VCP APEX (US)
BUSINESS CONTINUITY PLAN
SUMMARY DISCLOSURE STATEMENT

VCP Apex (US) (“VCP”), pursuant to Financial Industry Regulatory Authority, Inc. (“FINRA”) rules, has created a Business Continuity Plan, to address and guide our response to and recovery from Significant Business Disruptions (“SBDs”). Copies of this Summary Disclosure Statement shall be given to all clients at the time they open their accounts with VCP. VCP’s Business Continuity Plan is subject to modification
and an updated summary will be promptly e-mailed to our clients. Alternatively, clients may obtain updated summaries by requesting a written copy by mail or fax.

In all of the following scenarios, VCP plans to continue business and our planned recovery time, depending upon the time of occurrence, should not exceed 24 hours from the time of the declaration of the SBD. Staff, telephone calls, and e-mails will return to their original location upon full restoration of service.

Disruption to a single building or our Firm’s NY Main office, London branch office, NC branch office or Grand Cayman branch office

If a disruption occurs at our main and/or branch offices, we will move staff to the nearest reasonably suitable, available office location(s).

Disruption to a business district

If a disruption occurs in our business district affecting our main and/or branch offices, we will move staff to the nearest reasonably suitable, available office location(s). These locations shall be outside the
business district.

City-wide business disruption

If a disruption occurs in our city-wide area that affects our main and/or branch offices, we will move staff to the nearest reasonably suitable, available office location(s). These locations shall be outside the citywide area.

Regional disruption

If a regional disruption occurs that affects our main and/or branch offices, we will move staff to the nearest reasonably suitable, available office location(s).

VCP has also contracted with various entities to ensure that sensitive information is made redundant at back-up facilities. However, due to the nature of such information we do not disclose the specific location
of any back-up facilities, any proprietary information contained in our Business Continuity Plan or the
parties with whom we have back-up arrangements.

Please call if you should have any questions at 310-486-3321