TWEEDY, BROWNE COMPANY LLC

The advisory business is associated with the Firm since 1978 and provides advisory services to the Firm. The senior advisor to the Investment Committee, William H. Browne, has no disciplinary information that may be deemed material to be disclosed and is not actively engaged in any other investment-related business or occupation. He does not receive any additional compensation for providing advisory services to the Firm. AMG, a publicly traded asset management company, holds an equity interest in the Firm through a wholly-owned subsidiary, AMG TBC, LLC. However, Tweedy, Browne is operated autonomously and independently and does not have any material business dealings with the AMG Affiliates. The AMG Affiliates do not formulate advice for the Firm’s clients, and AMG’s ownership interest in the Firm does not present any potential conflict of interest for the Firm with respect to its clients.

The firm employs a value investing approach, which involves identifying stocks that are trading at a discount to their intrinsic value. The firm's analysts conduct in-depth research, including screening potential investments using proprietary metrics, reviewing publicly available information, meeting with company management, and analyzing acquisition transactions and third-party research. Client accounts are invested according to a value investment strategy, with a focus on international, global, global high dividend, or U.S. and ADR equity investments, depending on the client's direction. International accounts invest primarily in securities issued by companies located outside the United States or that derive a large portion of their revenues from activities outside the United States. Global and global high dividend accounts invest in securities issued by companies located or deriving revenues from both outside and within the United States. U.S. Equity/ADR accounts invest primarily in securities of U.S. issuers and American depositary receipts, which represent shares of non-U.S. companies that trade in U.S. financial markets.

(Subscription Required)