There are rumors that “Occupy Central Movement” will be taking place in July this year. Unlike the previous “camping out” event under the HSBC headquarters, this year the “Occupy Central Movement” is proposed to be a large-scale civil protest and may lead to a full blockade of Central, bringing Hong Kong’s financial center to a standstill.
The Hong Kong Police Force may take action to maintain public order by blocking streets and limiting access to certain areas, including Central office buildings. If the event goes ahead, all SFC licensed corporations should review their current Business Continuity Procedures to ensure that business operations within the firm, as well as with ongoing service providers, are not disrupted.
Kinetic Partners recommends that you review your Business Continuity Plan (“BCP”) to ensure your business operations can continue in any event, and potentially adverse impacts to your clients are minimized.
In particular, you should:
- Designate a senior member of staff to activate your BCP, communicate with other staff about the plan and the process, and coordinate with your external service providers
- Consider setting up a back-up site where your core operations and services can be maintained
- Enable remote access to your firm’s systems (e.g. email system, trading system) if your staff are unable to access your major office
- Back-up and store your critical business and transaction data, and make the data available for use in your back-up computer system within a reasonable timeframe
- Have an up-to-date emergency contact arrangement for all key staff members and ensure that all contact points are valid and reachable
- Test the functionality of your telecommunication systems (e.g. forward calls to another telephone system)
- Ensure all proper books and records are maintained during the period
- Discuss with your service providers (e.g. custodians and administrators) and understand their BCP and any other relevant arrangements in light of the “Occupy Central Movement”
- Assess the financial impact caused to your firm (e.g. potential claims from investors if you cannot provide the usual level of services to them) and assess the adequacy of your firm’s existing insurance coverage
- Notify the SFC of any change of information (e.g. change of business premises and emergency contacts)
If as a result of the “Occupy Central Movement”, a firm is required to implement its BCP, this implementation can serve as the annual BCP test/review for those firms registered with the SEC and/or CFTC.