Business Continuity Plan

Advisory Business Disclosure
GPB Capital Holdings, LLC (GPBCH), a Delaware limited liability company formed in March of 2013, is an SEC No. 801-79413 private fund adviser that structures, manages, promotes, sponsors, and through itself and affiliate entities, serves as general partner and/or investment manager for various private equity funds.

Customer Disclosure Statement
GPBCH plans to quickly recover and resume operations after a significant business disruption (SBD) and respond by safeguarding our employees and property, making a financial and operating assessment, protecting the Firm’s books and records, and resuming communications with our managed assets. In short, our Firm’s business continuity plan (BCP) is designed to permit us to resume operations as quickly as possible, given the scope and severity of the SBD.

The Business Continuity Plan (BCP)
The BCP 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; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business. The GPBCH fund administrator, Phoenix American Financial Services (2401 Kerner Blvd, San Rafael, CA 94901), maintains all documentation and financial records related to your investments and account holdings and backs up important records in accordance with their business continuity plans. For more information on their contingency plan, please contact the sponsor or issuer directly at the telephone number provided on your statements or offering documents or through its website.

Significant Business Disruption
GPBCH’s plan takes into account two types of SBDs – internal and external. Internal SBDs affect only GPBCH’s ability to communicate and do business, such as a fire or loss of electrical power in the building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a natural disaster, or another event that causes wide scale, regional disruption in essential services, or any related force majeure.

Internal SBDs
In the event of a disruption in GPBCH business operations due to an internal SBD, we will attempt to continue to conduct business as usual by utilizing alternative communication methods (if available) such as the Internet, cell phones, etc., or by relocating operations to an alternative location that has already been established for such an event. If personnel or operations must be moved to an alternate location, GPBCH anticipates that it will resume regular operations within 24 to 48 hours.

External SBDs
In the event of a disruption in GPBCH business operations due to an external SBD, we will attempt to continue to conduct business as usual by moving its operations to an alternative location outside of the affected area, if possible, or by providing clients with alternative communication arrangements, as indicated below, to conduct business or to access their funds and securities. GPBCH will attempt to resume operations within 24 to 48 hours and to keep its clients informed regarding relevant events to the best of its ability based on the circumstances. In all cases, GPBCH will resume normal business operations as soon as it is able to do so, based on the type and extent of the disrupting event. If the SBD is so severe that it prevents us from remaining in business, we will assure our customers’ prompt access to their funds and securities.

Communications
In the event you are unable to reach GPBCH at our main number 877-489-8484, please proceed as follows:

  1. Contact GPBCH at either (516) 858-5928 or (212) 235-2650
  2. Access the Firm’s website at www.gpb-cap.com;
  3. Contact the private placement issuer at the number listed on the applicable offering document, or alternatively, go to the issuer’s website for more information on contacting this entity and its business continuity plans. The website address can generally be found on your statement or offering documents.