BUSINESS CONTINUITY PLAN

All Group Financial Services Inc.

Executive Summary
All Group Financial Services Inc. ("All Group") BCP Officer is James Moon, (416) 816 7204, jmoon@allgroup.ca.  Mr. James Moon is the President, CEO and Chief Compliance Officer. The name will be updated in the event of a material change.

Firm Policy
All Group’s policy is to respond to a Significant Business Disruption (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 assure clients prompt access to their funds and securities.

Incident Management Plan
In the event that we are forced to leave our building during the course of a business day, all employees will promptly evacuate the building and meet at southwest corner of Bay and Queens Quay.

Staff Awareness
We are ensuring that all personnel are continually aware of their responsibilities and know how to remain in contact and what to do in the event of a crisis by issuing hard copies to each staff member and notifying of the location of the electronic copy. The current version of BCP is saved in the following location for staff reference: Z:\RR- 10.Policy and Procedures\All Group Business Continue Plan

Crisis Communication Centre
The IIROC Crisis Communication Centre (CCC) is an information exchange for Investment Industry Regulatory Organization of Canada (IIROC) Dealer Members to be used in the event of a SBD. The CCC is operated by IIROC and accessible through the IIROC Homepage (BCP CCC) or through the business continuity planning web page which can be accessed through Member Resources. In addition the following link can be used to log in: http://ccc.iiroc.ca/

Business Description
AGFS is a brokerage firm that conducts business in equity, fixed income, mutual funds and options. AGFS is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, we do not hold customer funds or securities. We accept and enter orders. All transactions are sent to our carrying broker Fidelity Clearing Canada ULC (FCC), who executes our orders, compares them, allocates them, clears and settles them. Our carrying broker also maintains our customers’ accounts, can grant customers access to them, and delivers funds and securities. Our firm services both retail and institutional customers.
Office Locations
Our firm has offices located in Toronto, Oshawa, Barrie, Niagara-on-the Lake and Cambellford.

  1. Head office – Toronto

    Our head office is located at 10 Bay Street, Suite 701, Toronto, Ontario, M5J 2R8. Its main telephone number is (416) 613-1550, and fax number is (416) 640-4751.We engage in order taking and entry at this location.

  2. Branch – Oshawa

    AGFS has one branch located at 538 Crimson Crt, Oshawa, Ontario, L1J 8E2. Its main telephone number is (905) 728-2615. We engage in order taking and entry at this location.

  3. Branch – Barrie

    AGFS has one branch located at 200 Brock Street, Suite 4, Barrie, Ontario, L4N 2M4. Its direct telephone line is (705) 345-6846. We engage in order taking and entry at this location.

  4. Branch – Niagara-on-the-lake

      AGFS has one branch located at 157 Victoria St, Niagara-on-the-Lake, Ontario, L0S1J0. It is direct   telephone line is (647) 931- 0805. We engage in order taking and entry at this location.

Alternative Physical Location of Employee
In the event of an SBD, we will move our staff from affected offices to the closest of our unaffected office locations. If none of the other office locations is able to receive staff, AGFS has a capability to send employees home and to continue operation from their place of residence. All of our staff will remain communicating within the business through e-mail, company distributed cell telephone and remote access to the server. Our current battery unit can keep the core server, switches and router online for approximately six hours. The main contact in this event is James Moon, UDP, President and CEO, whose mobile phone number to contact is (416) 816 – 7204.

Customer’s Access to Funds and Securities. 
Our firm does not maintain custody of customer’s fund or securities, which are maintained at our carrying broker, FCC. In the event of an internal or external SBD, that the website access is not available, and then if a telephone service is available, our registered persons will take customer orders or instructions and contact our clearing firm on their behalf. The customers may access their funds and securities by contacting their registered representatives on their cellular telephones or by contacting James Moon at his cellphone, (416) 816 -7204 or Michael Comeau at cellphone, (416) 579 -1799.

Order taking
Currently, our firm receives orders from customers via telephone and or face to face with a client. During a SBD, either internal or external, AGFS will continue to take orders through any methods that are  available  and  reliable. In addition, as communications permit, AGFS will inform our customers when communications become available and/or alternative solution to send their orders to AGFS. Method of communication should be include but not limited to telephone, mobile phone and/or Microsoft Lync. Microsoft Lync 2013 server has a capability to reroute/forward phone calls coming to AGFS ‘s head office to alternative numbers (e.g. RR’s mobile phone), at least for another 6 hours after the power is off in the head office building.

Other services currently provided to customer.
In addition to those services listed above in this section we also provide clients access to their accounts online through NDEX application.  In the event of an internal SBD, the client will still have an opportunity to monitor their accounts online. In the event of an external SBD, the clients will still be able to view their accounts  online  unless external  SBD will effect NDEX systems who  maintains  the access  web-site  and  data  from  location  in  Montreal,  Quebec  as  described above.

Mission Critical Systems Provided by Our Carrying Broker
Our firm relies, by contract, on our carrying broker, FCC, to provide order execution,   order comparison, order allocation, and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts.

Communication with Customers, Employees and Regulators.
We now communicate with our customers, employees and the regulator using the telephone, fax, e-mail, mail, and physical visit. In the event of an SBD, we will assess which means of communication  are still available to us, and use the means closest in speed and form (written  or oral)  to  the  means  that  we  have  used  in the  past  to  communicate  with  the other  party. Our backup email address is allgroupbackup@outlook.com. The backup phone line is (416) 816-7204.

External Dependencies – Service Providers
We have contacted our critical service providers (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm.

Regulatory Reporting
Acker Finley is subject to regulation by: IIROC, OSC, TSX and CNSX. We now file reports using the internet, email, paper copies in the mail, fax, and Echoworx Encrypted email. In the event of an SBD, we will check with our regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. At our alternate location, we will have a laptop computer pre-loaded with the Quickbooks program. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.

Updates and Annual Review
Our firm will update this plan whenever we have a material change to our operations, structure, business or location or to those of our carrying broker. In addition, our firm will review this BCP annually, at the end of November to the early December, to modify it for any changes in our operations, structure, business, or location or those of our carrying broker.

Senior Management Approval
Senior management has approved this Business Continuity Plan as reasonably designed to enable Acker Finley to meet its obligations to clients in the event of an SBD.