Bridgeway Capital Management

Bridgeway Capital Management, LLC (“Bridgeway”), headquartered in Houston, Texas since 1993, offers intelligently designed investment strategies primarily to institutions and clients of financial advisors. Bridgeway is the investment adviser to Bridgeway Funds, Inc., an SECregistered investment company, and other clients. Bridgeway offers discretionary portfolio management services to institutions, registered investment companies (“mutual funds” or “funds”), exchange traded funds (“ETFs”), high net worth individuals, pension and profit sharing plans, corporations, trusts, estates, charitable/nonprofit organizations, collective investment trusts, domestic and offshore private (unregistered) investment companies (“private funds”), and government entities. Bridgeway believes that a disciplined, statistical process – grounded in academic theory and fundamental data over long periods of time – drives success in long-term investing. As such, Bridgeway applies a statistical, evidence-based approach to money management across a wide range of equity categories. A team of dedicated and talented staff oversee the development and maintenance of Bridgeway’s statistical models which drive stock selection within each portfolio. All portfolios are constructed with the goal of providing superior risk-adjusted returns over a complete market cycle. With the exception of the Emerging Markets Small-Cap and Emerging Opportunities and certain proprietary account strategies, Bridgeway’s investment process also considers material environmental, social, and governance (“ESG”) information, when available. While Bridgeway makes all investment decisions on clients’ behalf, Bridgeway does permit clients to impose restrictions on investing in certain securities or other limitations as mutually agreed upon. All accounts are subject to a written investment advisory agreement which describes our discretionary authority, any investment limitations, investment objectives, fees and other matters. Assets Under Management as of December 31, 2025 Discretionary: $ 4,248,811,967 Non-Discretionary: $0 Bridgeway is organized as a Delaware limited liability company and is privately owned and independent. Bridgeway is a wholly-owned subsidiary of Bridgeway Investments, Inc. (formerly known as BCM Scorp Holdco, Inc.), a Texas S Corporation. John Montgomery, Founder, President, Chief Executive Officer, and Portfolio Manager, holds a controlling ownership interest in Bridgeway Investments, Inc. and non-controlling interests are held (either directly or indirectly) by other Bridgeway Partners (through the Partner Stock Ownership Plan, a limited liability company, and other equity plans), a special purpose trust, and other parties related to John Montgomery. Bridgeway’s ownership succession plan is designed to keep the firm private and independent into perpetuity. This plan is designed to provide stability and continuity for clients, colleagues and community objectives with management control remaining in the hands of

contemporaneous partners.

General Fee Information Bridgeway charges clients an advisory fee based either on a percentage of the account’s market value (“asset-based fee”) or a combination of asset-based and performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Asset-based fees are typically billed quarterly in advance, while performance-based fees are billed quarterly in arrears. Fees are pro-rated for partial periods. Performance-based fees are based on the performance of the account relative to a stock market index or a hurdle rate. Fees are deducted directly from client accounts or paid directly based on client written direction. In either situation, clients typically receive an invoice based on the frequency described above as part of the standard reporting package. Fees are negotiable under certain circumstances such as size and complexity of the account. Clients separately incur custody fees and brokerage and transaction costs. (Please see Item 12 for additional information on brokerage practices.) If a mutual fund or ETF is held in a client account, the client will separately incur fund expenses and fees. In certain instances, Bridgeway may recommend clients purchase and sell mutual funds or ETFs for which Bridgeway serves as investment adviser or sub-adviser. Client assets invested in these funds and/or ETFs within an account that Bridgeway manages are not subject to the advisory fee otherwise applicable to the account. Those assets are subject only to the mutual fund’s and/or ETFs’ expenses and fees applicable to all shareholders in the fund or ETF, as set forth in the applicable prospectus. However, such funds and ETFs pay Bridgeway an advisory fee which is a fund/ETF expense. Depending on which fund/ETF the account is invested in, the fees may be more or less than the separate account advisory fee otherwise applicable to the account. Because clients pay different fees based on differing fee schedules and/or the size of the account, Bridgeway maintains investment, trade allocation and account valuation (including fair valuation) policies and procedures designed to address conflicts of interest related to such differences. Further, investment performance return dispersion is reviewed regularly by the Best Execution Committee to reasonably ensure certain clients are not favored over other clients. A client, other than mutual fund clients, ETF clients and private funds, who wishes to terminate the investment advisory agreement must give 30 days’ written notice. Upon termination of the investment advisory agreement, net fees earned through the final day will be due and payable in accordance with the client’s investment advisory agreement and/or governing documents.

Fee Schedules For the strategies identified in the table below Bridgeway charges clients a fee based solely on the assets under management, subject to minimum annual fees per account. The information below shows Bridgeway’s standard separate account fee schedule, account asset minimum, and minimum annual fee for each strategy. All fees and minimums are subject to negotiation. Strategy Emerging Markets Small-Cap Aggressive Investors 1 Ultra-Small Company Market Small-Cap Value Omni Small-Cap Value Blue Chip

<$50M $50-$100M >$100M 1.25% 1.50% 0.70% 0.75% 0.70% 0.20%

1.25% 1.50% 0.65% 0.65% 0.65% 0.15%

1.25% 1.50% 0.60% 0.60% 0.60% 0.15%

Account Asset Minimum $10 million $10 million $10 million $10 million $25 million $50 million

Minimum Annual Fee $125,000 $150,000 $70,000 $75,000 $175,000 $100,000

For clients invested in separate accounts in the Emerging Opportunities strategy, Bridgeway charges clients an asset-based fee of 1.50% per year and performance-based fees. Performancebased fees amount to 20% of the account value exceeding the perpetual high-water mark at the end of the calculation period. The high-water mark is defined as the account’s value at the last crystallization of performance fees. The fee structure does not include a clawback provision. More specific information regarding the calculation of performance-based fees is included in each client’s investment advisory agreement. For clients invested in separate accounts in the Global Opportunities strategy, Bridgeway charges clients an asset-based fee of 1.50% per year and performance-based fees. Performance-based fees amount to 15% of the account value exceeding the perpetual high-water mark at the end of the calculation period. The high-water mark is defined as the account’s value at the last crystallization of performance fees. The fee structure does not include a clawback provision. More specific information regarding the calculation of performance-based fees is included in each client’s investment advisory agreement. Clients invested in the Aggressive Investors 1 strategy prior to April 2024 pay an asset-based fee and a performance-based fee. Clients investing beginning April 2024 in the Aggressive Investors 1 strategy pay fees as described above. Please see Item 6 for additional information regarding performance-based fee arrangements. Although the intent of the performance-based fees is to align Bridgeway’s interests with clients, there are conflicts of interest present when charging performance-based fees as Bridgeway has an incentive to make riskier, more speculative investments than would be the case in the absence of

these fees. At the same time, Bridgeway has an incentive to avoid making riskier, more speculative investments that could decline in value resulting in lower fees. Bridgeway manages all mutual funds under Bridgeway Funds, Inc. (“Bridgeway Funds”) with different management fees than those described above. Please reference the Bridgeway Funds’ Prospectuses and Statements of Additional Information for further information regarding management fees and other Bridgeway Fund fees and expenses. Bridgeway is the investment adviser to certain private funds. The minimum required investment amounts, advisory fees and performance fees, as applicable, charged by Bridgeway are disclosed in each private fund’s offering materials. Bridgeway is the sub-adviser to certain ETFs. Bridgeway provides discretionary portfolio management services to such ETFs in exchange for a sub-advisory fee which is calculated daily and paid monthly by the ETFs’ investment adviser based on the ETFs’ average daily net assets. Additionally, Bridgeway has entered into a fund sponsorship agreement with the ETFs’ investment adviser in which it has agreed to provide financial support to the ETFs in exchange for a portion of the profits generated by the advisory fee which is calculated and paid to the ETFs’ investment adviser. Account Valuation Practices Bridgeway uses account market values to calculate investment performance and client fees where applicable. ICE Data Services (“ICE”), a third-party security pricing vendor, provides security prices for account valuation purposes. For securities listed on a U.S. exchange, ICE provides a daily price as outlined in Bridgeway’s pricing and valuation procedures. For such securities, if prices are not readily available, or Bridgeway does not consider the price provided by ICE accurate, Bridgeway will fair value the security in accordance with the methodology outlined in Bridgeway’s pricing and valuation procedures. Bridgeway’s fair valuation of a security listed on a U.S. exchange is relatively limited, with generally less than 1% of assets in clients’ accounts managed in a U.S. strategy fair valued at any point in time. For equity securities listed on a foreign exchange held in private funds managed by Bridgeway, ICE’s Fair Value Information Service provides a fair valuation at month end. When the ICE Fair Value Information Service is not able to provide a value, for example when trading has halted for a security, Bridgeway will determine the fair value in accordance with the methodology outlined in Bridgeway’s pricing and valuation procedures. The Absolute Return strategies managed by Bridgeway invest in long and short swaps of foreign and/or U.S. securities that are traded in the over-the-counter market. Valuations for the long and short swap contracts are provided to Bridgeway by the prime broker utilized for these strategies. For proprietary accounts managed in these strategies, when market quotations of the underlying equity securities are not readily available or when events occur that make established valuation methods unreliable, the underlying securities are valued at fair value as determined by the prime

broker which may include valuing the underlying security at the last quoted price. See Item 8 for more information on Absolute Return strategies. There are conflicts of interest present when valuing securities for client accounts since Bridgeway has an incentive for security prices to be high to increase market values thereby increasing investment performance and advisory fees. Bridgeway maintains investment, trade allocation and account valuation (including fair valuation) policies and procedures designed to address such conflicts of interest. Bridgeway’s Pricing Committee is responsible for providing oversight of valuation matters.

Bridgeway uses statistical analyses and models to select investments for client accounts. Any imperfections, errors or limitations in the models or analyses and therefore any decisions made in reliance on such models or analyses could expose accounts to potential risks. In addition, the models used by Bridgeway assume that certain historical statistical relationships will continue. These models are constructed based on historical data supplied by third parties and, as a result, the success of relying on such models depend heavily on the accuracy and reliability of the supplied historical data. These models seek to identify both fundamentally and technically undervalued securities.

