Business Continuity & Disaster Recovery Policy
The firm’s plan for maintaining critical operations and recovering from significant business disruptions.
1. Purpose
This policy establishes the firm’s Business Continuity and Disaster Recovery program to maintain critical functions and protect investor interests during a significant business disruption.
2. Scope
The plan addresses disruptions affecting personnel, facilities, technology, and key service providers, including the fund administrator, auditor, custodian, and counsel.
3. Governance
The Chief Compliance Officer, with operations and technology leadership, maintains and tests the plan and reports to senior management.
4. Critical Functions
The plan identifies critical functions, including investor communications, capital calls and distributions, valuation, books and records, and regulatory reporting, and the resources required to sustain them.
5. Data Backup & Recovery
Firm and fund records are backed up regularly to geographically diverse, secure locations, with defined recovery-time and recovery-point objectives.
6. Alternate Operations
Personnel are equipped for secure remote work, and alternate facilities and communication methods are identified to enable continued operations during a disruption.
7. Service-Provider Resilience
Key service providers maintain their own continuity programs, which the firm reviews as part of ongoing due diligence.
8. Communications
During a disruption, the firm communicates with investors, personnel, service providers, and regulators through predefined channels and contact protocols.
9. Testing & Review
The plan is tested and reviewed at least annually and updated in response to changes in the business or lessons learned from testing and actual events.
Notice
This document is a summary of the firm’s internal policy as adopted by the approving body identified above. The complete policy as adopted governs in any case of conflict between this summary and the underlying policy document. Limited partners and other authorized parties may request the full policy from the policy owner. This document does not create contractual rights, employment rights, or third-party beneficiary rights, and may be amended at any time by action of the approving body.
Questions about this policy should be directed to [email protected]. Confidential or anonymous reports may also be made through the channels described in the Whistleblower Policy.
Questions about firm governance
Limited partners, regulators, and counterparties with questions about firm governance, policies, or compliance should contact [email protected].