Business continuity for disaster recovery is a high priority for GFI and its subsidiaries, including GFI Securities, LLC. Our goal is to ensure our continued ability to serve our clients and to protect their assets and the people and assets of our firm. Our Business Continuity Program (the “program”) has been developed to provide reasonable assurance of business continuity in the event that there are disruptions of normal operations at the firm’s critical facilities.

The firm has established a global, structured approach designed to ensure that the firm is prepared should a business disruption occur. This approach addresses business disruptions of varying scope and severity, which may include disruptions affecting individual business or specific locations; city-wide or industry-wide failures; and regional, national, or global events that affect our business.

No contingency plan can be failsafe or provide absolute assurance that an interruption in business will not occur or that negative consequences will not ensue from a crisis or event. Because natural and other disruptions – even if anticipated generally – are unpredictable and can change over time, a disruption may not have been fully anticipated when the plan was originally designed or later modified. That said, GFI is committed to ensuring that its program is comprehensive and up-to-date, particularly as new information, techniques, and technologies become available. We may alter, add to, or eliminate specific aspects of the program as we judge appropriate for the protection of all concerned. We will keep both our clients and our own community informed of pertinent changes.

The GFI’s Business Continuity Program

1. Crisis Management: Coordination, Communication, and Training

Crisis Management encompasses the communication processes and response procedures by which the firm manages a business disruption, as well as the tools, training, and exercises we use to help prepare the firm and our people for possible disruptions. Because the first two hours following a disruption are often the most critical, the firm has established a multi-pronged, rapid response capability that includes:

• Formal Command Centers in every region of the firm’s worldwide operations. The Command Centers allow the firm to monitor its environment, execute pre-established crisis management procedures, and coordinate responses.
• Communication plans with local authorities and regulators to facilitate information flow and coordination of responses.
• Processes and communication tools, including some automated tools, to notify key senior managers and personnel quickly at the onset of a disruption.

2. Business Recovery

Business Recovery focuses on protecting client assets and assuring that the firm is able to continue business operations in the event of a business disruption. Central to the firm’s business recovery efforts is a requirement that each GFI business unit develop, test, and maintain recovery plans for each of its core functions. As part of these plans, each business unit identifies critical risks and puts in place the appropriate level of business controls and functionality necessary to mitigate those risks. The resultant plans document the functional requirements – equipment, applications, vital records and regulatory reports, relocation sites, and recovery teams and tasks – needed to re-establish essential business operations. The plans also assess the impact of a business disruption on the firm’s business constituents, banks, and counterparties.

3. Systems and Data Recovery

Systems and Data Recovery focuses on restoring the firm’s core infrastructure, including networking, applications, market-data feeds, and other shared technologies to ensure the continuation of critical business systems processing. Applications are prioritized based on their criticality to the business. Recovery requirements and the frequency of application testing are then established based on those priorities.

Wherever practicable, GFI separates the people conducting business from the technology infrastructure or backup facilities supporting the business, housing them in separate locations, thus reducing the likelihood of simultaneous personnel and systems disasters. Backup generators are used to protect the most critical facilities.
In addition, offsite data centers have been established outside our primary facilities to support recovery of critical systems and data. Critical data is regularly backed up to these locations.

Also, GFI’’s clearing firms back 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 firms that they aim to restore their own operations and be able to complete existing transactions and accept new transactions and payments within a reasonable time after the event. Your orders and requests for funds and securities could be delayed during this period.

4. People Recovery Facilities

People Recovery Facilities focuses on ensuring that our people can quickly get back to productive work when their physical facilities are not operating. GFI has plans to ensure that the critical persons in each of our departments will be up and functional at different locations in the short term after a disaster. As a further safeguard, depending on the kind and extent of the disruption, many critical functions can be shifted to other principal offices of GFI, including offices outside the US.

5. Process Improvement: Continual Assessment and Testing

Process Improvement assesses and tests our state of readiness for foreseeable business disruptions, including:

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• Ongoing testing of current plans
• Continually reassessing risk – including operational and financial risks – and integrating new risk scenarios into the program.
• Updating business requirements and integrating them into the program.
• Introducing new strategies and technologies as they become available.
• Customer Communications and Questions

This document provides an overview of the firm’s Business Continuity Program. If you have additional questions, please contact your GFI representative. Please bear in mind that we will not respond to specific questions about the program that could compromise our security. Pertinent updates to this overview will be made available on thsis website. This overview can also be obtained via mail by contacting your GFI representative.

In the Event of a Business Disruption

Should there be a significant business disruption, customers are encouraged to visit the GFI Web site (www.gfigroup.com) for additional information or contact GFI at 212-968-4100 or in the event its New York Office cannot be contacted at its London affiliate at 011-44-20-7422-1000.

This overview is designed to satisfy disclosure requirements under FINRA rules requiring the establishment and maintenance of a Business Continuity and Contingency Plan.