Business continuity is a priority for Salient Partners, L.P. and its subsidiaries. Our goal is to ensure our continued ability to serve our clients and to protect their assets and the people and assets of our firm. Our Business Continuity Program has been developed to provide reasonable assurance of business continuity in the event there are disruptions of normal operations.
Salient Partners, L.P. (“Firm”) is responsible for maintaining the computer systems of all Firm entities and will issue clearly stated language setting forth our business continuity plan (“BCP”) to all personnel.
In general, our Firm will respond to a Significant Business Disruption (“SBD”), as further defined below in our BCP, by safeguarding employees’ lives and Firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the Firm’s books and records, and allowing our Customers to continue to transact business without significant interruption.
(i) Internal SBD (“ISBD”):
In the event that our Firm experiences an ISBD, including, but not limited to, a fire in our building, loss of electricity to our network, widespread employee absenteeism caused by bacterial agent such as influenza, our Firm will have contingency plans in place to handle the ISBD.
(ii) External SBD (“ESBD”):
In the event our Firm experiences an External SBD such as a terrorist attack, weather event, such as a hurricane or a wide scale regional disruption, our Firm will rely more heavily on other organizations and systems, especially on the capabilities of our outside vendors that are listed in this BCP (the “Vendors”). Executive Vice President and General Counsel, Jonathan DePriest, will annually obtain and review copies of our Vendors’ business continuity plans (the “Outside Plans”).
Jeremy Radcliffe and Kristen Bayazitoglu shall be responsible for approving the BCP in conjunction with other members of Senior Management. A copy of the Firm’s BCP with their approval of the BCP shall be maintained on file. Jeremy Radcliffe and Kristen Bayazitoglu shall conduct annual review and testing of the BCP.
Salient Partners is located at 4265 San Felipe, 8th Floor, Houston, TX 77027 and 345 California Street, Suite 1600, San Francisco, CA 94104.
In the event of an SBD, where access to our offices at 4265 San Felipe, 8th Floor, Houston, TX is limited or unavailable, firm employees will be able to access systems and applications remotely from home or hotels via dial-in or high-speed internet connections to ensure uninterrupted client service and processing of client transactions.
The Back-up Site can be activated when a SBD is declared. The Back-up Site may be activated as the coordination center for emergency operations if deemed appropriate by executive management. Set-up and operation of the Back-up Site is the responsibility of the Business Continuity Coordinator and operations staff. If the Back-up Site is activated, it will become the central communication and coordination point for the Firm until emergency operations are terminated.
In the event that Senior Management determines the Firm’s offices are unavailable for a prolonged period of time a management team will immediately begin efforts to procure temporary office space and will meet with local commercial real estate brokers who deal in temporary relocation as soon as possible.
Certain affiliated entities of Salient Partners, L.P. are regulated by the SEC and FINRA. Salient Trust Co., LTA is regulated by The Texas Department of Banking. The Firm’s Business Continuity Coordinators will communicate with our regulators using the telephone, e-mail, fax, U.S. mail, and in person. In the event of an SBD, they will assess which means of communication are still available to the Firm and use the means closest in speed and form (written or oral) to communicate with the appropriate regulatory authority.
Our Firm’s Senior Management, will quickly establish alternative arrangements if a service provider can no longer provide the needed goods or services when we need them because of a SBD to them or our Firm.
The following individuals are the business continuity coordinators and emergency contact persons for Salient Partners and Salient Trust Co., LTA:
Chief Operating Officer, Asset Management
Chief Operating Officer, Salient Private Client
The Firm utilizes a Tier3 datacenter for housing all Salient servers and storage. We review their controls to determine that the Firm’s servers and storage are protected from unauthorized access, safe from physical damage, malicious information systems attack and natural and man-made disasters.
The Firm performs daily backups for all data and utilizes a cloud storage service for redundancy. All data copied to the cloud service is encrypted before leaving the Firm’s network.
To create redundancy and service continuity, the Firm diversifies across two different Internet providers with different connection characteristics. The connections are configured in failover configuration.
The Firm’s operations personnel maintain and test contingency procedures to ensure that recovery can be completed with little to no disruption of service.