With the exception of the Emerging Markets Small-Cap and Emerging Opportunities and certain proprietary account strategies, Bridgeway’s investment process considers material environmental, social, and governance (“ESG”) information, when available, in the ongoing assessment of potential portfolio securities. Bridgeway uses ESG research and/or ratings information provided by third parties in performing this analysis and considering ESG risks. As with any consideration used in assessing portfolio securities, Bridgeway may, at times, utilize ESG information to increase the weighting of an issuer with a good ESG record or decrease the weighting of an issuer with a poor ESG record. However, as ESG information is just one investment consideration, ESG considerations are not solely determinative in any investment decision made by Bridgeway. ESG information for ultra-small companies may be limited, although Bridgeway’s investment process incorporates this information when available. For the U.S. strategies Bridgeway excludes stocks based on certain narrow social reasons including, but not limited to, if the issuer of the stock: (i) conducts or has direct investments in business operations in Sudan; (ii) is principally engaged in the tobacco industry; (iii) is substantially engaged in the production or trade of pornographic material. The number of such companies in Bridgeway’s U.S. equity universe is typically “de minimis.” Generally, client accounts are managed in accordance with a specific investment strategy, as described below. Clients should understand that investing in securities involves risk of loss that clients should be prepared to bear. Please also reference the Bridgeway Funds’ Prospectus and Statement of Additional Information for further information regarding the investment strategies, restrictions and risks related to the Bridgeway Funds that are offered in the strategies described below. The strategies, and risks related to those strategies, offered in private funds are disclosed in each private fund’s offering materials. International Strategies:

Emerging Markets Small-Cap – Bridgeway’s Emerging Markets Small-Cap strategy seeks to deliver excess returns above the MSCI Emerging Markets Small Cap Index (net) (the “Benchmark”) over a full market cycle. Bridgeway defines a full market cycle as a six to eight-year period. There is no guarantee that this objective will be achieved. The strategy seeks to achieve its investment objective by investing in an actively managed portfolio consisting primarily of equity securities of small sized companies in emerging markets as well as securities that are domiciled or have a significant portion of their business active in emerging markets. The investment strategy focuses on systematic application of fundamental analysis for companies in the MSCI Emerging Markets Investable Market Index (the “Index”). Bridgeway selects securities based on a systematic approach that considers fundamental measures such as value (e.g., price-to-earnings ratio), indicators of quality (e.g., return on equity), and sentiment (e.g., estimate revisions). Specific measures are applied based on an adaptive categorization of the type of company based on a proprietary definition of capital intensity. The categorization of securities considered for the strategy may be adjusted based on Bridgeway’s analysis of externalities, such as (but not limited to) rapid changes to regulations impacting the industry, leadership

transitions, or market volatility due to election outcomes or other externalities that could impact a company’s outlook. A differentiated approach to portfolio construction driven by risk analysis relative to the Benchmark is also a key element of the investment strategy. Emerging markets are those countries that are classified by MSCI as emerging markets and generally consist of those countries with securities markets that are less sophisticated than more developed markets in terms of participation, analyst coverage, liquidity and regulation. These are markets which have yet to reach a level of maturity associated with developed foreign stock markets, especially in terms of participation by investors. Some emerging market countries may be considered to be “frontier market” countries. The emerging markets small-cap strategy is speculative and entails a high degree of risk. These risks are in addition to the usual risks inherent in U.S. investments. There is the possibility of expropriation, nationalization, or confiscatory taxation, taxation of income earned in foreign nations or other taxes imposed with respect to investments in foreign nations, foreign exchange control (which may include suspension of the ability to transfer currency from a given country), default in foreign government securities, political or social instability, or diplomatic developments which could affect investments in securities of issuers in those nations. In addition, the risks associated with foreign investments are heightened when investing in emerging markets. The government and economies of emerging markets feature greater instability than those of more developed countries. Such investments tend to fluctuate in price more widely and to be less liquid than other foreign investment. Investments in small companies generally carry greater risk than is customarily associated with larger companies. This additional risk is attributable to a number of reasons, including the relatively limited financial resources that are typically available to small companies, and the fact that small companies often have comparatively limited product lines. In addition, the stock of small companies tends to be more volatile and less liquid than the stock of large companies, particularly in the short term and particularly in the early stages of an economic or market downturn. Absolute Return Strategies:

Emerging Opportunities – The Emerging Opportunities strategy pursues its investment objective by applying fundamental and sentiment analysis contextually. The strategy seeks to achieve its exposure by investing in an actively managed portfolio consisting primarily of long and short swaps of securities exposed to emerging markets economies. The strategy may invest directly in the underlying securities. Investment themes and investment universes may be added opportunistically. The categorization of underlying securities considered for the strategy may be adjusted based on Bridgeway’s analysis of externalities, such as (but not limited to) rapid changes to regulations impacting the industry, leadership transitions, or market volatility due to election outcomes or other externalities that could impact a company’s outlook. The strategy is generally intended to have a low correlation to the equity markets and is not designed to match the performance of any hedge fund index. Bridgeway seeks to mitigate risk through diversification of holdings and through active monitoring of volatility, counterparties and other risk measures. There is no

assurance, however, that these risks will be mitigated nor that the strategy will achieve its investment objective. Short selling is intended to create a profit based on declines in the price of securities being sold short, however, there is no guarantee the price of a security being sold short will decline and in fact short selling creates potentially unlimited risk of loss because there is no limit to how high the price of the security may rise. Please see foreign and emerging market risk disclosures in the Emerging Markets Small-Cap description above.

Global Opportunities – The Global Opportunities strategy pursues its investment objective by applying fundamental and sentiment analysis contextually. The strategy seeks to achieve its exposure by investing in an actively managed portfolio consisting primarily of long and short swaps of securities in the emerging markets, developed markets and U.S. markets. The strategy may invest directly in the underlying securities. Investment themes and investment universes may be added opportunistically. The categorization of underlying securities considered for the strategy may be adjusted based on Bridgeway’s analysis of externalities, such as (but not limited to) rapid changes to regulations impacting the industry, leadership transitions, or market volatility due to election outcomes or other externalities that could impact a company’s outlook. The strategy is generally intended to have a low correlation to the equity markets and is not designed to match the performance of any hedge fund index. Bridgeway seeks to mitigate risk through diversification of holdings and through active monitoring of volatility, counterparties and other risk measures. There is no assurance, however, that these risks will be mitigated nor that the strategy will achieve its investment objective. Short selling is intended to create a profit based on declines in the price of securities being sold short, however, there is no guarantee the price of a security being sold short will decline and in fact short selling creates potentially unlimited risk of loss because there is no limit to how high the price of the security may rise. Please see foreign and emerging market risk disclosures in the Emerging Markets Small-Cap description above and U.S. market risks described below.

U.S. Strategies:

Aggressive Investors 1 – Bridgeway’s Aggressive Investors 1 investment strategy seeks to provide long-term toral return on capital, primarily through capital appreciation . Under this approach, Bridgeway invests in U.S. companies of all sizes and holdings spanning various styles including growth and value stocks. Bridgeway selects stocks using a statistical approach to identify stocks with a lower probability of price decline over the long term, though the stock price may be more volatile in the short-term. Bridgeway generally selects companies to provide strong portfolio exposure to Quality (e.g., high profit margins and stable earnings), Value (e.g., low valuation multiples), and Sentiment (e.g., positive estimate revisions or price momentum) factors . Investments in small companies generally carry greater risk than is customarily associated with larger companies. This additional risk is attributable to a number of factors, including the relatively limited financial resources that are typically available to small companies, and

the fact that small companies often have comparatively limited product lines. In addition, the stock of small companies tends to be more volatile and less liquid than the stock of large companies, particularly in the short term and particularly in the early stages of an economic or market downturn. The strategy may invest in a smaller number of companies, which will likely add to volatility. The strategy may invest in foreign securities. Investment in foreign securities can be more volatile than investments in U.S. securities. The strategy engages in frequent trading, which could result in higher trading costs and for investors in taxable accounts, a higher tax burden. Leverage created from borrowing may impair the strategy’s liquidity, cause it to liquidate positions at an unfavorable time, increase volatility or otherwise not achieve its intended objective. However, Bridgeway considers the use of these strategies as conservative. Nevertheless, investors may be taking on more risk than they would otherwise if they invested in the stock market as a whole.

Ultra-Small Company – Bridgeway’s Ultra-Small Company strategy seeks to provide long-term capital appreciation. The benchmark for this strategy is the Russell Microcap Index. For purposes of this strategy, Bridgeway defines ultra-small as those companies with a market capitalization of less than $1 billion at the time of purchase. Bridgeway generally seeks to construct a portfolio of companies within the smallest 20% of U.S.-listed stocks. Bridgeway selects companies to provide strong portfolio exposure to Quality (e.g., high profit margins and stable earnings), Value (e.g., low valuation multiples), and Sentiment (e.g., positive estimate revisions or price momentum) factors. Investments in ultra-small companies generally carry greater risk than is customarily associated with large, small and even micro-cap company shares. This additional risk is attributable to a number of factors, including the relatively limited financial resources that are typically available to ultra-small companies, and the fact that ultra-small companies often have comparatively limited product lines. In addition, the stock of ultra-small companies tends to be more volatile and less liquid than the stock of large companies, particularly in the short term and particularly in the early stages of an economic or market downturn. The strategy may engage in active and frequent trading, which could result in higher trading costs and for investors in taxable accounts, a higher tax burden. The strategy may purchase stock market index futures and ETFs, in order to equitize cash. The strategy may invest in foreign securities. Investment in foreign securities can be more volatile than investments in U.S. securities. This strategy is only available as a mutual fund.

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Bridgeway provides investment management services to institutions, mutual funds, ETFs, high net worth individuals, pension and profit sharing plans, corporations, trusts, estates, charitable/nonprofit organizations, collective investment trusts, private funds, government entities and model manager accounts. All clients are required to enter into an investment advisory agreement prior to Bridgeway providing any services. Client account minimums are disclosed in Item 5. Bridgeway also manages separate accounts for family members of staff. These clients receive standard client reporting and are not involved in day-to-day operations of the firm. Bridgeway maintains investment, trade allocation and account valuation (including fair valuation) policies and procedures designed to address such conflicts of interest. Further, investment performance return dispersion is reviewed regularly by Bridgeway’s Best Execution Committee to reasonably ensure that certain clients are not favored over other clients. Although Bridgeway does not manage separate accounts for individual staff members, the firm does have investments in the mutual funds, ETFs and private funds that Bridgeway manages and staff members are permitted to invest in the mutual funds, private funds and ETFs Bridgeway manages. Bridgeway manages proprietary accounts involving global and international strategies (also referred to as, Absolute Return) including the Emerging Opportunities strategy, which is offered to clients, as well as other Absolute Return strategies that are not currently offered to clients. Please see Item 12 for a description of the conflicts of interest associated with the overlap of securities between proprietary and client accounts as well as Bridgeway’s investment allocation and trade allocation policies and procedures related to such practices. Bridgeway maintains investment and trade allocation policies and procedures designed to address conflicts of interest related to these accounts. Please see Item 11 for a discussion of Bridgeway’s Code of Ethics and Personal Trading Policy, which requires staff members to preclear investments in private funds Bridgeway manages and report investments in the private funds and mutual funds, including subadvised mutual funds and ETFs that Bridgeway manages.

