RUANE, CUNNIFF & GOLDFARB L.P.

The Adviser offers discretionary investment advisory services to individuals and institutions with separately managed accounts and a registered investment company. The Adviser also provides non-discretionary investment sub-advisory services to Hyperion Capital Advisors LP, an SEC-registered investment adviser that is affiliated with the Adviser. The Adviser has adopted and implemented policies and procedures that are intended to address conflicts of interest relating to managing and providing advice to multiple accounts and the allocation of investment opportunities. The Adviser reviews investment decisions for the purpose of seeking to ensure that all accounts with substantially similar investment objectives are treated equitably over time. The Adviser’s procedures relating to the allocation of investment opportunities require that similarly- managed accounts participate in investment opportunities pro rata based on asset size (based on the value of the assets of each participating account relative to the value of the assets of all participating accounts), however the Adviser may allocate investment opportunities on a non-pro rata basis due to consideration of the factors described in Item 16. The Adviser’s procedures also require that, to the extent orders are aggregated, the orders are price averaged.

The Adviser employs two main investment strategies: 1. Buy and Hold: This strategy involves acquiring securities for clients and holding them for extended periods, regardless of short-term market fluctuations or stock price volatility. 2. Focused Portfolio/Non-diversification: This strategy concentrates investments on a limited number of issuers without seeking diversification across security types, countries, or industry sectors.

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