SUMMARY OF U.S. BUSINESS CONTINUITY PLAN
Instinet Incorporated has, among its primary goals, the safety of its personnel, protection of its clients' interests and security of its assets. To this end, Instinet Incorporated maintains a comprehensive Business Continuity Program ("BCP"), which seeks to promote enterprise-wide recovery capabilities by ensuring the Company has measures in place to address the impact of an unplanned business disruption.
Instinet Incorporated's BCP encompasses key areas within the Company and its subsidiaries, including Technology, Trading, and Clearing & Settlements. In addition, this plan summary also covers Instinet Incorporated's U.S. subsidiaries, Instinet, LLC and Instinet Group, LLC.
Instinet Incorporated's overall contingency framework is structured to support the continuation of business processes essential to the operation of critical business areas throughout the organization. While the specific response may vary based on the extent of the situation (e.g. firm-only or more extensive in scope), our BCP assumptions and methodologies, as well as associated recovery strategies are designed to provide an appropriate response to a wide range of business interruptions of varying severity.
Business Continuity Plans
Documented and tested BCPs are in place for critical business areas across each division. These plans identify the personnel, resources and key dependencies (e.g., third-party organizations) required to recover critical business functions, as well as the various procedures necessary to respond to and recover from a business disruption.
Business Recovery Facilities
Instinet Incorporated maintains multiple internal recovery locations for the continuation of business operations in the event of a business disruption that results in relocation of personnel or functions from any of its primary business locations. Recovery facilities have been located in geographically-diverse areas, a strategy designed to ensure viability and reasonable accessibility during adverse events. Additionally, recovery locations are supported by different utility power grids and telephone carrier central offices.
Business recovery facilities have been equipped to accommodate critical business processes, personnel and associated applications/services. These facilities were designed with the objective of continuing essential operations at an activity level comparable to that handled in the primary facility.
Business Continuity Testing
Business and technology tests are conducted periodically to validate the effectiveness of BCP procedures as well as the availability and functionality of the critical services at the backup locations in order to demonstrate the ability of business areas to recover critical business functions within specified recovery time objectives. Three types of testing are performed:
- Structured Walk-Through - Also referred to as a tabletop exercise, this is a paper evaluation of a BCP designed to expose gaps or omissions and verify that recovery personnel are familiar with recovery procedures.
- Plan Component Testing - Actual physical exercises designed to assess the effectiveness of individual plan elements and recovery activities (e.g. recovery site equipment/hardware functionality, etc.). This methodology is effective for identifying and resolving issues associated with isolated recovery activities.
- Full Recovery Site Operations Test - Validation of the full range of recovery capabilities available at the designated recovery locations.
Data Center Resiliency
In support of critical technology applications, systems and client connectivity, Instinet Incorporated maintains two production data center facilities in the US, which have been designed to promote a secure, resilient environment for processing capabilities. Locations are geographically diverse, being supported by separate power grids and telephone company central offices. Numerous access methods and vendors are utilized to minimize exposure from vendor failures.
Data centers are maintained as active centers that each provide vendor and client connectivity to production systems as part of normal operations. These are "live" stand-by locations that are utilized in the case of failure of a primary site.
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 Company's business, including client connectivity, transaction processing and clearing & settlements.
Integrated Management Structure
Senior management provides oversight and support for contingency planning activities within the BCP and aligns each business area's management with this program to promote the effectiveness of planning initiatives.
Additionally, Instinet Incorporated's corporate Crisis Management Team consists of senior management members from critical business and functional areas to provide a centralized and structured response during adverse events. All of the Company's incident management and recovery activities are guided by, and operate in direct conjunction with, this management structure.
Through the core BCP elements outlined above, Instinet Incorporated strives to provide a prompt response and subsequent recovery from any business disruption. While this information summarizes Instinet Incorporated's general intended response to a variety of potential business disruptions, it is important to note that actual response activities and recovery times will be determined largely by a number of factors related to the scope and severity of the specific situation.
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 specific impact of the disruption.
Instinet Incorporated's BCP is subject to modification and it is updated periodically, as a result of recovery testing, site activation, or whenever there is a material change to a business area's critical functions. The plan summary provided herein will be updated accordingly and posted on the Company's website (www.instinet.com). Clients may alternatively obtain an updated summary by requesting a written copy by mail:
309 West 49th Street
New York NY 10019
Any questions regarding Instinet Incorporated's BCP should be directed to the Global Business Continuity Manager.
All press and media inquiries should be directed to Instinet Media Relations:
309 West 49th Street
New York, NY 10019
Last Updated February 2020