This is a summary of the Business Continuity Plan (the “Plan”) of Cohen & Steers Capital Management, Inc. and its affiliates (collectively, the “Company”), including Cohen & Steers Securities, LLC, a registered broker-dealer and distributor of the Cohen & Steers open-end funds. Whether we are affected by a firm only, single building, citywide or regional disruption, our policy is to respond by first and foremost safeguarding our employees’ lives. The Company will immediately seek to account for all employees, ensure their safety and communicate any relevant instructions to them. The Plan is then designed to allow us to assess our financial and operational status, quickly recover and resume normal business operations, protect the firm’s books and records, and allow our customers to transact business. The Plan is reviewed periodically to ensure that documented information is current and recovery strategies support our operations.
Examples of scenarios requiring the use of business continuity capabilities:
1. Firm-only business disruption: a critical system and accompanying data are unavailable.
Our critical systems and data are replicated in real-time at an offsite location and we would fail the affected system over to the alternate location and continue processing.
2. Disruption in our building or region: building unavailable
If our building is rendered unavailable, critical staff would be deployed to an offsite facility to resume operations. In addition, other employees would be able to access the Company’s computer network and systems, when available, through an Internet connection.
Although we believe our Plan allows us to respond reasonably and effectively to events of varying scope, unforeseen circumstances may create situations where we are unable to fully recover from a significant business disruption.