As discussed in Item 5 above, Bridgeway charges certain clients both asset-based and performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Because Bridgeway utilizes both fee structures and in certain situations clients in the same strategy may be charged both fee structures or only an asset-based fee, portfolio managers are responsible for accounts and/or strategies with either or both fee structures. Such arrangements create an implied incentive to favor the performance-based fee accounts over asset-based fee accounts in order to earn the highest possible compensation; however, based on the structure of Bridgeway’s performance-based fee arrangements, the opposite may also be true. Bridgeway maintains investment, trade allocation and account valuation (including fair valuation) policies and procedures designed to address potential conflicts of interest associated with side-by-side management to reasonably ensure certain clients are not favored over other clients. Further, investment decisions are triggered by statistical models, thus removing some of the subjectivity to Bridgeway’s investment process. Bridgeway only charges a performance-based fee to clients who are qualified to be charged such a fee. Clients who are eligible to be charged a performance-based fee are generally defined as: Individuals or companies that have a least $1,400,000 under management with Bridgeway immediately after entering into the contract (SEC rule mandates excluding the value of investor’s home from the net worth calculation):

Individuals or companies that Bridgeway reasonably believes have a net worth of more than $2,700,000; or

Individuals who immediately before entering into a contract are either: (1) executive officers, directors, trustees, general partners or hold similar positions with Bridgeway; or (2) Bridgeway staff who have participated in Bridgeway’s, or another company’s investment functions for at least one year.

Bridgeway provides investment management services to a proprietary mutual fund family, the Bridgeway Funds. Bridgeway also provides certain administrative services to the Bridgeway Funds for which the firm is paid an annual fee. Certain Bridgeway staff members are registered representatives of Foreside Fund Services, LLC, Bridgeway Funds’ unaffiliated distributor. Some officers also have roles with Bridgeway Funds, while other staff members of Bridgeway perform certain activities on behalf of the Bridgeway Funds, which could create conflicts of interest due to competing priorities. Bridgeway maintains investment and trade allocation policies and procedures and a Code of Ethics and Personal Trading Policy, which outlines standards of conduct, to address such conflicts of interest. The following is a list of the Bridgeway Funds:

Global Opportunities Fund Ultra-Small Company Fund

Omni Small-Cap Value Fund

In addition, Bridgeway provides investment management services to ETFs on a sub-advised basis.

Standards of Conduct Bridgeway maintains a Code of Ethics and Personal Trading Policy (“Code”) which applies to all staff, officers and directors of Bridgeway. As a fiduciary, Bridgeway has a duty of utmost good faith to act solely in the best interests of each of our clients. Bridgeway’s fiduciary duty comprises a duty of care and a duty of loyalty. The duty of care requires Bridgeway to (a) provide investment advice in the best interest of its clients, based on each client’s objectives; (b) seek best execution of clients’ transactions; and (c) provide advice and monitoring over the course of the client relationship. The duty of loyalty requires Bridgeway to: (a) make full and fair disclosure of all material facts relating to the advisory relationship; and (b) eliminate or mitigate and make full and fair disclosure of all conflicts of interest. This fiduciary duty compels all staff members to act with the utmost integrity in all dealings. Bridgeway believes the firm’s commitment to integrity will contribute to better investment performance, service and efficiency and all staff members look for ways to challenge each other positively to meet this ideal. The Code outlines the standards of conduct expected of staff members and includes limitations on personal trading, the giving and acceptance of gifts and entertainment, political and charitable contributions, serving as a director or trustee for an external organization, and engaging in outside business activities. In addition, staff members are prohibited from using nonpublic information to trade in personal accounts or on behalf of clients including trading on nonpublic information related to any mutual fund, ETF or private fund managed by Bridgeway. Bridgeway also maintains physical and electronic safeguards to protect nonpublic client information while in the firm’s possession and upon destruction. Staff members are required to report promptly any violation of the Code (including the discovery of any violation or suspected violation committed by another staff member) to the Chief Compliance Officer (“CCO”) or designee. A copy of the Code is available upon request. Personal Trading Bridgeway requires staff members to pre-clear personal securities transactions. In addition, the Code requires staff members to report certain security holdings initially upon being hired and annually thereafter. Finally, staff members are required to report personal transactions to the CCO on a quarterly basis.

Staff members may not execute a transaction in a security (including the underlying security for any long or short swap contract), except for shares of a mutual fund Bridgeway advises or subadvises, that Bridgeway: (1) is purchasing or selling in client accounts; (2) has recommended for purchase or sale in client accounts; (3) has decided to purchase or sell in client accounts, but has not yet made the recommendation; or (4) has a current model buy or sell signal, but has not yet made a final decision. Additionally, staff members may not purchase or sell derivatives or options when a personal security transaction in its underlying security would be denied, regardless of whether or not the derivatives or options are being traded by the firm. Staff members may not purchase and sell or sell and purchase the same or equivalent securities, including advised funds or sub-advised funds within 60 calendar days. Staff members may not sell Bridgeway Funds or ETFs and mutual funds sub-advised by Bridgeway from November 1st until one business day after the dividend record date for each applicable fund. Staff members may not engage in excessive personal trading, or any other personal trading that interferes with duties for clients, as determined by the CCO and/or Bridgeway’s President. Further, Investment Management Team members (excluding traders) are subject to additional personal trading restrictions outlined within the Code. Staff members are permitted to invest in mutual funds, ETFs and private funds where Bridgeway serves as adviser or sub-adviser. This creates an incentive for Bridgeway to put the interests of the mutual funds, ETFs and private funds ahead of other clients. However, the Code requires staff members to put clients’ interests ahead of their own and to report personal transactions and holdings in mutual funds, ETFs and private funds managed by Bridgeway to the CCO in accordance with the reporting requirements described above.

