Business Continuity Plan

Summary Disclosure of Business Continuity Plan

Hines Pri­vate Wealth Solu­tions LLC (“Hines PWS”) has devel­oped a com­pre­hen­sive Busi­ness Con­ti­nu­ity Plan (“BCP”) on how we will respond to a sig­nif­i­cant busi­ness dis­rup­tion. Since the tim­ing and impact of dis­as­ters and dis­rup­tions are unpre­dictable, we will have to be flex­i­ble when respond­ing to actu­al events as they occur. With that in mind, we are pro­vid­ing you with this infor­ma­tion on our busi­ness con­ti­nu­ity plan.

Our Business Continuity Plan

The pol­i­cy of Hines PWS is to respond to a Sig­nif­i­cant Busi­ness Dis­rup­tion (“SBD”) by safe­guard­ing employ­ees’ lives and firm prop­er­ty, mak­ing a finan­cial and oper­a­tional assess­ment, quick­ly recov­er­ing and resum­ing oper­a­tions, pro­tect­ing the firm’s books and records, and allow­ing our cus­tomers to trans­act busi­ness as soon as pos­si­ble fol­low­ing such SBD. The plan is updat­ed as need­ed and is sub­ject to test­ing, eval­u­a­tion, and senior man­age­ment review on an ongo­ing basis. Our BCP address­es: data back-up and recov­ery (hard copy and elec­tron­ic); all mis­sion crit­i­cal sys­tems; finan­cial and oper­a­tional assess­ments; alter­nate com­mu­ni­ca­tions with cus­tomers; alter­nate com­mu­ni­ca­tions with employ­ees; alter­nate phys­i­cal loca­tion of employ­ees; crit­i­cal busi­ness con­stituents, banks, and counter-par­ty impact; reg­u­la­to­ry report­ing; com­mu­ni­ca­tions with reg­u­la­tors; and pro­ce­dures to ensure our cus­tomers’ prompt access to their funds and secu­ri­ties in the event that the we deter­mine we are unable to con­tin­ue our business.

Business Disruption Scenarios

Under most sce­nar­ios, we expect to con­tin­ue doing busi­ness and resume oper­a­tions with min­i­mal ser­vice impacts. How­ev­er, under cer­tain sce­nar­ios, the time that it takes Hines PWS to recov­er and to resume oper­a­tions may be sig­nif­i­cant­ly increased depend­ing on the extent of dis­rup­tion to our sys­tems and the num­ber of per­son­nel affect­ed. In the event of a dis­rup­tion that affects our main office, such as pow­er out­age, we would acti­vate the dis­as­ter rout­ing plan for our phone sys­tem and move key per­son­nel to a remote loca­tion. If this type of dis­rup­tion takes place, we expect to recov­er and resume busi­ness with­in 24 hours. If a dis­rup­tion is sig­nif­i­cant enough to affect the entire city or region, such as a hur­ri­cane, cer­tain key employ­ees will work remote­ly and cer­tain oper­a­tions and sup­port ser­vices will be relo­cat­ed to an alter­nate site out­side of the affect­ed area. If this type of dis­rup­tion takes place, we expect to recov­er and resume busi­ness with­in 48 hours. In the sit­u­a­tions described above, in light of the var­i­ous types of dis­rup­tions that could take place and that every emer­gency pos­es unique prob­lems, it may take longer to resume oper­a­tions dur­ing any par­tic­u­lar dis­rup­tion. Our actu­al recov­ery time under these sce­nar­ios will depend on the nature and extent of the busi­ness dis­rup­tion and could result in length­i­er delays.

Contacting Us

If after a sig­nif­i­cant busi­ness dis­rup­tion you can­not con­tact us as you usu­al­ly do at 888.446.3773, you should go to our web­site at www​.hine​spri​vatewealth​.com/​r​e​s​o​urces.