HydePark
Nuveen Investments
HYDEPARK GROUP, LLC DISASTER RECOVERY

Policy

As part of its fiduciary duty to its clients and as a matter of best business practices, HydePark Group, LLC has adopted policies and procedures for disaster recovery and for continuing its business in the event of a disaster. These policies are designed to allow HydePark to resume providing service to its clients in as short a period of time as possible. These policies are, to the extent practicable, designed to address those specific types of disasters that HydePark might reasonably face given its business and location

Background

Since the terrorist activities of 9/11/2001, all advisory firms need to establish written disaster recovery and business continuity plans for the firm’s business. This will allow advisors to meet their responsibilities to clients as a fiduciary in managing client assets, among other things. It also allows a firm to meet its regulatory requirements in the event of any kind of disaster, such as bombing, fire, flood, earthquake, power failure or any other events that may disable the firm or prevent access to our office(s).

Responsibility

The Chief Investment Officer is responsible for oversight of the Plan. The Chief Information Officer is responsible for maintaining and implementing Hydepark’s Disaster Recover and Business Continuity Plan.

Procedure

HydePark has adopted various procedures to implement the firm’s policy and reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

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The following individuals have the primary responsibility for implementation and monitoring of our Disaster Recovery Policy:

The Chief Information Officer is responsible for documenting computer back-up procedures, i.e., frequency, procedure, person(s) responsible, etc.

The Chief Information Officer is responsible for designated back-up storage locations(s) and persons responsible to maintain back-up data in separate locations.

The Office Manager/Database Manager is responsible for identifying and listing key or mission critical people in the event of an emergency or disaster, obtaining their names, addresses, e-mail, fax, cell phone and other information and distributing this information to all personnel.

The Chief Information Officer is responsible for designating and arranging for “hot,” “warm,” or home site recovery location(s) for mission critical persons to meet to continue business, and for obtaining or arranging for adequate systems equipment for these locations.

The Client Support Manager is responsible for establishing back-up telephone communication system for clients, personnel and others to contact the firm and for the firm to contact clients.

The Chief Information Officer is responsible for determining and assessing back-up systems for key vendors and mission critical service providers.

The Chief Information Officer is responsible for conducting periodic and actual testing and training for mission critical and all personnel.

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HydePark’s disaster recovery systems will be tested periodically.

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HydePark’s disaster recovery plan will be reviewed periodically, and on at least an annual basis, by the Disaster Recovery Team.