ZAO DCC (hereinafter referred to as DCC or the Company) guarantees to its clients provision of high-quality depository and clearing services enabling its clients to achieve their varied strategies.

Business Continuity Management (hereinafter referred to as BCM) is one of priority orientations for DCC management.

Business Continuity strategy at DCC represents fundamental principles, provisions and methodology basics accepted by the Company for the purpose of implementation of the BCM policy.

Business Continuity Planning (BCP) at ZAO DCC is a package of measures (management, organizational, information measures etc.) aimed to develop and implement the policy directed at prevention of situations fraught with business process interruptions or suspension of the Company's activity. Furthermore, a still greater emphasis is put on development of the system of managerial solutions that makes it possible to minimize negative consequences of contingency events.

Development of programs of Business Continuity Planning at DCC is carried out in line with international standards and market practices adjusted so that to accord with the Company's peculiarities and needs.

BCP covers all organizational elements of the Company's structure.

Issues of information security, personnel policy and project management have been given consideration in the process of planning.

Business Continuity Management at DCC primarily focuses оn:

    - Development of Business Continuity Strategy;
    - Business Impact Analysis;
    - Development, implementation and testing of Business Continuity Plan;
    - Business Continuity awareness and staff training;
    - Disaster Recovery Planning.

The Contingency Plan, which shall enable prompt management, co-ordination of operations and minimization of negative consequences of contingency situations, is being developed within the framework of BCP. The contingency plan lays down the time schedule for each member in case of a contingency event.

Methodology of Business Continuity Management at DCC

Business Continuity Planning at DCC is based on development of the following areas:

Business Impact Analysis: The analysis, classification and prioritization of business objectives and critical operations which are essential for business recovery. Estimation of the allowable downtime for each crucial business process.
Risk Assessment and Risk Management: Evaluation of impact on critical business processes and identification of procedures that should be put in place so that to minimize negative consequences of such an impact.
Optimization: Optimization of the Company's tangible and intangible resources for their rational use to ensure business continuity.
Developing a Business Continuity Plan: Identification, description and documentation of activities that shall be taken in case of a contingency event in order to resume business-processes. The Crisis Committee: identification of functions and area of responsibility of each member of the Committee, a mechanism to initialize the Committee's activity. Determination of the composition of the Crisis Management Organization and functions of each member of the Crisis Management Organization. Description of the mechanism to initialize activities of the Crisis Management Organization. Plan of action in case of a contingency event.
Testing: Annual testing of the Business Continuity Plan.
Risk monitoring and updates to Business Continuity Plan:
Update of the Business Continuity Plan in accordance with alterations to business processes, auditors' recommendations, test results and new risks elicited in the course of analyses of factors affecting business.

The given strategy of Business Continuity Management guarantees a process-oriented approach and the up-to-date state of the Company's Business Continuity Plan.

Crisis Management

Crisis Management Organization (hereinafter referred to as CMO) is activated in case of a contingency event, i.e. against the backdrop of an accident, natural hazard, disaster, natural or any other calamity which can result in or have resulted in human losses, damage to people's health or the environment, considerable losses.

CMO of DCC consists of President, Security Officer, HR Director, Vice President for Operations, Vice President for IT and Internal Controller. The Company's President is the head of CMO. CMO can be activated by any member.

Crisis Management Organization:

Identifies the character and scale of the event;
Takes action to keep the event under control;
Ensures communication with interested parties;
Initiates the contingency scenario.

In accordance with the BCM methodology the Crisis Committee (hereinafter referred to as CC) is established. CC consists of representatives of the departments whose activity is critical for continuity of business processes. The President activates DCC Crisis Committee as soon as it becomes clear that the problem can no longer be kept under control with the help of normal procedures. The head of the Crisis Committee has the power to change the quantitative composition and manning of CC in her/his own discretion.

The Crisis Committee appoints Third Parties Relations Manager whose duties include provision of agreed information to interested parties. A representative of each company can communicate with Third Parties Relations Manager at DCC and obtain information on the issues related to the business continuity system accepted at the Company.

DCC reserves the right to limit the quantity of information on BCM to be disseminated.

Validation of Business Continuity Plan

DCC Business Continuity Plan is reviewed by the internal audit and by representatives of all departments. It is updated every six months based on the analyses performed.

The Вusiness Сontinuity Рlan and Business Continuity Strategy are ratified by the Company's President.

External auditors regularly perform audit of the existing ВС plan to find out if it complies with international practices in this area.

Members of CC and CMO dispose the up-to-date Business Continuity Plan.

Infrastructural and IT Risks

To stress the importance of infrastructural and IT risks we shall mention the main principles underlying the continuity policy in these spheres.

DCC adheres to flexible back-up policy as well as to double protection methods. Server-clustering technology is employed to ensure operational reliability of major systems that are in charge of depository and clearing services.

Back-up policy at DCC involves a set of rules and procedures that regulate the process of making back-up copies, storage of such copies and their operating procedures. Complete back-up of all SDS databases and financial systems, all user networked resources, mail server data and EDI system is performed on a daily basis. Back-up is effected simultaneously by two drives to two media. Upon completion of the back-up process one media is taken off-site (to a safe-deposit box), the other is stored in a specially equipped premise.

In case DCC is incapable to perform its professional and financial and economic activities and provide services from its head office (the head office is damaged, there is no access to the head office etc.) DCC shall use its back-up center, which is equipped with the number of servers and working stations sufficient to maintain business.

Electrical power is essential to the Company's uninterrupted operation. To prevent any interruptions in the supply of electrical power DCC has an alternative autonomous power source which is completely sufficient to maintain all crucial business operations.

In order to secure communication in case of a major problem or a disaster we have reserved telephone lines and other communication facilities that can ensure efficient communication at the main or reserve buildings.

DCC fully appreciates the significance of not only tangible assets but also intangible assets (employee motivation, market reputation, client confidence etc.) and elaborates on the Business Continuity Plan taking into account all these factors.

The Business Continuity Plan includes personnel trainings, career progression programs and staff rotation system to ensure continuity of crucial business processes. Furthermore, a still greater emphasis is put on the issues of interaction with the Company's clients and staff awareness: all the necessary documents and the contingency plan are promptly communicated to all employees.

The multifaceted approach to issues of Business Continuity Management at DCC allows not only to develop an efficient contingency recovery scheme but also to minimize negative impact of risks which the Company can not possibly be insured against.
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