Millington Securities, Inc. (“Millington” or the “Firm”) has developed a Business Continuity Plan which is designed to help the business cope with an incident which affects our ability to perform in a normal way. The scale and type of response depends on the incident involved. A Significant Business Disruption (“SBD”) is defined as any event, either man-made or natural, that results in a prolonged interruption to the business and cannot be managed through normal management processes. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our Business Continuity Plan and our general Policy regarding business continuity planning.
Our Business Continuity Plan – Our Business Continuity Plan is designed to help us recover and resume operations as quickly as possible, depending on the scope and severity of the significant business disruption. Our priorities are to safeguard our employees and property, make a financial and operational assessment, protect the Firm’s books and records, and most importantly, allow our customers to transact business. Our Business Continuity Plan addresses data backup 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 counterparty impact; regulatory reporting and assuring our customers prompt access to their funds and securities if we are unable to continue business.
Our clearing firm, Pershing LLC, 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 critical functions and services and be able to complete existing transactions and accept new transactions and payments within one business day. Your orders and requests for funds and securities could be delayed during this period.
Varying Disruptions – SBDs can vary in scope and may affect only our Firm, a single building housing our Firm, the business district where our Firm is located, the city where we are located, or the whole region. 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, we will transfer our operations to a local site when needed and expect to recover and resume business as soon as possible. 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 as soon as possible. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our website or customer contact number, on how to contact us. If the SBD is so severe that it prevents us from remaining in business, we will assure our customers’ prompt access to their funds and securities through Pershing, the Firm’s clearing agent.