Brandywine Asset Management

Firm Description Brandywine is a registered investment adviser in Pennsylvania. Brandywine is organized as an S Corp under the laws of the Commonwealth of Pennsylvania. Michael Dever is 100% owner. Brandywine is an asset management firm founded in 1982. Brandywine does not provide financial planning services or sell annuities, insurance, stocks, bonds, or other commissioned products, but rather offers clients fund management and managed account services. Brandywine receives a combination of management and performance-based fees as compensation. Brandywine manages Employee Retirement Income Security Act of 1974, as amended (“ERISA”), assets in the Brandywine Collective Investment Trust (“CIT”). The CIT is bankmaintained and not registered with the Securities and Exchange Commission. The CIT is not a mutual fund registered under the Investment Company Act of 1940, as amended (“1940 Act”), or other applicable law, and unit holders are not entitled to the protections of the 1940 Act. The regulations applicable to CIT differ from those applicable to a mutual fund. The CIT’s units are not securities registered under the Securities Act of 1933, as amended, or applicable securities laws of any state or other jurisdiction. Brandywine also manages a private investment fund, Safer Equity Fund LP. Brandywine does not tailor its advisory services, investment objectives, or strategies to the requests or needs of individual investors. Types of Advisory Services Brandywine manages investment funds and separately managed accounts on a discretionary basis pursuant to proprietary investment programs developed and managed by Brandywine. As of June 1, 2026, Brandywine managed discretionary client assets valued at approximately $150,000,000 and no non-discretionary assets. Brandywine does not offer comprehensive investment advisory services but rather serves as an investment manager to funds and managed accounts. We currently manage a suite of funds that are used in 401(k) and other qualified retirement plans plus a private hedge fund that is available only to “qualified investors.” In referring to qualified investors, we are specifically referencing that we only offer direct advisory services to those meeting the Securities and Exchange Commission (“SEC”) standard of a person or institution being an “accredited investor” or “qualified purchaser.” Investors meeting this criteria may inquire about investing into one of Brandywine’s funds or a managed account. For more information, please see Item 4 of our Form ADV Part 2A. When providing asset management services Brandywine provides services on a discretionary basis (we will have the authority to determine the type and amount of securities to be bought or sold in the fund or your managed account). For more information please see Item 16 of our Form ADV Part 2A. For Separately Managed Accounts and Private Funds: Account & Fee Minimums: Generally, the minimum investment for Brandywine’s private funds is $750,000 and the minimum investment for a separately managed account is

$25,000,000. Brandywine’s standard fee is 2% of assets annually (charged 1/6 of 1% per month) plus an “incentive Fee” equal to 20% of profits (payable quarterly). Collective Investment Trust Brandywine offers investors the ability to invest with Brandywine through the Brandywine Collective Investment Trust and its underlying funds: 1. Brandywine Large Cap

6.

2. Brandywine Extended Market 3. Summit Large Cap Growth 4. Summit Small Cap Growth

7. Focus International 8. Foundation Core Bond 9. Foundation Diversi_ied Income 10. Brandywine Target 2060

5. Advantage Large Cap Value

Advantage Small Cap Value

11. Brandywine Target 2050 12. Brandywine Target 2040 13. Brandywine Target 2030 14. Brandywine Target Retirement

Brandywine’s fees vary based the product. The fees are negotiable. The Brandywine Collective Investment Trust charges a management fee ranging from 0.34% to 0.64% (annualized) depending on the underlying fund. Management Fee Brandywine Large Cap Founders Class Summit Large Cap Growth Founders Class Advantage Large Cap Value Founders Class Brandywine Extended Market Founders Class Summit Small Cap Growth Founders Class Advantage Small Cap Value Founders Class Focus International Founders Class Foundation Core Bond Founders Class Foundation Diversified Income Founders Class Foundation Preservation Founders Class

