This is a summary of the Business Recovery Plan (the "Plan") of Tradewinds Global
Investors LLC (hereafter the "Company"). The Plan is designed to address a significant
business disruption affecting the Company's business operations conducted at its
Los Angeles headquarters location and sets forth the Company's objectives of safeguarding
employees, recovering and resuming operations, protecting books and records, and
enabling communications with employees, clients, key service providers, and regulators.
The Plan also covers NWQ Investment Management Company, LLC, which is a registered
investment adviser and subsidiary of Nuveen Investments, Inc. The Company, and NWQ
are headquartered in Los Angeles, and nearly all of the mission critical systems
and processes are also conducted or located in Los Angeles. The Company's parent,
Nuveen Investments, Inc., and its affiliates (collectively, "Nuveen") have adopted
similar plans to address significant business interruptions affecting operations
at their offices in Chicago, IL, Radnor, PA, Santa Barbara, CA, and San Francisco,
CA.
Whether you are an institutional client, managed account holder, a shareholder of
a fund, or a business partner, please be advised that the Company's Plan reflects
a commitment of Tradewinds and its employees to plan for and be prepared for a significant
business disruption. Should you have questions regarding a Tradewinds account, please
contact your financial advisor directly. Institutional Account holders should contact
Patrick Schloss, Director of Institutional Client Service, directly at 310-712-4043.
The Plan addresses both disruptions that may be caused by an internal incident (such
as a fire in the Company's headquarters building at 2049 Century Park East in Los
Angeles) or by a regional or market-related disruption that applies to many companies.
The Plan covers the Company's critical business processes and related employees
that are essential for the Company to continue to conduct business for an interim
or temporary period during a business interruption. All of the most important aspects
of the Company's advisory business, including continued investment management and
trading of institutional and separately managed account portfolios, mutual funds,
and other portfolios, and rapid communication to key business partners and clients,
is addressed in these processes. The Company's primary business recovery strategy
is to resume its critical business processes and/or provide access to key critical
systems/applications from remote locations, with minimal interruption as soon as
possible, depending on the nature or severity of the disruption.
The steps being taken pursuant to the Plan are designed to ensure that critical
information is captured on a daily basis in a manner that can be accessed by employees
from remote or alternate locations. The Company has contacted its critical business
constituents, such as vendors providing critical systems/applications and/or other
services and evaluated their capabilities to provide services in light of various
disruption scenarios, as well as alternative providers. The Plan also provides that
the Company will maintain contacts with regulators during any business interruption.
The Company's Information Technology operations form a critical part of the Company's
business and its mission critical systems. The Plan includes details on the Information
Technology Department's protocol that identifies the functions, operations and resources
necessary to support the restoration and resumption of critical business processes
performed by the Company's (including NWQ's) Los Angeles location or facilitate
access to critical systems/applications housed at third-party service providers
via an array of communications connectivity. An alternate facility outside of California
also serves as a back-up facility supporting resumption of critical in-house systems/applications.
This summary plan is subject to modification from time to time as the Company reviews
the Plan and its business operations.
In conclusion, the Company's Plan addresses the steps the Company (including NWQ)
will take to address a temporary business disruption in a systematic and organized
fashion. Of course, the effects of a disaster are difficult to predict and the disruption
of systems and processes on an industry wide basis will pose great challenges for
any business continuity plan. There can be no assurance that any plan can address
such unforeseen contingencies.