General Outline of the Plan
First Eagle Investment Management, LLC and FEF Distributors (collectively, “First Eagle”) is dedicated to the continuity of its critical business processes in support of its business. In the event of an incident resulting in a significant disruption of First Eagle’s business, First Eagle has implemented a business continuity plan (BCP) designed to permit the firm to continue its business operations with minimum disruption. (This plan is maintained by First Eagle Investment Management, LLC, the parent company of FEF Distributors, LLC, and the activities of FEF Distributors are covered in the BCP.)
The BCP identifies the key components for recovery of business operations and deals with emergency response activities, emergency recovery, and rehabilitation of damaged facilities and materials. In that spirit, we are committed to ensuring that the continuation of service shareholders of the First Eagle Funds even when events occur which could potentially disrupt our business. (FEF Distributors does not hold customer funds or securities and does not perform clearing functions.)
Elements of the BCP include: offsite mirroring of systems that have been designated mission-critical; and two dedicated facilities around the New York metropolitan area the region that can function as alternative working locations for our staff. For those functions that are outsourced to a third party, conduct periodic due diligence on the business-continuity capabilities of our key service providers.
Other Elements of the BCP
Plan procedures include, but are not limited to, the following:
- Identification of time sensitive functions, critical functions and services to sustain operation;
- Guidelines for continuing, restarting or resuming operations in the event of a business interruption;
- Interactions with clients, vendors and/or regulators;
- Interactions with other business operations within FEIM;
- Systems recovery priorities;
- Identification and documentation of internal and external dependencies;
- Recovery tasks by function; and
- Emergency notification protocols and procedures.
It is impossible to forecast every potential problem that may occur, but we believe we have taken reasonable precautions to enable us to respond to events of varying scope. In addition, the plan includes several important degrees of flexibility that could be used in case of unexpected problem conditions.
If you want more information about our BCP, you can contact us at (212)698-3300.