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Note: Brandywine charges 0% management fee on its target date funds since they invest in the underlying funds above. Client Payment of Fees Brandywine’s management fees in regard to Collective Investment Trust (CITs) are paid to Brandywine monthly by the fund’s trustee, Alta Trust Company. Brandywine’s Management Fee, charged by its private limited partnerships, is billed quarterly in advance, meaning the fund is billed within the first week of each quarter. With regard to Separately Managed Accounts, management fees are usually charged monthly in advance and deducted from a designated client account to facilitate billing. The client must

consent in advance to the direct debiting of their investment account. Brandywine Collective Investment Trust charges fees daily and pays them to Brandywine at the end of each month. Brandywine’s Performance fee for its private limited partnership is billed at the end of each calendar year. Brandywine’s Performance fee for its Separately Managed Accounts is billed at the end of each calendar quarter. Additional Client Fees Charged Also in addition to the asset management and/or performance-based fee assessed to clients in any Fund or Separately Managed Account managed by Brandywine, each Fund or Account (referred to as “Account”) bears all costs and expenses directly related to its investment program, including: costs associated with specific investment transactions affected or positions held for a Account’s account including all fees and costs of the purchase of and the sale of interests in all investments of an Account; underwriting and private placements; brokerage commissions; custody fees and any withholding or transfer taxes imposed on the Account. The Account also bears all out-of-pocket costs of the administration of an Account, including accounting, audit and legal expenses, research and research-related expenses, and costs associated with reporting and providing information to existing and prospective Account investors. An Account’s operator may, however, in its sole discretion, choose to absorb any such expenses incurred on behalf of the Account. The above list and description of costs and investments that an Account may bear is not complete. Thus, investors should refer to the offering document for each Account for a complete description and list of costs and expenses that each Account may bear. For more details on the brokerage practices, see Item 12 of this brochure. External Compensation for the Sale of Securities to Clients Brandywine does not receive any external compensation for the sale of securities to clients, but investment advisor representatives of Brandywine may receive commissions for the sale of securities as registered representatives of unaffiliated broker dealers. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. As registered representatives, investment advisor representatives of Brandywine do not charge advisory fees for the services offered through unaffiliated broker dealers. This conflict is mitigated by the fact that investment advisor representatives of Brandywine have a fiduciary responsibility to place the best interest of the client first and clients are not required to purchase any products or services. Clients have the option to purchase these products through another registered representative of their choosing.

Investment Programs Brandywine is a specialist firm, offering investment advisory services built around its “Return Driver” and “Risk Replacement” models. These include the Brandywine Enhanced and Target Date Funds developed for 401(k) and other qualified retirement plans, and a hedge fund and managed account program. Brandywine’s “Risk Replacement” is an investment methodology in which an underlying benchmark (such as the S&P 500 or U.S. Aggregate Bond index) exposure is maintained, but a portion of the risk of owning the index is offset with option protection and, in its original form, replaced by the lower risk of holding a smaller allocation made to Brandywine’s Return Driver Diversifier. Investment Strategy

While Brandywine’s specific investment strategy is dependent upon the investment program selected for each fund or separately managed account, Brandywine applies a common philosophy and research approach. Brandywine’s underlying philosophy is based on the belief the reduced loss can lead to increased returns over time. This has led to Brandywine using options to protect downside exposure, as well as combining multiple uncorrelated trading strategies – each designed to profit from a logical, distinct Return Driver – into a balanced and systematically executed “Return Driver Diversifier” that is structured to pay for the cost of the option protection. An example of a commonly recognized Return Driver is that of corporate earnings growth powering the long-term performance of equities. But Brandywine expands its Return Driver Diversifier well beyond that of the typical equity investor. Brandywine’s investment strategies are designed to exploit a diversity of Return Drivers based on behavioral, fundamental, arbitrage and quantitative factors. Applied to a wide range of global markets, these strategies produce returns that are uncorrelated with those of all other investment benchmarks. Material Risks The transactions in which Brandywine generally will engage involve trading risks. Growing competition in the markets as well as the development of sophisticated technology that is able to discover investment opportunities more rapidly may limit Brandywine’s ability to take advantage of opportunities in rapidly changing markets. It is possible that some of the trading strategies selected by Brandywine will not meet all of the above criteria, and that some or all of the investments selected by Brandywine will not perform as anticipated. The summary above is based upon numerous assumptions and opinions of Brandywine concerning financial markets and other matters, the accuracy of which cannot be assured. There can be no assurance that Brandywine’s investment strategy will achieve profitable results, and results may vary substantially over time. Past performance of Brandywine or its affiliates is not indicative of future results. Investors risk the loss of their entire investment. Because of the nature of Brandywine’s investment programs, a clients’ results will fluctuate from month to month and from period to period. Accordingly, clients should understand that the results of a particular period will not necessarily be indicative of results in future periods. Clients face the following investment risks and should discuss these risks with Brandywine:

Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.

