New York Stock Exchange, Inc. Rule 446 and National Association of Securities Dealers, Inc. Rule 3510 require member firms to create and maintain a business continuity plan (“BCP”).  In accordance with these rules, Hapoalim has developed a Business Continuity Plan 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. With that in mind, we are providing you with this information on our business continuity plan.

 
Contacting Us – If after a significant business disruption you cannot contact us as you usually do at (212) 898-6200 your call will be forwarded to our disaster recovery site whose main number is (201) 729-2800, or you can go to our website at www.hapoalimsec.com.   If you cannot access us through either of those means, you should contact our clearing firm for retail customers, Pershing LLC at (201) 413-3635 or go to their website at www.pershing.com  for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash and security transfer transactions for your customers.  If you cannot access the instructions from the web site or previously noted telephone number, Pershing may be contacted at (213) 624-6100 extension 500 as an alternate telephone number for recorded instructions. Please not that the telephone numbers listed above are alternate numbers and are to be used only if you fail to reach Hapoalim Securities.

Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. 

Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Hapoalim maintains a disaster recovery facility in a geographical location outside of New York, New York.  The remote location is capable of supporting most of the Firm’s business operations including sales, trading, operations, accounting and information technology.  In the event of a disaster in which the Firm’s management decides that business cannot resume in its current location, key personnel may be relocated to the Firm’s back-up site.  Workstations, phones, printers, fax machines and all other business tools are maintained at the off-site location.  The Firm’s disaster recovery plan is tested annually and key personnel are trained on the business resumption procedures.  

Our clearing firms, Pershing LLC and JP Morgan back up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firms that their objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within 4 hours. Your orders and requests for funds and securities could be delayed during this period.