Gleacher Partners LLC and affiliates (“Gleacher”) has designed a business continuity plan (“BCP”) to evaluate and manage a potential significant disruption on its business operations so that we may continue critical business functions in the event of an emergency. Critical functions include the storage and preservation of data, alternate communications with clients and regulators, and alternate communications with employees.

Applicable regulations require Gleacher to provide this disclosure statement to its clients, which provides a summary of the BCP’s key elements.  Due to the proprietary nature of some information, full details of the plan are not distributed to the public.

The BCP is designed after reviewing the potential risks, and ability to recover from key losses.  The BCP is reviewed and updated at least annually. 

The BCP includes discussion of potential disruptions including loss of one or more offices, loss of telephone services, loss of power, loss of key personnel, and loss of key service providers.  Gleacher utilizes its various offices to replicate critical data and technology.  In the event of a loss described above, Gleacher expects that clients should not experience more than a 24 hour disruption. 

The nature of the BCP is to lessen the impact of emergencies.  Because events that bring about disruptions are unpredictable, Gleacher may have no ability to restore full service in the event of failures in certain infrastructure such as utilities, communication networks, transportation, and third party providers that Gleacher may require.  There can therefore be no guarantee that Gleacher will be recovered from any serious emergency.