US Business Continuity Program

SGAS has taken the following steps to address the resumption of critical business functions in the event a crisis impacts its ability to function at its primary work site. This is affected through a rigorous and focused recovery plan supported by a comprehensive infrastructure and a diverse secondary production data center site. The key components of recovery are:

• firm-wide crisis management process;
• thorough departmental recovery plans;
• annual departmental/revision/enhancement of plans;
• scheduled and executed IT and recovery staff exercises; and
• regular audit and regulatory validation.

SGAS measures all aspects of recovery against stated recovery goals that are reviewed and approved on an annual basis. Subsequently SGAS continues to adjust and refine the plan as needed.

Business continuity planning is a company-wide effort that requires the contributions of both business and support functions.

• SGAS business teams are responsible for developing, maintaining, testing and updating their recovery plans with the facilitation of the SG Corporate and Investment Banking Business Continuity department.
• The Crisis Management Team, headed by the SGAS CEO and COO, has Crisis Management plans that detail high level procedures and guidelines for the Crisis Management Teams.
• Supporting the business teams are technical units, including communications, computer support and customer support, providing for seamless resumption at alternate locations that are as transparent as possible to our customers.
• The Internal Audit Department reviews the exercise scope, observes the exercise results and validates them.

The primary alternate work centers for all of SGAS activities supports identified critical staff providing services to our customers. This is accomplished through the use of a robust technical infrastructure as well as communication interfaces with our major settlement and clearing suppliers and other key business partners. The number of staff, supporting equipment and communication interfaces are reviewed by the business units on an ongoing basis and adjustments are made as needed and validated by senior managers.

• Several times throughout the year, each business unit has the opportunity to conduct its own recovery exercises, which include, as relevant, desktop validation site visits, connectivity of equipment, configuration of equipment and actual processing at the alternate work centers.
• At least once annually, all business units are required to participate in a coordinated exercise to ensure that the recovery centers can support all required activities.
• In addition, twice annually, computer systems and servers are switched to the alternate site within designated time frames and validated for connectivity and functionality.
• Additional staff exercises such as evacuation and assembly drills are organized on an annual basis to ensure that all recovery staff remained trained to ensure that staff is fully orientated to the disaster procedures.

If after a significant business disruption you cannot contact SGAS in New York at our main headquarters at (212) 278-6000, you should call our alternative number at (212) 278-6868. If you cannot access us through either of those means, you should contact our clearing area, SGAS, John Ryan at (201) 839-8971 for instructions on how to conduct securities transactions processing, clearance, settlement, maintenance of customer accounts, and access to customer accounts and the delivery of funds.

If you have questions about our business continuity planning, contact the Societe Generale Business Continuity group at (212) 278-6868 or Michael Melillo, Managing Director of Business Continuity Management at (212) 278-6098 / e-mail: michael.melillo@sgcib.com