Bridgeway’s Best Execution Committee provides oversight of investment, trading and brokerage policies and practices. In addition, Bridgeway maintains investment, trading, and brokerage policies and procedures. The following is an overview of trading and brokerage practices, policies and procedures when Bridgeway is responsible for trade execution. Selection of Brokers for U.S. Strategies Bridgeway utilizes traditional brokers as well as Execution Management Systems (“EMS”) which offer traders the ability to access liquidity through algorithms and smart order routing across a wide spectrum of venues including major exchanges, dark pools, alternative trading systems and crossing networks, to execute trades on clients’ behalf. Bridgeway has established the Best Execution Committee to monitor and evaluate the quality of execution received from brokerdealers executing transactions on behalf of clients and to oversee trading practices and procedures. In selecting broker-dealers, Bridgeway attempts to obtain the best execution available for each transaction, which may not result in the client paying the lowest fees and expenses. However, Bridgeway seeks low fees and expenses. In seeking best execution, Bridgeway considers the quality of overall execution services provided by the broker, speed of execution, promptness and

accuracy of oral, hard copy or electronic reports of execution, the market where the security trades, any expertise the broker has in executing trades for the particular type of security, commission charged by the broker, reliability of the broker, size of the order, whether the broker can respond during volatile market periods, the broker’s ability for customization of EMS and algorithms and strong technical support. Selection of Brokers for International Strategies All trades for the Emerging Markets Small-Cap strategy are placed in baskets with Bridgeway’s prime broker. Prior to use, any new EMS or broker-dealer for the EMSC strategy will be reviewed by appropriate members of the Investment Management Team for quality, ease of use, functionality, support, clearing and price. Additionally, foreign securities in the Emerging Markets Small-Cap strategy are typically purchased and sold in their local currencies so daily currency transactions are executed to convert to the applicable local market currency. BCM utilizes BNY Mellon to manage and execute foreign currency transactions. Bridgeway’s Best Execution Committee is responsible for monitoring and evaluating the quality of execution of transactions received from the broker-dealer and foreign currency transactions from the custodian and to oversee trading practices and procedures. Selection of Brokers for Absolute Return Strategies Bridgeway utilizes an EMS to trade for the Absolute Return strategies which includes the Emerging Opportunities strategy, Global Opportunities strategy and certain proprietary accounts. All trades for the Absolute Return strategies are placed in baskets and sent to Bridgeway’s prime broker who packages the underlying securities into long and short total return swaps based on instructions from Bridgeway. Prior to use, any new EMS or broker-dealer for the Absolute Return strategies will be reviewed by appropriate members of the Investment Management Team for quality, ease of use, functionality, support, clearing and price. Bridgeway’s Best Execution Committee is responsible for monitoring and evaluating the quality of execution of transactions received from the broker-dealer and foreign currency transactions from the custodian and to oversee trading practices and procedures. Soft Dollars Bridgeway does not engage in pre-arranged soft dollar arrangements, which are formal arrangements where an investment adviser directs portfolio brokerage commissions to a brokerdealer in return for brokerage or research services that may be used in making investment decisions for clients. Bridgeway, however, does receive the benefit of research services provided by brokerdealers, such as invitations to conferences or general research and brokerage services such as

execution management systems or trade analytic tools. While Bridgeway is permitted under the 28(e) safe harbor to consider research and brokerage services provided in allocating brokerage to a specific broker, this is not a consideration as a practical matter as Bridgeway allocates brokerage on the basis of execution quality and other factors described in Bridgeway’s Best Execution Policy. The research and brokerage services received, as described in this policy, will not be used solely for the accounts that generated the brokerage commission, but will generally be used in managing all client accounts. Brokerage for Client Referrals Bridgeway does not consider a broker-dealer’s sale of mutual fund shares when determining whether to select such broker-dealer to execute transactions for mutual fund clients. In addition, Bridgeway does not select or recommend broker-dealers (i.e., direct brokerage to broker-dealers) in consideration for any client referrals (if any) from broker-dealers or other third parties. Broker/Custodian Arrangement Certain clients have elected to establish brokerage accounts with a designated brokerage firm (“broker/custodian”) to maintain custody of their assets and to effect trades for their accounts. Bridgeway is not affiliated with any brokerage firms. For clients’ accounts maintained in a brokerage firm’s custody, the brokerage firm generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related fees generated through securities trades that are executed through the brokerage firm or that settle into the brokerage firm’s accounts. Brokerage firms provide services that assist Bridgeway in managing and administering client accounts. These services include providing access to client account data, facilitating trade execution (and allocation of aggregated trade orders for multiple client accounts) and facilitating payment of fees from client accounts. Brokerage firms typically assess such clients a “trade away” fee for trades not executed through the brokerage firm, which may happen in instances where Bridgeway believes that best execution for that particular trade can be achieved at another broker-dealer. Directed Brokerage On occasion, clients may direct Bridgeway to use a specific broker-dealer(s) (“Directed Broker”) to effect transactions in their accounts. In such cases, Bridgeway generally does not attempt to negotiate commissions on client’s behalf. Clients may sacrifice execution quality and/or pay higher commissions and fees than if the brokerage were not directed to a Directed Broker. Trades in accounts where the client directs brokerage are typically placed after trades for clients that do not direct brokerage. For these reasons, Bridgeway cannot assure best execution on trades for client accounts that are directed to a Directed Broker.

