Business Continuity Plan Disclosure

These disclosures are supplemental to any agreements, terms of business or other documentation you may have in place with any Hidden Road entity (including, but not limited to Hidden Road Partners CIV UK Ltd, Hidden Road Partners CIV (BVI) Limited, Hidden Road Partners CIV NL B.V., Hidden Road Partners CIV US OTC LLC and Hidden Road Partners CIV US LLC (collectively “Hidden Road”, “us”)) and may be amended or supplemented by additional disclosures from time to time and are intended for use by professional clients and eligible counterparties. Defined terms used but not defined herein have the meanings ascribed to them in the Terms.

Hidden Road Inc, including subsidiaries and affiliates has developed a Business Continuity Plan (“BCP” or the “Plan”) on how we will respond to events that significantly disrupt our business. 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 BCP.

 

Contacting Us

If after a significant business disruption, you cannot contact us as you usually do, you should go to the Group’s website at www.hiddenroad.com for further guidance and/or attempt the following methods:

 

Email

 

Telephone

  • Hidden Road New York: +1.646.837.5623
  • Hidden Road London: +44.0.20.7081.2588

 

Our Business Continuity Plan

The key objective of the Business Continuity Plan is the preservation of our business in the event of a Disruption. The Chief Executive Officer and the senior management of the Firm take this objective very seriously. We operate within a region that has suffered business interruptions caused by terrorism (the attacks of September 11, 2001) and the failure of infrastructure due to severe weather systems such as massive hurricanes, tropical storms, Nor’easters and blizzards. As such, the firm has taken steps to utilize Software-as-a-Service (“SaaS”), Platform-as-a-Service (“PaaS”), and Infrastructure-as-a-Service (“IaaS”) platforms hosted in public and private clouds. This strategy reduces our Firm’s footprint and the dependency on locally stored infrastructure.

The Plan is a living document. The concept of business continuity is an active, ongoing state of preparedness that we must maintain through testing, updating, modification and education. Management has instilled a culture where every employee to take this effort seriously and in some way be an active participant in this endeavor.

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the Group’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

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 counter-party impact;
  • regulatory reporting; and
  • assuring our customers prompt access to their funds and/or positions as applicable, if we are unable to continue our business.

 

The Group is 100% public cloud based. As such, we employ many third-party service providers who host multi-regional, public cloud SaaS/PaaS/IaaS environments. The software, platforms, and infrastructure are utilized for the daily running of our business. The applications, platforms and infrastructure services are all accessible via the Internet and do not require traditional dedicated onsite infrastructure to utilize them. All of the Group’s data is backed up on an ongoing basis throughout the day and is recoverable in minutes.

When choosing vendors for the critical business systems, we attempt to understand their BCP, redundancy and data back-up procedures. We confirm that, when our records are maintained in third-party’s system, that they back up our important records, as necessary.

While every emergency situation poses unique problems based on external factors, such as time of day , the severity of the disruption, and its scope, we choose vendors with the objective of maximizing redundancy and minimizing failover time so that we can restore operations and be able to complete existing transactions and accept new transactions and payments as soon as possible. Your orders and requests for funds and securities could possibly be delayed during this period while we take every effort to be able to restore as much functionality across our businesses as completely and promptly as practicable.

 

Varying Disruptions

Significant business disruptions can vary in their scope, such as 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. Within each of these areas, 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 ensure all our operations are shifted to an external access model such as working from home and expect to recover and resume business in less than 5 minutes as the majority of Hidden Road’s staff work from home, especially during this COVID crisis. 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 within two hours.

In either situation, we plan to continue in business; however, if the significant business disruption is so severe that it prevents us from remaining in business, we will take every effort practicable so that our customers can have prompt access to their funds and positions.

 

For more information

If you have questions about our business continuity planning, you can contact us through the previously mentioned communication channels.

Subsidiaries and affiliates include, but is not limited to the following entities: Hidden Road Inc, the top-level Group entity; Hidden Road Partners CIV UK Ltd (“HRPUK”), authorized and regulated by the Financial Conduct Authority (“FCA”); Hidden Road Partners CIV US LLC (“HRPUS”), registered with the CFTC and NFA as a futures commission merchant (FCM).; and Hidden Road Partners CIV OTC US LLC, an unregulated forex prime broker, Hidden Road Partners CIV (BVI) Ltd and Hidden Road Partners CIV NL B.V..

 

Last Updated: October 21, 2022