Atalanta Sosnoff Capital, LLC, together with each of its subsidiaries and affiliates, (“Atalanta Sosnoff” or the “Firm”) are committed to safeguarding the interests of our clients and customers in the event of an emergency or significant business disruption. This Business Continuity Plan Disclosure (the “BCP”) summarizes the Firms’ effort to mitigate risks inherent with unforeseen business interruptions. The Firm’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our clients and customers in the event of an emergency or significant business disruption.

Overview

Atalanta Sosnoff maintains one primary New York City facility for its trading, sales, operations and information technology systems. The data is backed up and stored at an off-site facility daily. The Firm utilizes Disaster Recovery-as-a-Service (DRAAS) to provide disaster recovery solutions and business continuity.

Communication with Our Employees in the Event of a Disruption

The safety and well-being of our employees is a primary concern. In the event of an emergency or significant business disruption, the Firm will communicate with its employees via a combination of general broadcast and direct targeted outreach. General information such as office closures and operating hours will be posted on the Firm’s internal and external websites and similar recorded updates will play around-the-clock on the Atalanta Sosnoff emergency telephone hotline. Senior managers will be contacted directly via telephone and/or email.

Redundancy of Mission Critical Information Technology Systems

Atalanta Sosnoff has an information technology processing and backup site that, collectively, provide the redundancy required to protect the Firm’s books and records, balance sheet and capital, and provide business continuity and client protection. Atalanta Sosnoff is utilizing Disaster Recovery-as-a-Service (DRAAS) from an established cloud provider for our DR and business continuity. The software provides continuous replication for our critical information/servers. Recovery times for mission critical systems range between real time recovery and 1 to 2 hours.

Back-Up Trading, Sales and Operations Site

Atalanta Sosnoff does not need to maintain a backup trading floor and operations center because the Firm can effectively and timely conduct client transactions remotely. In the event that we are unable to enter our building, we will be able to perform necessary procedures remotely. Atalanta Sosnoff utilizes a trading application which is hosted by the application vendor that meets all the compliance requirements. The application vendor also utilizes a DR site which is annually tested by the Atalanta Sosnoff traders concurrently when the vendor performs their DR Failover tests. To ensure additional data protection, Atalanta Sosnoff stores digitally encrypted backup copies of its data at an offsite facility. The functionality of the DRAAS is routinely monitored and tested by our information technology team.

Protection of Primary Facilities

Protecting the infrastructure of our primary facility is a high priority because it allows the Firm to continue operations in the event of a disaster situation, by permitting our employees to have access to and use of our New York City facility during that event. If the Firm is not afforded access to the building for a prolonged period of time we would utilize the DRAAS and work remotely via internet, telephone and facsimile. The Firm’s DRAAS center is located in a low-risk area and it has sufficient backup power to operate for an extended period of time.

Disclaimer
The Firm’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our clients and customers in the event of an emergency or significant business disruption; however it is not infallible. The Plan is designed to work in many different emergency situations; but these events are, by their nature, unpredictable and it is impossible to anticipate every scenario that could cause a business disruption. Furthermore, although we are confident in our own preparedness, Atalanta Sosnoff has no control over the various entities that we must rely upon in the event of an emergency. Our business continuity plans are tested periodically to ensure readiness; yet such tests may not be able to replicate the actual conditions we experience in a real emergency. This BCP is subject to change without notice. In the event that this BCP is modified, the updated document will be promptly posted on the Firms’ internet website at www.atalantasosnoff.com. Alternatively, customers may obtain a copy of our BCP upon request. The information contained in this disclosure is provided by Atalanta Sosnoff for informational purposes only. Nothing contained herein shall be construed to amend, supplement or otherwise modify any of the terms and conditions set forth in any customer agreement between you and Atalanta Sosnoff.