Business Continuity Plan

This document addresses the Business Continuity Plan of Seven Points Capital, LLC. (“Seven Points Capital”) The purpose of this plan is to ensure Seven Points Capital’s uninterrupted operations and/or restoration of its business and operations in the most efficient and timely manner in case of an internal or external SBD (Significant Business Disruption). Seven Points Capital clears its securities business through Cowen Execution Services.

Cowen stores our records in a geographically separate area from where they and the Firm conduct its business. While every emergency situation poses unique problems based upon external factors, such as time of day and the severity of the disruption, we have been advised by Cowen that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within a reasonable period of time.

Varying disruptions

A disruption can be caused by any accidental, natural or man-made malicious event that threatens or does disrupt normal operations or services for sufficient time to affect significantly, or cause failure to, an organization.

Business disruptions, by their nature, can vary greatly in size, scope and duration. In a disruption to only our firm or a building housing our firm, we will recover our backed-up data and transfer our operations to a local site when needed and expect to recover and resume business within one business day. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area and recover and resume business within three business days. In either situation, we plan to continue in business and notify you through our website.

Our business continuity plan

Our goal is to quickly recover and resume business operations after a SBD and respond by safeguarding our employee’s lives and the Firm’s property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the Firm’s books and records, and to continue to transact business.

Our business continuity plan addresses: data back-up and recovery; all mission critical systems; financial and operational assessments; alternative communications with, employees, regulators; critical suppliers, contractors, banks and counter-party impact; and regulatory reporting.