Business Continuity

Capstone Asset Management Company has developed a Business Continuity and Contingency Program (BCCP) that 1) safeguards the health of Capstone’s employees; 2) protects and preserves Capstone’s tangible and intangible property, books and records; and 3) assures Capstone’s clients that in the event of a significant business disruption, the firm will continue to operate and 4) a succession grid to ensure management continuity in the event of unanticipated unavailability of management personnel. Capstone has procedures and systems in place to restore operations in a timely manner. Because the timing and impact of events causing business disruptions are unpredictable, Capstone’s senior management will need to be flexible in responding to actual events as they occur.

If the primary Capstone contact phone number (713-260-9000) is inoperable due to a significant business interruption, Capstone may be alternately contacted by calling Scott Frakes at 314.922.3331.

The BCCP provides a framework for notifying employees in the event of a significant business disruption and instructing them as to when and where to report for business. Pursuant to the BCCP, Capstone has established a business resumption team to assess the complications of the business disruption and address the logistical and operational problems and contingencies. Each resumption team member has the authority to initiate the BCCP.

The BCCP is designed to permit Capstone to resume operations as quickly as possible given the scope and severity of the business disruption. The BCCP addresses management backup, data backup and recovery; mission-critical systems; financial and operational assessments; alternative communications with customers, employees and regulators; alternative physical location for employees; the impact of a significant business interruption to Capstone’s critical suppliers, contractors, banks or other service providers; regulatory reporting and assuring continuity of service to Capstone’s customers.

Significant business disruptions can vary in their scope, such as affecting only Capstone, Capstone’s office facilities, the business district in which Capstone is located, the city or the entire region. Within each of those areas, the extent of the disruption event can also vary from minimal to severe. For a business disruption that affects only Capstone or Capstone’s office facilities, operations will be transferred to a local site as needed and operations are expected to be resumed within two business days. For business disruptions affecting Capstone’s business district, city or region, Capstone will transfer operations to a site outside of the affected area and expects to resume operations within five business days. Capstone’s management expects to continue operations in any event and the BCCP includes procedures to notify Capstone’s customers and provide information through our emergency contacts (Mike Kern at mkern@capstonefinancial.com or Scott Frakes at sfrakes@capstonefinancial.com).

The BCCP is subject to modification and a written copy of any updated summaries may be requested by contacting Capstone at 713-260-9000.