Business Continuity Policy
Nextury Asset Management Business Continuity Policy: key principles, processes and measures designed to ensure operational stability.
Chapter I
Purpose of the Document
The purpose of the Business Continuity Policy is to ensure that, in the event of a disruption to the operation of the systems or procedures used by the management company UAB “Nextury Asset Management”, essential data is preserved, the performance of the Company’s functions is not interrupted,and investment activities continue to be carried out. If this is not possible, the aim is to restore data and the performance of functions within the shortest possible time and to resume investment activities.
The measures set out in this Policy shall apply in the event of extraordinary circumstances that may cause the Company to lose equipment, data or other resources necessary to ensure the performance of its functions and the provision of its services, as well as in the event of unforeseen circumstances that may adversely affect the interests of the collective investment undertakings managed by the Company or their Investors.
The Company’s operations shall be deemed to have been restored if the Company is able to successfully manage the assets of the CIU.
Chapter III
Organisational Provisions
The Head of the Company shall be responsible for the implementation of this Policy and for the restoration of the Company’s operations in the event of extraordinary circumstances.
The Head of the Company may delegate part of the functions related to the restoration of the Company’s operations to Employees; however, in all cases, the Head of the Company remains responsible for the restoration of the Company’s operations.
In the event of extraordinary circumstances where the Head of the Company is unable to participate in ensuring the restoration of the Company’s operations or is unable to do so alone, the persons temporarily acting as Director or substituting the Director shall participate in the operational recovery actions. In their absence, the Chairman of the Company’s Board shall participate.
In the event of extraordinary circumstances and disruption of the Company’s operations, the Head of the Company shall establish a business continuity management group. The functions of this group shall include:
- communication with specialists hired for the restoration of operations;
- communication with law enforcement or other authorities;
- communication with Investors or groups of Investors;
- communication with Employees and their coordination;
- allocation and control of financial and other resources;
- physical security of assets and information, where necessary;
- restoration, maintenance and coordination of information systems;
- organisation of information system data recovery;
- organisation of the restoration of proper functioning of applicable software applications.
Chapter IV
Main Risks Arising in the Company’s Activities and Their Management
Chapter V
Circumstances Posing a Threat to the Company’s Operations and Preventive Measures
- Employees must share information about ongoing tasks during weekly meetings.
- An Employee must briefly describe and hand over ongoing tasks to a colleague.
- Financial models and asset management strategies must be documented and continuously updated.
- Employees must periodically save the data they use in an external data storage system.
- Delays in payments for services provided by the Company must not exceed 30 days.
- The Company must always maintain a cash reserve sufficient to cover 3 months of current liabilities.
- The funds of the CIUs managed by the Company are separated from the Company’s own funds.
- Financial reports shall be submitted to shareholders at least once per quarter.
- Important electronic documents shall be saved on the Microsoft Data server and in online data storage at least once per month.
- CIU accounting documents shall be saved on the Microsoft Data server at least once per week.
- Antivirus software and a firewall shall be installed on all computers.
- Access to personal computers shall be password-protected.
- If computers stop functioning, smartphones with internet access shall be used as an alternative.
- In the event of computer failure, Employees’ personal computers may be used temporarily.
- The Company must always have at least several printed copies of the main document templates available.
- The Company has an account opened with one of the largest commercial banks operating in Lithuania.
- The Company continuously monitors and assesses the financial condition and capital adequacy indicators of banks.
- Laptops shall be used, with battery life ranging from 5 to 9 hours without an additional power source.
- In the event of longer disruptions, laptops shall be moved to an alternative workplace.
- Internet access may be obtained by using wireless modems available on smartphones.
Chapter VII
Elimination of Extraordinary Circumstances
Taking into account the interests of Investors, in the event of extraordinary circumstances, the Company’s operations shall be restored according to the priority of the activities carried out by the Company in the following order: