Business Continuity Plan Summary
Winslow Capital Management, LLC (“Winslow Capital”) maintains comprehensive procedures reflecting the firm’s commitment to plan for and to be prepared for significant business disruptions. Winslow Capital’s Business Continuity Plan (“BCP”) addresses significant disruptions to the firm’s business operations conducted at its Minneapolis location, where all of Winslow Capital’s mission critical processes are conducted.
The BCP has been designed to cover all critical business processes that are essential for Winslow Capital to continue conducting business during a temporary business interruption. The most important aspects of Winslow Capital’s investment advisory business are addressed in the BCP, including continued management and trading of client portfolios, ongoing operational and legal/compliance support, protecting books and records, and maintaining communication with employees, clients, service providers, and regulators.
The Firm’s primary business recovery strategy is to resume its critical business processes and/or provide access to key critical systems/applications from Winslow Capital’s BCP office location in Mendota Heights or via remote locations, with minimal interruption, as soon as possible, depending on the nature of the disruption. As such, the steps taken, pursuant to the BCP, are designed to ensure that critical information is captured on a daily basis in a manner that can be accessed by employees from the BCP office or remotely. Additionally, Winslow Capital has contacted its critical business partners, such as vendors providing essential systems/applications and/or other services and has evaluated their capabilities to provide services in the event of various disruption scenarios. Winslow Capital has additionally considered alternative providers that could be utilized if necessary. Furthermore, Winslow Capital’s information technology operations form a critical part of the firm’s business and each of its critical business processes. The BCP includes a detailed information technology component which identifies the functions, operations, and resources necessary to support the restoration and resumption of all critical business processes performed at Winslow Capital’s Minneapolis location and to facilitate access to critical systems/applications housed at third-party service providers via an array of communications connectivity.
In conclusion, the BCP addresses the steps Winslow Capital will take to address a temporary business disruption in a systematic and organized fashion. However, since the effects of a disaster are difficult to predict and the disruption of systems and processes on an industry-wide basis will pose great challenges for any business continuity plan, there can be no assurance that any plan can address such unforeseen contingencies.
Effective: September 2012