Market Risk: The price of a security may drop in reaction to tangible and

intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market-wide reactions not necessarily associated with any given individual security’s underlying fundamentals or other investment characteristics. Regardless of how well individual companies or securities perform, the value of a client’s investment portfolio may decline due to deterioration within broader economic market conditions.

Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation.

Currency Risk: Non-domestic investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk.

Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.

Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value.

Dependence on key personnel: Brandywine is dependent on the services of a limited number of persons, and if the services of such key persons were to become unavailable, it could negatively affect the ability of Brandywine to provide its services.

Short-term investments: Short-term investments are typically undertaken for one year or less, and are often tactical in nature – attempting to take advantage of near- term changes in economic factors. Short-term investments may be undertaken to increase an investment portfolio’s value, but are generally undertaken to insulate it from some degree of decline in value. Short-term investing inherently requires investment or broader market timing. Poor timing can result in significant declines in investment value.

Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved.

Options Trading: Options are derivative securities. The value of an option is based upon the value of an underlying security or security index. The risks involved with trading options are that they are highly time-sensitive investments, and that price volatility is generally much higher for an option than for the underlying security on which the option contract is based. An option contract generally spans a few months, but can extend out across multiple years. The buyer or seller of an option could lose his or her entire investment, even with a correct prediction of the direction and magnitude of a price change, if the price change does not occur within the relevant time period (i.e., before the option expires). The pricing and valuation of an option contract are more complex than those of some other securities, and a particular contract’s value may not be directly correlated to the underlying security’s value. Additionally, options are less tangible than some other investments. An option is a “book-entry” only investment without a paper certificate of ownership.

Description Brandywine provides investment advice to ultra-high-net-worth individuals, corporations, and other business entities via separately managed accounts and to Collective Investment Trusts. Client relationships vary in scope and length of service. Account Minimums Brandywine requires an account minimum of $25,000,000 to open a Separately Managed Account, but reserves the right to waive the minimum at its discretion.

Sharing of Performance Separately managed account clients must be “Qualified Clients” under Rule 205-3 of the Investment Advisers Act of 1940.The underlying investors in the Funds, while not considered clients of Brandywine under the Investment Advisers Act of 1940, are persons that are "accredited investors" within the meaning of Regulation D of the Securities Act of 1933, as amended and “qualified purchasers” under Section 2(a)51 of the Investment Company Act of 1940.

The adviser will structure any performance-based fee arrangement subject to Section 205(a)(1) of the Investment Advisers Act of 1940 in accordance with the available exemptions thereunder, including the exemption set forth in Rule 205 -3 as applicable. Brandywine’s performance fees are based on a share of the profits in client accounts managed by Brandywine. Performance-based compensation aligns Brandywine’s interests with those of the client. While performance-based fees may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client, because Brandywine’s investment programs are systematic and predefined, this risk is mitigated. The Fund’s management fee is currently up to two percent (2%) per annum to be paid in advance in quarterly installments. Brandywine may also receive performance-based fees (or allocations) (generally referred to herein as performance fees). The current performancebased fee rate is up to twenty percent (20%). Brandywine may reduce or eliminate management fees and/or performance fees with respect to any Fund investor in its sole discretion, including investors that are members, principals, employees of Brandywine, or the general partner of a Fund, or relatives of such persons, and for certain large or strategic investors. Asset management fees and performance fees are calculated by the Funds’ thirdparty administrator. Brandywine will comply with Rule 205-3 of the Investment Advisers Act of 1940 regarding performance-based fees. Each investor is asked to have his/her attorney review the contractual agreement that specifies the terms and conditions of the negotiated business arrangement. Either party may terminate the contract by notifying the other party in writing in advance of termination.

Brandywine is registered as an investment adviser with the SEC.

