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Business Continuity Plan


Pavilion Global Markets Ltd. has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our Business Continuity Plan.

Contacting Us

After a significant business disruption, you should be able to contact us as at 514 932-8948 or 1-877-932-7171 (or at traders@paviliongm.com). In the event that you cannot contact us in the usual manner, please refer to the Contact Us page.

Plan details

We plan to quickly recover and resume business operations after a significant business disruption and respond by:

  • safeguarding our employees and property;
  • making a financial and operational assessment;
  • protecting the firm’s books and records; and
  • allowing our customers to transact business.

In short, our Business Continuity Plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our plan addresses:

  • data backup and recovery;
  • all mission critical systems;
  • financial and operational assessments;
  • alternative communications with customers, employees, and regulators;
  • alternate physical location of employees;
  • critical supplier, contractor, bank and counter-party impact; and
  • regulatory reporting.

Our U.S. securities trading clearing firm, Pershing LLC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our U.S. securities trading clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four (4) hours. Your orders and requests for funds and securities could be delayed during this period.

Varying disruptions

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to our firm or a building housing our firm, or a disruption affecting our business district, we will transfer our operations to our local disaster recovery site when needed and expect to recover and resume business within sixty (60) minutes. In either situation, we plan to resume business, transfer operations to our clearing firm only if absolutely necessary, and notify you through our web site or our customer emergency number, (514 932-8948 or 1-877-932-7171).

If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our institutional customers have prompt access to their accounts.

For more information – If you have questions about our Business Continuity Plan, you can contact us at bcp@paviliongm.com.

SEC Rule 606


Disclosure of Order Routing Information

U.S. Securities and Exchange Commission (SEC) Rule 606(a) requires all brokerage firms to make publicly available quarterly reports, broken down by calendar month, containing certain required statistical information regarding the routing of held, non-directed customer orders in Regulation NMS stocks and listed options.

Pavilion Global Markets Ltd. (“PGML”) is publishing such quarterly report in accordance with Rule 606(a), and will keep the report publicly available for a period of three (3) years.

The report contains a section for Regulation NMS stocks (separated by securities that are included in the S&P 500 Index as of the first day of the quarter and other Non-S&P 500 stocks) and a separate section for listed options. For each section, the report identifies the venues to which PGML routed the relevant orders and, for each venue, the required statistical information broken down by order type (i.e., market order, marketable limit order, non-marketable limit order and other orders). Each section of the report also contains information regarding the material aspects of PGML’s relationship, if any, with each venue.
For further information on SEC Rule 606, you may visit the SEC website.

SEC Rule 606(a) Report:

2021

2020

SEC Rule 607


Disclosure of Payment for Order Flow

Pavilion Global Markets Ltd. transacts business on the varying market venues and as such is subject to the standard schedule of transaction fees for broker-dealers of those Exchanges and ECN’s. Those transaction fee schedules may include payment of rebates for certain order types. In the course of transacting business, the Firm may be the recipient of said rebates.

Although Pavilion Global Markets Ltd. has used commercially reasonable efforts to provide accurate information, the data is provided to you on an “as is” basis.

PAVILION GLOBAL MARKETS LTD. SPECIFICALLY DISCLAIMS ALL WARRANTIES EXPRESS OR IMPLIED WITH RESPECT TO THE INFORMATION, INCLUDING SPECIFICALLY, BUT NOT EXCLUSIVELY, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. YOU AGREE THAT PAVILION GLOBAL MARKETS LTD. SHALL NOT HAVE ANY LIABILITY FOR ANY INDIRECT, CONSEQUENTIAL, SPECIAL OR DIRECT DAMAGES FOR ANY ACTION OR INACTION WHICH YOU MAY TAKE AS THE RESULT OF THE DATA, WHETHER AS A RESULT OF ANY CLAIM SOUNDING IN CONTRACT OR ANY OTHER THEORY OF LIABILITY.

Trade Matching Statement


Our Trading Matching Statement can be accessed here.