Emergency Contact Persons
Our firm’s emergency contact persons are:
- Christopher Y. Williams, CEO, 508-579-7441, christopher.williams@strategicgold.com
- Michael C. Williams, President, 239-821-3763, michael.williams@strategicgold.com
- Charlotte A. Williams, Executive Vice President, 914-582-1908, charlotte.williams@strategicgold.com
- Peter K. Blume, Independent Trustee, 412-394-7762, pblume@clarkhill.com
These names will be updated in the event of a material change.
Firm Policy
Strategic Gold Corporation (“SGC”) has developed and set forth below a written plan to ensure business continuity in the event of a Significant Business Disruption (“SBD”). Our firm’s policy is to respond to an SBD by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our clients to transact business. In the event that we determine we are unable to continue our business, we will notify our clients.
Significant Business Disruptions (SBDs)
Our plan anticipates two kinds of SBDs: internal and external. Internal SBDs affect only SGC’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of the markets or a number of firms, such as a terrorist attack, a city flood, or a wide scale regional disruption.
Business Description
SGC is an administrative company whose sole purpose is to facilitate the direct and uncompromised ownership of precious metals by bringing investors to the Primary Bullion Market through the Clear Title Program. SGC clients can liquidate all or part of their bullion assets at any time during the trading day. There is no lock-up period.
Custodian
Custodian: Loomis International
Vault Locations:
- The bullion vault of Loomis International, Miami, Florida
- The bullion vault of Loomis International, Zurich, Switzerland
- The bullion vault of Loomis International, New York
- The bullion vault of Loomis International, Toronto, Canada
Office Locations
Our firm has offices located in two locations. All mission critical systems are fully operable in both locations.
Main Office
5072 Annunciation Circle, Suite 317, Ave Maria, Florida, 34142. Tel: 239-692-9154
Backup Office
3722 Yakobi Lane, Naples, Florida, 34119. Tel: 239-842-8067
Alternative Physical Location(s) of Employees
In the event of an SBD, we will move our staff to the closest unaffected office location. If none of our offices is available, we will move them to our disaster recovery site in Pittsburgh, Pennsylvania.
Building Related Interruption
Short Term Interruption: In the event of a short term or intra-day interruption (1-3 days), SGC’s Ave Maria, Florida recovery site is designed to finish out the first business day of an interruption.
Customer Service and Critical Business Phone and Fax Lines
SGC’s Business Continuity plans include pre-defined phone re-routing to ensure that business calls will be handled.
Customers’ Access to Funds and Precious Metals
Our firm does not maintain custody of customers’ bullion assets, which are maintained within the custodial vaults of Loomis International. In the event of an internal or external SBD, if telephone service is available, our employees will take customer orders or instructions and contact the custodian on their behalf.
Financial and Operational Assessments
In the event of an SBD, we will immediately identify what means will permit us to communicate with our clients, employees, critical business constituents, critical banks, and critical counter parties.
Circumstances in Extremis
If Strategic Gold is unable to perform its obligations due to force majeure, bankruptcy, or otherwise, the Strategic Gold Operational Procedures for Circumstances In Extremis will be initiated. An independent Trustee has been established to protect the individual property rights of our clients.
Independent Trustee
Peter K. Blume, Clark Hill, LLP
Tel: 412-394-7762 | Cell: 412-295-7840 | Fax: 412-394-2555
Address: One Oxford Centre, 301 Grant St, 14th Floor, Pittsburgh, PA 15219
Operational Procedures for Circumstances In Extremis
- Senior Management informs the Trustee that the Procedures for Circumstances In Extremis are in effect.
- Trustee will notify clients by phone, email, or fax that their bullion assets will no longer be administered by SGC.
- Clients will have 30 days to decide whether to liquidate their holdings, take physical delivery, or secure a new administrator.
Data Back Up and Recovery
In the event of an SBD that causes the loss of our records, we will recover them from our backup site. If our primary site is inoperable, we will continue operations from an alternate location.
Mission Critical Systems
SGC’s mission critical systems include those that ensure the continuation of services, such as maintaining client and transaction records.
Alternate Communications
We will use telephone, email, and other communication methods to keep our clients informed during an SBD.
Critical Business Constituents, Banks, and Counter Parties
We have contacted our critical business constituents, banks, and counter parties to ensure that we can continue our business relationships in the event of an SBD.
Disclosure of Business Continuity Plan
We provide a written BCP disclosure statement to customers at account opening and upon request.
Updates and Annual Review and Testing
SGC will update this plan whenever we have a material change to our operations, structure, business, or location, or those of our clearing firm. SGC will also review this BCP annually.