Allocation of Investment Opportunities for U.S. Strategies Bridgeway has adopted investment and trading policies designed with the intention to reasonably ensure investment opportunities and trades are allocated fairly and equitably among clients over time. Bridgeway’s Investment Management Team is responsible for managing client accounts according to the investment objectives outlined in the client’s contract. In general, investment opportunities are made available to all clients that are eligible to participate and where such investment opportunities are deemed appropriate for the specific client. To the extent an investment opportunity is considered for multiple investment styles, Bridgeway will examine each style’s particular needs, in conjunction with the firm’s overall investment process, to determine which styles and accounts within a style will receive an allocation. The following factors are considered when allocating investment opportunities:

Each client’s investment objectives; Statistical investment model(s) results; Trading strategy for the account; Current account holdings; Each client’s available cash and/or cash needs; The availability of a block of shares from a broker-dealer; The client’s borrowing ability; The client’s tax situation; and Client-imposed restrictions and exclusions.

Should the circumstance arise where the same security is being bought and sold for different client accounts, the portfolio managers for the clients involved will take action they believe is fair and equitable to the clients participating in the transactions, including engaging in an inter-portfolio trade, where permitted. Should Bridgeway engage in an inter-portfolio trade, this will be done in accordance with the Inter-Portfolio Trades Policy. (Please see Inter-Portfolio Trades section below.) Allocation of Investment Opportunities for International and Absolute Return Strategies Bridgeway has adopted investment and trading policies designed with the intention to reasonably ensure investment opportunities and trades are allocated fairly and equitably among clients over time. Bridgeway’s Investment Management Team is responsible for managing client accounts according to the investment objectives outlined in the private fund governing documents and other client account documents, as appropriate. In general, the Emerging Markets Small-Cap private fund and Absolute Return accounts are each traded when the respective target portfolio is updated or re-balanced or when the tracking error of the private fund or absolute volatility of an Absolute Return account portfolio exceeds an internally set threshold. Basket trading is used to place the

majority of the transactions needed for these portfolios to bring each in line with the respective target portfolio. Bridgeway prioritizes strategy and re-balancing investment recommendations for client accounts over any proprietary account managed to an Absolute Return strategy. Overlap of Investment Opportunities Between U.S., International and Absolute Return Strategies Although expected to occur infrequently, there may be overlap between a U.S. and International strategy in a limited number of American Depositary Receipts (“ADRs”) holdings and/or recommendations, all of which are considered highly liquid. If the same ADR is held and/or purchased/sold in both a U.S. strategy and an International strategy, each strategy may place trades independently of one another and may be trading at the same time in the same or opposite directions. The Absolute Return strategies invest in long and short swaps of international and/or U.S. securities and there is generally overlap in the equity securities and swaps’ underlying securities (hereinafter referred to as, same securities) held (and/or purchased and sold) between an Absolute Return strategy and a U.S. strategy and/or between an Absolute Return strategy and an International strategy. The same security may be purchased and/or /sold in an Absolute Return and a U.S. or International strategy at the same or differing times (including in opposite directions) or may be held long in a U.S. or International strategy and short in an Absolute Return strategy which has the potential to create conflicts of interest among clients and with Bridgeway’s own interests (due to proprietary accounts) competing for the same securities and/or security trades working against each other. However, Bridgeway believes these conflicts of interest are managed as each strategy’s investment recommendations and relevant trading instructions are performed independently of one another and in accordance with the strategy’s investment objective and guidelines. Further, Bridgeway maintains trading and portfolio management policies and procedures addressing these practices. Trade Aggregation for U.S. Strategies The following information applies when Bridgeway is responsible for trading of the client account. When practical, trades, including trades across multiple strategies and styles, will be combined in a single order in an effort to obtain best execution at the best security price available. Occasionally, if determined by the portfolio managers for the accounts that it is in the best interest of all clients involved in the trade, the Investment Management Team will submit an order which may be combined with an order actively being traded. Generally in those situations, the trader will close the active order, randomly allocate any executed shares and create a new merged order which includes all eligible accounts. When a trade involves both accounts custodied at a broker/custodian and accounts custodied elsewhere, the trades are not typically aggregated due to trade-away fees assessed by the broker/custodian for the respective brokerage accounts (please see Broker/Custodian section

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Other Compensation Other than the compensation described in Items 5, 6, and 12 (Soft Dollars sub-sections) above, Bridgeway does not receive an economic benefit from anyone other than its clients. Compensation for Client Referrals Bridgeway, from its own resources, may make payments to financial service agents as compensation for access to platforms or programs that facilitate the sale or distribution of the Bridgeway Funds, and for related services provided in connection with such platforms and programs. These payments would be in addition to any other payments described in the Prospectus for the Bridgeway Funds. The amount of the payment may be different for different agents. These