Personal Trading

in Client Trading and

Code of Ethics Description The employees of Brandywine have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of Brandywine employees and to address conflicts that may arise. The Code defines acceptable behavior for Brandywine employees. The Code reflects Brandywine’s and its supervised persons’ responsibility to act in their clients' best interests. One area the Code addresses is when employees buy or sell securities for their personal accounts, and how to mitigate any potential conflicts of interest with our clients. Brandywine does not allow any employees to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our clients. Our policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of Brandywine may recommend any transaction in a security or its derivative to advisory clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. Our Code is based on the guiding principle that the client's interests are our top priority. Our officers, directors, advisors, and other employees have a fiduciary duty to our clients and must diligently fulfill that duty to maintain their complete trust and confidence. When a conflict arises, it is our obligation to put the client’s interests above those of employees or the company. The Code applies to “access” persons. “Access” persons are employees who have access to non- public information regarding any clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to clients, or who have access to such recommendations that are non-public. Brandywine will provide a copy of the Code of Ethics to any client or prospective client upon request. Advisory Firm Purchase of Securities Recommended to Clients and Conflicts of Interest Brandywine invests alongside clients in the same private funds managed by Brandywine and does not maintain a firm proprietary trading account to trade in individual securities. Other

than the private funds managed by Brandywine, Brandywine does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. Brandywine’s employees may buy or sell securities for their own accounts and may buy or sell securities that are also held by clients. In order to minimize conflicts of interest, Brandywine’s employees are required to disclose all reportable securities transactions as well as provide Brandywine with copies of their brokerage statements. The CCO of Brandywine is Harris Bogner. He reviews all employee trades each quarter. The personal trading reviews helps mitigate that the personal trading of employees does not affect the markets and that clients of Brandywine have received preferential treatment over employee trades.

Factors Used to Select Broker-Dealers for Client Transactions Pursuant to SEC interpretations of the Investment Advisers Act of 1940, Brandywine has a fiduciary obligation to obtain best execution of customers' transactions under the circumstances of the particular transaction. Brandywine will consider the full range and quality of the broker's services in placing a trade with that broker, including, among other things, the value of services provided as well as execution capability, commission rate, financial responsibility, and responsiveness to the adviser. The determinative factor is not necessarily the lowest possible commission cost, but whether the transaction represents the best qualitative execution for the managed account. Brandywine may recommend the use of a particular broker-dealer for securities transactions or Futures Commission Merchant (“FCM”) for futures transactions or may utilize a broker dealer or FCM of the client's choosing (“brokers” or “custodians”’). Brandywine will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees, ability to accept electronic orders from Brandywine, market coverage and reporting ability. Brandywine relies on its brokers to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all brokerage fees in addition to the advisory fees charged by Brandywine. Aggregating Securities Transactions for Client Accounts Brandywine may aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of Brandywine. All clients participating in the aggregated order shall receive an allocation based on a systematic, pre-arranged process designed to provide a comparable transaction price over time, with all other transaction costs shared on a pro-rated basis.

On occasion, Brandywine will make presentations to brokers and other selling agents in an effort to have such parties recommend to their own clients that they become clients of Brandywine or invest in Brandywine’s Funds. Brandywine has a conflict of interest because selecting such brokers or selecting brokers who have already referred clients to Brandywine, to effect client transactions may encourage the referral of new clients by the brokers or their employees and registered representatives. This creates an incentive for Brandywine to direct more brokerage to such brokers in an effort to generate future referrals or obtain additional contributions. This incentive conflicts with Brandywine’s duty to select brokers consistent with its duty to obtain best execution. Brandywine believes that it has developed adequate policies and procedures to monitor its selection of brokers who have referred or may refer clients to Brandywine. Brandywine may agree to share a portion of the management fees or net new profits otherwise allocable to it with persons who intro Brandywine may agree to share a portion of the management fees or net new profits otherwise allocable to it with persons who introduce clients to Brandywine or a subscriber to Brandywine-managed private Fund. Any commissions and/or placement fees will only be paid to persons who are registered as a broker-dealer under the Securities Act of 1934 or appropriately exempt therefrom.

Criminal or Civil Actions Brandywine and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings Brandywine and its management have not been involved in administrative enforcement

proceedings. Self-Regulatory Organization Enforcement Proceedings Brandywine’s management has not been involved in legal or disciplinary events related to past or present investment clients. Brandywine agreed to pay National Futures Association (“NFA”) $35,000 in 2007, without admitting or denying the allegation that Brandywine failed to timely file annual reports with NFA.

