Firm Overview GBS Finance, LLC (“GBS”) is a Delaware limited liability company that was formed in May 2012. GBS’ principal place of business is in Miami, Florida. Aramil Develops, S.L. is the principal owner of GBS and the indirect principal owners include GBS Finanzas, S.A. Please refer to Schedule A of GBS’ Form ADV Part 1A for additional information about the ownership of the firm. Clients and Services GBS is an investment management and wealth advisory firm providing services to primarily high net-worth individuals, families, family offices, foundations, endowments and other institutions. GBS provides these services on a discretionary and non-discretionary basis for domestic and non-U.S. accounts. Discretionary Services. GBS manages client portfolios pursuant to a variety of investment strategies that clients may select depending on their investment objectives and restrictions. Such strategies generally include, without limitation, equities, emerging markets, fixed income, collective investment vehicles and derivatives. More detailed information about these strategies is found below under “Item 8: Methods of Analysis, Investment Strategies and Risk of Loss.” Clients may impose restrictions on how GBS manages their accounts according to these strategies. These restrictions generally appear either in the client’s investment management agreement or in the investment guidelines adopted for the account. Non-Discretionary Services. GBS provides non-discretionary management services to clients in the following areas: (1) GBS assists clients in the design and implementation of the architecture of overall investment programs, based on, among other things, each client’s financial circumstances, risk parameters, investment objectives and restrictions,

and cash flow needs. (2) GBS provides recommendations with respect to liquidity management for the cash needs and goals of clients based on parameters and other information provided by each client. (3) GBS provides oversight, monitoring and review services with respect to the investment management services provided by third-party investment managers who manage portions of client assets (including via their management of pooled investment vehicles in which client assets may be invested) (“Third-Party Managers”). As part of its services, GBS will offer to audit a prospective client’s portfolio to gain a better understanding of the allocations, current positions, volatility and risks across the entire portfolio, as well as the prospect’s investment suitability. GBS will also analyze the portfolio’s fee structure, including the client’s use of banks/custodians, and, where appropriate, make recommendations intended to improve portfolio efficiency that may result in the client paying lower fees and expenses than previously. In addition, GBS may act in a sub-adviser capacity from time to time. GBS may also provide other advisory, private business, family office consulting and administrative services as clients may request. The scope of any such services provided by GBS will vary depending on the needs of the client. In the event that GBS may provide any commodities and futures trading advice to clients that would require GBS to register as a “commodity trading advisor” (“CTA”) under the Commodity Exchange Act, as amended, GBS intends to rely on available exemptions from such registration. As of December 31, 2022, GBS managed approximately $26,270,645 in client assets ($17,004,793 on a discretionary basis, and $9,265,852 on a non-discretionary basis).