Business Continuity Plan Summary

T. S. Phillips Investments, Inc., (“T S Phillips” or “Firm”), is committed to safeguarding the interests of our customers and employees in the event of an emergency of significant Business Disruption (“SBD”). T S Phillips has developed a Business Continuity Plan (“BCP”) on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. The firm’s policy is to safeguard our employees lives and firm property, make financial and operational assessments, meet our obligations and responsibilities to our customers, continue to conduct business under varying degrees of a SBD, and if unable to continue in business, assure customers of prompt access to their funds and securities.


The actual impact of a disruption of business is dependent upon the event and the severity of that event. We have identified our critical systems. The systems we deem critical are telecommunications, computer systems, our clearing firm, books and records, and location. Our mission in a business disruption situation is to provide for the safety of our employees, to stay in contact with our customers and resume normal business activities in as little time and disruption as possible. Our firm is dependent, as is everyone, on electrical power and telephone lines. In certain instances we can overcome these obstacles.


Our client and market information is available to us via the Internet system. Our clearing firm is First Clearing LLC (FCLLC). The services they provide to our firm and for client access is Internet based. In the event customers are unable to reach our firm, they may contact the clearing firm directly. FCLLC backs up our important client records in geographically separate areas. FCLLC has a pre-established contingency and disaster recovery plan. Components of their plans are tested periodically to ensure effectiveness. Our clearing firm has successfully supported critical business disruption activities during hurricanes, tornados, blizzards and other natural and man-made disasters. These disruptions have clearly tested their readiness across virtually all dimensions; safety, systems and telecommunications, physical space, policy, processes, and procedures.


Our BCP covers data back-up and recovery; all critical systems; financial and operational assessments; alternative communications with customers, employees, independents, clearing firm, and regulators; alternate physical location of employees; critical suppliers of services and products, banks and counter-parties; regulatory reporting; and assuring customers prompt access to their funds and securities if we are unable to continue our business.


T S Phillips has planned for alternate means of communications with customers, the clearing firm, and employees if a local telecommunications interruption should occur. Arrangements will be made with line and circuit providers to re-route calls to various locations where customers can contact us to transact business.


SBD can vary in scope, such as to only our office, a single building which houses our firm, the business district where our firm is located, the city where our office is located, or an entire region and to the severity of the disruption. Upon determination of the severity, our plan includes moving employees, equipment and operations to another site, which could be another office or a remote site. Recover time would be 24-48 hours. If a large area was affected then setting up at another site might require 48+ hours. In any situation, we plan to continue in business, giving customers alternate means to contact us by telephone, e-mail, Internet, public communications, etc. We will use our web site www.phillipsinvestments.com to cover as wide an area as possible with updated information.


All emergency contacts and disaster coordinating managers have a copy of the firm’s BCP and have been advised of their responsibilities in the event of a SBD. Alternate work locations would be assigned, data restored, other records restored, communication reestablished with employees, customers and clearing firm.


The Business Continuity Plan is subject to modification at any time. Updates to the plan summary will be promptly posted to our website www.phillipsinvestments.com