TEXAS STATE SECURITIES BOARD / ENFORCEMENT DIVISION

questionnaire relating to

GS Partners, GSPartners.Global and GSPro.Network et al.

CONFIDENTIAL PER SECTION 4002.161 OF THE TEXAS GOVERNMENT CODE

The Texas State Securities Board/Enforcement Division is a regulatory and law enforcement agency. In November 2023, the Securities Commissioner announced the filing of an ex parte emergency enforcement action against GS Partners and other respondents, including parties alleged to be owners, officers, agents and/or affiliates of the firm. The action accused the respondents of perpetrating illegal and fraudulent securities schemes in Texas that threatened irreparable public harm.

^{As of April 4, 2024, the emergency action is final and not subject to appeal as it relates to Dirc Zahlmann, Bruce Innes Wylde Hughes, Aline Lima and Swiss Valorem Bank LTD. The other parties are afforded the opportunity to challenge the emergency action.}
If you are a client of GS Partners, GS Pro or related parties, we want to hear from you, regardless of whether you live in Texas. The Enforcement Division is requesting that you complete this brief form. Your responses will be treated as confidential pursuant to Section 4002.161 of the Texas Government Code (the Securities Act) and Texas Administrative Code Title 7, Part 7, Chapter 131 (the Rules and Regulations of the State Securities Board). We estimate that it will take approximately 10 minutes to complete the form depending on the amount of information you chose to provide.

You can research the agency at its website at ssb.texas.gov. Please direct questions to the attention of Joe Rotunda, Seth Oufnac and Kristen McCourt at enforceinfo@ssb.texas.gov or by telephone at 512-305-8300.

This form, including its contents and any communications made contemporaneously with its dissemination, should not be construed to imply (a) any allegations of actual or suspected wrongdoing on the part of the parties described herein, (b) any allegations or findings of affiliations or associations by or between parties identified herein, (c) any allegations or findings of affiliations or associations by or between the parties identified herein and the parties named in the emergency order, or (d) any actual or anticipated investigation of any party. Additionally, the agency's emergency order was issued on an ex parte basis pursuant to Section 4007.104 of the Securities Act, Texas Gov't Code Section 4001.001 to 4008.105. As set forth in the statute, emergency orders are, in part, issued on the Securities Commissioner's determination that certain conduct, acts or practices threaten immediate and irreparable public harm. Parties named in the emergency order are afforded the opportunity to request a hearing to challenge the emergency order. The accusations set forth in the ex parte order described herein therefore constitute allegations and, after a hearing, may be affirmed, modified or set aside.

As of April 4, 2024, the emergency order is final and not subject to appeal as it relates to Dirc Zahlmann, Bruce Innes Wylde Hughes, Aline Lima and Swiss Valorem Bank LTD. The other respondents are challenging the emergency order and are entitled to a hearing, the opportunity to present evidence and testimony and all other rights granted by the Securities Act and the Administrative Procedure Act, Tex. Gov't Code Ann Sections 2001.001-2001.903.