SUMMARY OF U.S. BUSINESS CONTINUITY PLAN
Business Continuity Overview
Instinet Holdings Incorporated (“Instinet” or the “Firm”) and its subsidiaries, which includes Instinet Incorporated's U.S. subsidiaries, Instinet, LLC and Instinet Group, LLC have created a Business Continuity Plan ("BCP" or "Plan") to facilitate the continuation of operations following the occurrence of an emergency situation or significant business disruption (“SBD”). The Plan focuses on promoting employee safety, facilitating rapid response and decision-making, conducting a financial and operational assessment of the situation, minimizing business disruptions, protecting the Firm’s books and records and providing a foundation for resuming interrupted operations and services as quickly and efficiently as possible given the scope and severity of the SBD.
The Plan contemplates disruption of varying scope, including but not limited to, major technology and power outages, natural disasters, terrorism, and physical damage to offices or data center facilities such that employee access is not permitted. Of course, despite this "all hazards" approach to business continuity planning, no plan can anticipate all possible occurrences or guarantee the recovery of all services where the emergency event results in a significant loss of life and or physical assets.
The Firms' Plan incorporates the following core elements:
The Firm recognizes that a successful response to a SBD hinges on an effective command, control and communications program. To this end, the Plan utilizes an incident management program that brings together key leadership in a formal team structure. The team can analyze quickly the impact of an incident and take appropriate action. The Firms use multiple communications technologies to ensure that team members remain connected in an emergency. Additionally, the same communication technologies can be leveraged to communicate with other broker-dealers, counter-parties, customers and regulators.
Pursuant to applicable regulation and Firm mandate, all business lines and support functions are required to develop procedures to account for all business processes in emergency circumstances, including a SBD. These measures include, but are not limited to:
- Data back-up and recovery;
- All mission critical systems;
- Financial and operational assessments;
- Alternate communications;
- Alternate physical locations;
- Critical business constituent, bank, and counter-party impact;
- Regulatory reporting; and
- If applicable, assuring the Firm’s customers' prompt access to their funds and securities in the event that the Firm determines that it is unable to continue its business.
Systems and Data Recovery
The Plan's effectiveness depends in part on the creation and maintenance of a highly resilient technology infrastructure. The Firm maintains multiple data center facilities, which have been designed to promote a secure, resilient environment for processing capabilities and serve to eliminate a single point of failure. The Firm also maintains multiple network connections across data center facilities to provide maximum resilience. All Firm critical systems are backed up daily and the data is stored at an off-site location.
The overall network design strategy fosters resiliency, continuous availability and failover for critical network/telecommunications services. Data centers have the capability to failover critical system components and these processes operate in conjunction with procedures to support restoration of critical functions of the Firm’s business, including client connectivity, transaction processing and settlement.
The Firm maintains fully-equipped, operational real estate capacity outside of New York City to allow all major lines of business to continue operations in the event that the Firms' normal physical workspaces in New York City become unavailable.
The Firm has developed a BCP/Disaster Recovery testing program to ensure that all components of the Plan are accurate, updated and meet expected goals. The Firm’s testing program encompasses all critical applications, simulations of workspace recovery at various Firm locations and incident management drills.
Business and technology tests are conducted periodically to validate the effectiveness of Instinet’s BCP as well as the availability and functionality of the critical services at the backup locations. Tests also demonstrate the Firm’s ability to recover critical business functions within specified recovery time objectives.
Integrated Management Structure
Instinet’s Crisis Management Team consists of senior management members from critical business and functional areas to provide a centralized and structured response during adverse events. Senior management provides oversight and support for contingency planning activities within the BCP and aligns each business unit with this program to promote consistent and effective of planning initiatives.
Instinet Incorporated will make every effort to provide clients with information on the status of operations as quickly as possible, using the most effective method of communication available based on the impact of the disruption.
Instinet's BCP is subject to modification and may be updated as a result of recovery testing, site activation, or as a result of a material change to the Firm’s business. The Plan summary provided herein will be updated accordingly and posted on the Firm’s website (www.instinet.com). Customers may alternatively obtain an updated summary by requesting a written copy by mail:
Questions regarding Instinet's BCP should be directed to:
Instinet Business Resilience Team
309 West 49th Street
New York NY 10019
Press and media inquiries should be directed to Instinet Media Relations:
309 West 49th Street
New York, NY 10019
Last Updated September 2023