Schedule for Periodic Review of Client Accounts Brandywine performs quarterly account reviews for each fund and account it m a n a g e s . This includes:

calculation of risk and performance,

determination that client accounts are being managed in line with each program’s design, and

potential changes that could be made to further benefit clients.

Clients in Brandywine’s private funds also receive a monthly report summarizing the

performance of their account. In addition, Brandywine makes an effort to ensure that, ninety (90) days after the end of each fiscal year, each investor in a fund is furnished with certified audited financial statements of the respective fund and to provide to investors any fund related tax information necessary for the preparation of the investors’ income tax returns. Content of Client Provided Reports and Frequency Clients in private funds managed by Brandywine receive written account statements monthly. Private fund account statements are issued by each fund’s third-party administrator. Separately managed account clients receive statements from Brandywine no less than quarterly. Managed account clients receive confirmations of each transaction in their account from the custodian and an additional statement during any month in which a transaction occurs.

Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to the performance reports prepared by Brandywine or each private fund’s third-party administrator. Pursuant to Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended, Brandywine

satisfies its custody obligations by ensuring that all Funds are audited as required by the rule and that investors in the Funds receive the financial statements resulting from such audits as required.

Discretionary Authority for Trading Brandywine accepts discretionary authority to manage securities accounts on behalf of clients. Brandywine has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The client will authorize Advisor discretionary authority to execute selected investment program transactions as stated within Brandywine’s Advisory Agreement. The client approves the custodian to be used and the commission rates paid to the custodian. Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian.

Proxy Votes Brandywine does not vote proxies on securities held by clients in separately managed accounts, nor does it provide voting recommendations to clients. Clients are expected to vote their own proxies. The client will receive their proxies directly from the account custodian or a transfer agent.

A registered investment adviser is required to provide you with certain financial information or disclosures about its financial condition. Brandywine has no financial commitments that impair its ability to meet contractual and fiduciary obligations to clients, and it has not been the subject of a bankruptcy proceeding.

Brochure Supplement Part 2B of Form ADV Michael P. Dever, CFP® June 2026

Item 1 Cover Page

The Mill 381 Brinton Lake Road Suite 5 Thornton, PA 19373 Telephone:610.361.1000 Email: mike@brandywine.com Website: www.brandywine.com

This brochure supplement provides information about Michael Dever and supplements the Brandywine Asset Management, Inc. brochure. You should have received a copy of that brochure. Please contact Michael Dever or Harris Bogner if you did not receive the brochure or if you have any questions about its contents. Additional information about Michael Dever (CRD #1384212) is available on the SEC’s website at www.adviserinfo.sec.gov

Michael P. Dever, CFP® Year of birth: 1957 Item 2 Educational Background and Business Experience Educational Background: • West Chester University; Bachelor of Science – Business; 1981 Business Experience:

Brandywine Asset Management, Inc. - Founder & CEO; 1982 – Present Ignite Publications, Inc. - Founder & CEO; 2010 – Present Spree.com LLC - Founder & CEO - 1996 – 1999 Mind Drivers LLC - Co-founder & CEO; 1999 – 2009 Internetseer, Inc. - Co-founder & CEO; 1999 – 2006 Brandywine Securities, Inc. - Founder & CEO; 2004 – 10/2013

Item 3 Professional Certifications The employee has earned certifications and credentials that r e q u i r e further explanation. The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:

Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance and risk management, employee benefits, investment, income tax, retirement, and estate planning.

Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered over 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to realworld circumstances.

Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and

Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals.

Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks:

Continuing Education – Complete 30 hours of continuing education every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and

Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in their clients' best interests.

CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Item 4 Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. SelfRegulatory Proceeding: None to report. Item 5 Other Business Activities In February 2026, Brandywine applied to become a member of the National Futures Association (NFA) and to be registered as a Commodity Trading Adviser (CTA) and Commodity Pool Operator (CPO). The status is still pending and anticipated to be effective in Q2 2026. Michael Dever devotes substantially all his business time to his activities at Brandywine and is not actively involved in other business activities. Item 6 Additional Compensation Michael Dever does not receive any significant compensation from any business activity unrelated to Brandywine. Item 7 Supervision Michael Dever is supervised by the CCO, Harris Bogner, regarding the policies and procedures described in Brandywine’s compliance manual and code of ethics. Mr. Bogner can be reached by telephone at (917) 376-0144.