additional payments may include amounts that are sometimes referred to as “revenue sharing” payments. These payments may create an incentive for the recipient to recommend or sell shares of a Bridgeway Fund. The Board of Directors of the Bridgeway Funds will monitor these revenue sharing arrangements as well as the payment of management fees paid by the Bridgeway Funds to ensure that the levels of such management fees do not involve the indirect use of the Funds’ assets to pay for marketing, promotional or related services. Because revenue sharing payments are paid from legitimate profits of Bridgeway, and not from the Funds’ assets, the amount of any revenue sharing payments is determined by Bridgeway. To the extent that Bridgeway enters into these types of arrangements, Bridgeway intends to comply with the disclosure requirements and all other requirements under applicable law. Bridgeway may enter into written arrangements whereby third parties (“Promoters”) refer potential clients or investors to Bridgeway in return for direct or indirect compensation. When Bridgeway enters into such arrangements with Promoters, Bridgeway does so in compliance with the applicable provisions of Rule 204(4)-1 of the Advisers Act (the “Advertising Rule”). Bridgeway has adopted a Marketing and Advertising Policy to reasonably ensure that client or investor referrals in exchange for direct or indirect compensation are carried out in compliance with the Advertising Rule.

There are no reportable disciplinary actions to report.

All client accounts and Bridgeway-managed private funds are reviewed by a member of the Investment Management Team at least quarterly. In addition, trade activity and cash balances are reviewed more frequently as necessary by a portfolio manager. High net worth clients are provided with a written, quarterly reporting package which typically includes an account summary, performance on the account and benchmark data, performance attribution, contribution to return, portfolio characteristics, sector distribution, and asset list reports. Institutional clients are provided with monthly account and benchmark performance reports and quarterly reporting packages that generally include performance commentary, account summary, performance on the account and benchmark data, performance attribution, contribution to return, portfolio characteristics, sector distribution and asset list reports. Additional reports may be provided to clients upon request. Investors in private funds managed by Bridgeway are provided with the reporting described in each private fund’s offering materials.

If a client has provided Bridgeway with written authority to deduct advisory fees directly from the client account, Bridgeway is deemed to have custody of those accounts. However, outside of those circumstances, Bridgeway does not maintain custody of client assets (except as described below for private funds). Bridgeway has policies and procedures designed to provide reasonable assurance the firm does not inadvertently obtain further custody over clients’ assets. Bridgeway has policies and procedures to provide reasonable assurance that the client’s qualified custodian is sending quarterly statements to the client. In addition, Bridgeway typically sends each client an advisory fee invoice. Bridgeway encourages clients to carefully review statements received from the custodian. Further, Bridgeway encourages clients to compare information in Bridgeway reports to reports provided by the client’s qualified custodian. Bridgeway has no affiliated qualified custodians. As a result of the SEC investment adviser custody rule, Bridgeway may be deemed to have custody of each private fund’s assets, due to its control, as general partner, of disbursement authority over the each such fund’s bank account. Bridgeway, however, does not have actual custody of the private fund’s assets. Under the SEC investment adviser custody rule, each private fund must be audited annually, and all assets (other than un-certificated, restricted securities) are required to be held in the fund’s name at a qualified custodian (e.g., a bank or broker-dealer). Bridgeway distributes each private fund’s audited financial statements (prepared in accordance with Generally Accepted Accounting Principles) to all investors within 120 days of the applicable private fund’s

fiscal year end. Bridgeway may implement additional controls related to custody of assets and the custody rule as it relates to private funds.

Bridgeway provides portfolio management services on a discretionary basis. All client accounts are subject to a written investment advisory agreement which describes discretionary authority, any investment limitations, investment objectives, fees and other matters.

When a client grants Bridgeway proxy-voting authority, Bridgeway strives to vote such proxies in the client’s best economic interest. Bridgeway has adopted and maintains a written Proxy Voting Policy that describes the approach to voting proxy proposals. In summary, Bridgeway has engaged Institutional Shareholder Services, Inc. (“ISS”), a third-party proxy voting agent, to provide proxy voting research, provide vote recommendations and execution services on behalf of clients. Subject to certain exceptions, Bridgeway has instructed ISS to vote proxies in accordance with ISS United States SRI Proxy Voting Guidelines for all U.S. proxy issues and the ISS International SRI Proxy Voting Guidelines for all non-U.S. proxy issues, which Bridgeway has adopted. If Bridgeway determines that the ISS vote recommendation is not in the best interests of clients, Bridgeway will direct ISS to vote the proxy contrary to ISS’s recommendation. Additionally, in cases where ISS does not provide a vote recommendation, Bridgeway will review the proxy proposal and direct ISS to vote the proxy in the best interests of clients. As a general matter, securities on loan will not be recalled to facilitate proxy voting (in which case the borrower of the security shall be entitled to vote the proxy). Bridgeway’s Head of Investment Operations is responsible for this policy while the Chair of the Portfolio Innovation and Risk Committee is responsible for oversight of proxy voting. ISS monitors its conflicts of interest in voting proxies and has provided an executive summary of its annual compliance review report and Bridgeway conducts regular reviews of ISS. However, conflicts of interest may arise in cases where Bridgeway provides a vote recommendation. In such cases, Bridgeway will determine whether the proxy may be voted by Bridgeway, whether to seek legal advice, or whether to refer the proxy to the client(s) (or another fiduciary of the client(s)) for voting purposes. A copy of Bridgeway’s proxy voting policy and procedures, as well as a record of how proxies were voted, will be furnished free to a client upon request.

There are no financial conditions to disclose which would impair Bridgeway’s ability to meet contractual commitments to clients.

Other Information Class Actions and other Legal Proceedings Bridgeway does not file legal proceedings, including class actions, on behalf of clients.