BCP Summary (Last update July 2005)


Viscogliosi has developed a Business Continuity Plan (‘BCP’) as part of our ongoing contingency planning effort.  In order to keep our clients informed, we are providing information necessary to you about our plan and how it addresses the possibility of a future significant disruption to our business.  Depending on the scope and severity of a possible disruption (which cannot be predicted in advance) Viscogliosi’s plan remains flexible.  Our plan is subject to periodic and ongoing revision; any modifications or updates to the BCP summary will be promptly posted on our website at www.vcoinc.com.

Plan Overview
Business continuity planning (BCP), by its very nature, is designed to enable our firm to continue to operate and provide services to our clients under a variety of circumstances in which one or more events may make our office unavailable due to a local, regional or national emergency, or due to the failure of one or more systems that Viscogliosi relies upon to provide the services that we routinely provide to our clients, our employees and our various business partners and counterparties.  The BCP plan covers all business areas of the firm and provides contingency plans for technology, staffing, equipment, and communication to employees, clients and counter-parties.  While we have described certain types of business continuity issues, we must advise you that such occurrences, by their very nature are unpredictable, and can occur in a manner that is outside of our planning guidelines and could render our estimates of timing for recovery inaccurate.  Under all circumstances it is our intention to remain in business and to provide ongoing service, as if no disruption had occurred.

Viscogliosi maintains its headquarters and principal operating location at 505 Park Avenue, 14
th Floor, New York, NY 10022.  In order to provide continuity for this facility, the company maintains a data backup facility for information technology, redundant file storage and data processing.

Viscogliosi relies on public utilities for power and phone services and various industry vendors for services that are significant and important to our business for the communication of information regarding client holdings, for the pricing and valuing of client holdings, and for permitting our company’s employees to communicate on an efficient basis.  All of these service providers have assured our company that they have made plans for providing continued service in the case of an unexpected event that might disrupt their services. Our planning described in various scenarios set forth below depends to some degree on the accuracy of these assurances.

In any of the following scenarios, we recommend that clients attempt to contact their normal business contact or visit www.vcoinc.com for further information.

Scenarios

The following scenarios outline, at a high level, our plans for business continuity:·
       
Firm-only event:  In the event of a disaster that affects only Viscogliosi, the firm intends to utilize as necessary, its data backup facility.  Our general response to this event is to rely on our data backup facility to quickly and efficiently restore services to our firm and to our clients.  We believe that our BCP will enable us to do so.  Our plan provides for back-up of our key systems upon a same or next day basis after the first occurrence of a business disruption.  Certain non-core functions are assumed to become available as soon as possible thereafter.·
       
Office location or NYC event:  Business disruptions occurring to our office building, its general vicinity or all of NYC may impact the ability of many of our key employees to reach the company’s office.  In cases such as these we will rely on our data backup facility, our website (www.vcoinc.com), the Internet, email and our employees’ personal communication devices to insure effective communication with clients, employees business partners and other counterparties.  We believe that our plan and the means of communications made available to employees should permit the company to maintain the recovery times described above.·
       
Regional or national event:  Events occurring in regions other than NYC should not impact the company’s ability to provide service to clients from our office, unless such events effect local services such as utilities, phone service, cellular phone service, Internet, etc.  The data backup facility maintained by the company operates on a separate electric utility grid and has separate communications providers, but the company cannot provide assurance that an event that is regional in nature could not cascade to other geographic areas, and significantly impact the company’s plan for recovery.  Under most circumstances the company believes that it could provide reconstituted key services to clients upon a same or next day basis.  However, it is likely that in a New York regional event that industry utilities, other securities firms and required third party services might be unavailable and that recovery times could be impacted.

Clients should call their normal business contact for information or visit our website at www.vcoinc.com for more information.