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Business Continuity Plan (BCP) for Agallas Equities LLC

Last Updated: January 1, 2025

Introduction

Agallas Equities LLC is committed to ensuring operational resilience and safeguarding client 
interests during unforeseen disruptions. This Business Continuity Plan (BCP) outlines strategies to maintain critical functions, mitigate risks, and recover swiftly from incidents such as cyberattacks, natural disasters, or system failures.

Purpose and Scope

Purpose:

Ensure continuity of critical operations, protect client assets, and minimize downtime during disruptions.

Scope:

Applies to all business functions, employees, contractors, vendors, and stakeholders. Covers disruptions ranging from IT outages to pandemics.

Governance and Oversight

BCP Committee:

Ensure continuity of critical operations, protect client assets, and minimize downtime during disruptions.

Scope:

Applies to all business functions, employees, contractors, vendors, and stakeholders. Covers disruptions ranging from IT outages to pandemics.

Data Sharing and Disclosure

We do not sell, trade, or otherwise transfer your personal information to outside parties without your consent, except in the following circumstances:

Service Providers:
  • Chair: Managing Partner
  • Members: Heads of IT, Risk Management, Compliance, Operations, and HR.
Oversight:

Board of Directors reviews the plan annually. Senior Management approves updates.

Risk Assessment and Business Impact Analysis (BIA)

Key Risks: Cyberattacks, market disruptions, power outages, pandemics, and critical vendor failures.

Business Continuity Strategies

  • Data Backup: Daily encrypted backups stored in geographically diverse locations (AWS, Azure).
  • Alternate Worksites: Remote access via secure VPN.
  • Vendor Management: Key vendors (e.g., clearinghouses) must provide BCP attestations annually.
  • IT Resilience: Cloud-based systems, and real-time data replication.

Incident Response and Crisis Management

Activation Criteria:
  • Level 1 (Minor): Isolated system outage – resolved internally.
  • Level 2 (Major): Multi-day disruption – activate remote work protocols.
  • Level 3 (Severe): Region-wide disaster – relocate to alternate site.
Response Steps:
  • Assessment: BCP Committee evaluates impact.
  • Containment: IT isolates breaches; Operations reroutes workflows.
  • Communication: Notify investors, regulators, and employees within 1 hour.
  • Recovery: Restore systems per RTO/RPO targets.
  • Post-Incident Review: Document lessons learned; update BCP.

Communication Plan

Internal:
  • Employees: Alerts via SMS, email, and Microsoft Teams.
  • Incident Response Team: Daily briefings via Zoom.
External:
  • Investors: Updates via website banner, email, and client portal.
  • Regulators: Notifications within 4 hours (per FINRA/SEC rules).
  • Vendors/Partners: Direct contact through account managers.

Testing and Exercises

  • Annual Tests: Simulated cyberattacks, trading platform failovers.
  • Quarterly Tabletop Exercises: Scenario-based drills (e.g., pandemic response).
  • Post-Test Actions: Address gaps within 30 days.

Training and Awareness

  • Employee Training: Mandatory BCP sessions during onboarding and bi-annually.
  • Incident Response Team: Advanced training on crisis decision-making.
  • Awareness Campaigns: Monthly emails highlighting BCP updates.

Plan Maintenance and Review

  • Quarterly Reviews: Update for new risks (e.g., regulatory changes, new tech).
  • Trigger-Based Updates: Post-incident or after significant operational changes.
  • Board Review: Annual presentation on BCP effectiveness.

Conclusion

Agallas Equities LLC prioritizes resilience through proactive planning, robust infrastructure, and continuous improvement. This BCP ensures readiness to protect client assets and uphold market integrity.

Contact Information

Role Name Email
BCP Committee Chair Manuel Tavarez mtavarez@agaeq.com
Disclaimer
This website is neither an offer to sell nor a solicitation of an offer to purchase shares of any security offered by Agallas Equities. Such securities are offered only by means of a prospectus or offering memorandum. This material must be read in conjunction with a prospectus in order to understand fully all of the implications and risks of an investment in the securities offered by Agallas Equities LLC. Neither the Securities and Exchange Commission, the Attorney General of the State of New York nor any other state securities regulator has passed on or endorsed the merits of the securities offered by Agallas Equities LLC. Any representation to the contrary is unlawful.