RUANE, CUNNIFF & GOLDFARB L.P.

The Adviser provides investment advisory services on a discretionary basis to various clients, including individuals, institutions with separately managed accounts, and a registered investment company. Certain supervised persons of the Adviser also provide advisory services to private funds intended for sophisticated individual and institutional investors. Additionally, the Adviser offers non-discretionary investment sub-advisory services to Hyperion Capital Advisors LP, an affiliated SEC-registered investment adviser. The Adviser has implemented policies and procedures to address conflicts of interest related to managing multiple accounts and allocating investment opportunities. Investment decisions are reviewed to ensure equitable treatment of accounts with similar objectives. Investment opportunities are generally allocated pro rata based on asset size, although non-pro rata allocations may occur considering factors described in Item 16. The Adviser's procedures also require price averaging for aggregated orders.

The Adviser employs several investment strategies, including Buy and Hold, where securities are acquired and held for relatively longer periods, regardless of short-term market fluctuations. Another strategy is a Focused Portfolio/Non-diversification approach, concentrating investments on a limited number of issuers without diversifying across types of securities, countries, or industry sectors. Additionally, the Adviser may engage in Margin transactions, acquiring securities with borrowed money against the value of assets in the client's custodial account. These strategies carry specific risks. Buy and Hold may miss short-term gains, and incorrect predictions can lead to sharp declines in security value. Focused Portfolios can be subject to more rapid changes in value due to the lack of diversification. External factors like terrorism, war, natural disasters, and public health events can also impact investment liquidity and performance. The Adviser's investment decisions may cause underperformance compared to other strategies or benchmark indices, and assessments of industries or companies may be incorrect.

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