Dimensional Fund Advisors LP and its affiliates (collectively, “we” or “Dimensional”) have adopted a Business Continuity and Disaster Recovery Policy (“Policy”) with a goal to achieve continuity of our business operations in the event of a disaster or other disruption. In an effort to meet this commitment, Dimensional maintains a Business Continuity and Disaster Recovery Program (the “BC/DR Program”).

The BC/DR Program seeks to address various types of business disruption, broadly defined as any event that prevents access to Dimensional’s critical office spaces, significantly limits Dimensional’s use of its technology, or materially impedes Dimensional’s ability to communicate with clients. With any disruption, our priority is employee safety and then resumption of the critical processes and systems.

The BC/DR Program is supported by Business Continuity Plans, Disaster Recovery Plans, and Crisis Management Team Plans (collectively, the “Plans”) that include location- and department-specific recovery procedures and contact information for use by that location or department in meeting its recovery responsibilities. 

In the event of a business disruption, Dimensional has designated a Crisis Management Team (CMT) that consists of key executives and department heads who will lead our recovery efforts. The CMT works in connection with Local Crisis Management Teams (“Local CMTs”) that operate for each of Dimensional’s global offices or regions. During a disruption, the CMT’s and Local CMT’s responsibilities include activating the Plans, implementing recovery strategies and facilitating communication. The CMT and Local CMTs undertake regular exercises and follow pre-determined escalation procedures in an effort to identify and address issues as promptly as possible under given circumstances.

Though the CMT and Local CMTs lead recovery efforts during an event, all Dimensional departments are responsible for completing their critical processes and for maintaining communication with their clients and stakeholders. Department plans contain procedures and contact lists to help meet this responsibility.

Dimensional sites are geographically diverse. Dimensional’s trading and operation sites are equipped with redundant power supply/generator solutions that assist in continuing critical operations during a power failure. Through our global technology and network infrastructure, Dimensional’s objective is to have trading and operations support each other during major recovery scenarios by transferring critical processes to another site. Additionally, key employees in each location are expected to work from home and log into the network using a virtual private network (VPN), or equivalent, if required due to an outage.

We have a secure primary data center and a backup data center in separate locations. All Dimensional sites are connected by a global network with backup data connections at each site. If the primary data center is unavailable, critical systems and data are designed to be available at the backup data center. A corporate-wide phone system, with failover and forwarding capabilities, provides telephone communications globally.

We expect our geographic diversity, technological redundancy, and communications flexibility to allow us to continue operations should one of our offices or data centers become disabled or experience an outage.

In the event of a significant technology outage, Dimensional intends to restore our systems in tiers, based on their criticality to business operations. Those that support mission critical processes are restored first with the remaining systems restored according to their relative priority. Our data backup policy aims to have data and systems backed up daily, stored offsite, and maintained based on regulatory requirements.

Each year, Dimensional conducts exercises in an effort to validate and update the Plans and procedures. Annual exercises may include elements of communication, technology, and critical process recovery. Departments conduct annual business impact analyses, which identify the critical business processes within each department, the systems on which these processes depend, and workarounds in the event of system failure. This analysis helps Dimensional to have a better understanding of its business and technology environment so that it can continue its critical business processes during a disaster.

The Policy and Plans are updated regularly and reviewed by senior management of Dimensional with the goal of enabling our firm to meet its obligations to clients in the event of a business disruption.

The recovery plan and this summary are subject to revisions. This statement was updated May 17, 2021.