tested periodically.

TITLE II – DESIGNATED OWNER

Article 1. Designated Owner

The Firm has appointed Daniele Crisci, Head of Finance & Operations as the Designated Owner of this BCP. The Designated Owner has full authority for all decisions, including spending, during a business continuity event. It is the responsibility of the Designated Owner to ensure test results are presented to the Principals periodically.

TITLE III – RISK ASSESSMENT

Article 2. Risk Assessment

This BCP takes into account risks that the Firm should be prepared for, as identified by the Principals. The risk assessment is reviewed at least annually after testing, and following any major operational change.

The following events and potential disasters have been considered for the purpose of this exercise. Whilst not exhaustive, the Firm believes the probability of these occurring or affecting its business is greatest:

• inaccessibility to the office and other threats to the physical premises;
• power failure;
• inability to access IT systems;
• failure of telephone landlines;
• loss or damage to hard copy files and records; and
• loss of key
• The above risks may have an impact upon one or more of the following aspects of the business:
• critical computer systems;
• critical systems data;
• critical paper assets;
• communications;
• premises; and
• staff.

TITLE IV – BUSINESS CONTINUITY PLAN

Article 3. Access to the office and other threats to the premises

Premises:

49, Via Torino

Milan, 20123

The BCP conforms to that of the Building Manager. The contact details of the Building Manager are:

Mr. Franco Catalano Immobiliare Camepa Srl Mob.: +39 320 8504240

Email: info@immobiliarecamepasrl.com

Events may occur that render the building inaccessible. In such circumstances, all Personnel should return home and connect remotely to the Firm’s system or relocate to the Firm’s disaster recovery site as directed. The Designated Owner will contact all Personnel, beginning with the Principals, to notify them of appropriate action depending on the nature of the circumstances. Emergency contact details are listed at the end of the BCP.

In the event that the premises should require vacating, standard evacuation procedures will be followed (see below). In case of a bomb or terrorist alert the evacuation procedures may be altered depending on the nature of the alert as it may be safer to remain inside the building. In these circumstances, the Designated Owner will coordinate with the Building Manager and Emergency Services and will direct all Personnel as to the appropriate action.

In the event of a serious incident occurring outside of normal working hours the Building Manager will act as a central contact point and will make contact with the Designated Owner. A decision will be made in conjunction with the Emergency Services where necessary as to whether to invoke the BCP.

Article 4. Power failure

• Servers/Routers/Switches are protected by uninterruptible power supply (UPS) or similar battery backup or generators.

Article 5. Computer failure or breakdown

• The Firm’s internal backup email solution can be activated within 30
• A disaster recovery backup is taken off the server on a monthly basis to an External Hard drive and Daily backup to a COLO Centre in London and to our group backup centre in the US to ensure that if it needs to be rebuilt or replaced it could be quickly restored to the appropriate configuration.

Article 6. Failure of telephone landlines

• All Personnel have mobile phones and therefore it is not anticipated that a failure of the telephone switch would cause serious issue. All telephone hardware is under warranty with the manufacture.
• Voice communications recovery strategy can be implemented within 30 Min of invocation. 100% of voice lines can be redirected to an appropriate alternative location (e.g. recovery site, call centre) within 30 Min of invocation.
• At least 100% of business as usual calls throughout (including fax and modem) can be handled at the recovery site. There are connections to multiple external telephone

Article 7. Loss or damage to hard copy files and records

• All critical data is copied or replicated at another site. It takes less than one hour to retrieve off- site copies of critical recovery data.

Article 8. Recovery Site/ Rebuild

If the BCP is invoked the Designated Owner has 24 hour access to the Firm’s nominated

recovery site

at the following address:

Imperial Capital (International), LLP

One Eagle Place

London SW1Y 6AF

UNITED KINGDOM

The Firm’s IT Support, (all IT Support is provide it by Imperial Capital staff, where the first contact will be Fadi Jaber), will have access to the recovery site and will begin restoring all IT systems within 24 hours.

Alternatively, if the BCP is invoked the Designated Owner has 24 hour access to the Firm’s IT Support, (all IT Support is provide it by Imperial Capital staff, where the first contact will be Fadi Jaber), who will begin to restore mirror systems, including back up devices and software to manage backups from online backup systems when the primary system has failed. IT restoration addresses the need of remote access for Personnel who are required to stay at home.

Article 9. BCP Awareness & Training

• This BCP is readily accessible and available to all It is posted on the Intranet.
• Principals and relevant Personnel are familiar with their intended role during a major disruption and their responsibilities for the operation of the BCP.
• All critical Principals and Personnel have trained deputies who can fulfil their

Article 10. Pre-Planned Testing

All arrangements contained in this BCP are tested periodically, and the results of the testing fully documented.

Tests involve integrated simulation, which includes IT, office facility and critical staff recovery using alternate facilities.

• IT recovery tests are required to realistically reflect the worst case scenario where all critical systems must be restored concurrently.
• Capacity to cope with multiple concurrent usage has been
• Critical systems recovery is tested every 3
• Testing of identified critical application or hardware and/or software
• Operation of market data and other critical third party feeds are tested at the disaster recovery site.
• Tests to rebuild the client or desktop
• Restoration of critical applications: backups on an un-configured system are
• If critical backups are needed, the restore is tested every
• UPS are full load tested twice a
• Unscheduled recall of offsite copies of critical recovery data are requested to test
• Out of hours telephone contact tests are conducted at least once per
• Telephony recovery test takes place at least
• After any of the above tests, reports are completed with clear actions and

Article 11. Emergency Contact List