DAVIS SELECTED ADVISERS

Davis Selected Advisers, L.P. Davis Selected Advisers, L.P. (referred to jointly with Davis Selected Advisers–NY, Inc. as “Davis Advisors”) provides discretionary portfolio management services, serving as investment adviser or sub-adviser for registered investment companies (including the Davis ETFs, Davis Funds, Selected Fund, and Clipper Fund), unregistered investment companies, offshore funds, private accounts, and other pooled investment vehicles. Davis Advisors also works with sponsors to serve as investment adviser for managed money/wrap account programs. In certain managed money/wrap account programs, Davis Advisors will provide non-discretionary investment management services (generally in the form of a model portfolio). Davis Selected Advisers, L.P. has been offering investment advisory services since 1969. Davis Selected Advisers, L.P. is a private Colorado limited partnership. Davis Selected Advisers, L.P.’s limited partnership units are owned (either directly or through holding companies) primarily by members of the Davis family, and Davis Selected Advisers, L.P.’s officers and employees. Andrew Davis and Christopher Davis each own 25% or more of Davis Selected Advisers, L.P.’s limited partnership units. Davis Investments, LLC (a Delaware limited liability company) serves as Davis Selected Advisers, L.P.’s sole general partner. Davis Investments, LLC is wholly owned by Christopher Davis. Davis Selected Advisers–NY, Inc. Davis Selected Advisers–NY, Inc.’s only business is to serve as a sub-adviser for certain institutional accounts for which Davis Selected Advisers, L.P. serves as investment adviser. Clients do not do business directly with Davis Selected Advisers–NY, Inc.; Davis Selected Advisers–NY, Inc. works exclusively as a sub-adviser with select clients of Davis Selected Advisers, L.P. Davis Selected Advisers–NY, Inc. (a Delaware corporation) is a wholly owned affiliate of Davis Selected Advisers, L.P. Davis Selected Advisers–NY, Inc. has been offering sub-advisory services to select clients of Davis Selected Advisers, L.P. since 1997. Advisory Services Offered As of December 31, 2025, Davis Advisors managed approximately $25,619,655,091 in client assets on a discretionary basis and approximately $4,500,533,820 in client assets on a non-discretionary basis. Davis Advisors manages client accounts in the following investment strategies:

Large-cap value; Concentrated equity; Multi-cap equity; Financial services; International companies; Global companies; Real estate companies; Balanced; Government securities; and Government money market funds.

A brief description of each of these investment strategies and their principal risks is included in Item 8 Methods of Analysis, Investment Strategies and Risk of Loss. Accounts are managed based on an existing Davis Advisors investment strategy. Davis Advisors may tailor its advisory services to the reasonable requests of its clients. The tailoring of any Davis Advisors investment strategy is generally accomplished through investment restrictions established by the client and provided to Davis Advisors in writing. For example, clients may impose reasonable investment limitations and restrictions on specific securities or industry sectors. Davis Advisors retains the right to refuse to accept a client for any reason, including unreasonable investment limitations or restrictions. In certain cases, an account following the same investment strategy as another account or the model account will be more concentrated. These differences are usually the result of an operational impediment (e.g., a client is unable to purchase a foreign security) or as a result of a client’s instructions (e.g., a client instructs Davis Advisors to not invest in a certain sector or security). A client account that is subject to ERISA may be restricted from owning the client’s employer’s securities. A client must inform Davis Advisors of any such restriction. In addition, a client must also provide Davis Advisors with a list

of any “party in interest” as defined in Section 3(14) of ERISA and every affiliate that has the authority to appoint or terminate Davis Advisors or to negotiate the terms of the investment management agreement with Davis Advisors so that they may rely on the class exemption for qualified professional asset managers. Managed money/wrap accounts Davis Advisors has been retained as an investment adviser under a number of investment advisory programs, commonly referred to as a separately managed account, directly managed account, unified managed account, wrap account or similarly named programs (collectively, “managed money/wrap account”). The wrap sponsor pays Davis Advisors a portion of the wrap fee for its services. These managed money/wrap accounts have been created by the financial institutions (each a “Sponsor”). For a current list of financial institutions sponsoring managed money/wrap accounts which Davis Advisors participates in, see Section 5.I.(2) in Davis Advisors’ Form ADV Part 1. When advising managed money/wrap accounts, Davis Advisors’ trading desk typically instructs the program sponsors when to execute portfolio transactions. When advising accounts other than managed money/wrap accounts (including private accounts or investment companies), Davis Advisors’ trading desk will execute portfolio transactions on behalf of the client. For more detailed information, see Item 12 Brokerage Practices. Some custodians/broker-dealers have established programs for independent registered investment advisors (RIA) that allow the RIAs to act as a managed money/wrap account sponsor. In these circumstances, Davis Advisors may enter into an investment advisory agreement with a client directly. Although Davis Advisors has entered into an agreement with the client directly, the RIA still serves as the sponsor. In these circumstances, Davis Advisors receives only limited information from the RIA. The Sponsors may recommend to a client the retention of Davis Advisors as an investment adviser, pay Davis Advisors’ investment advisory fee on behalf of the client, monitor and evaluate Davis Advisors’ performance, execute the client’s portfolio transactions and/or provide custodial services for the client’s assets. Certain Sponsors receive Davis Advisors’ model portfolio holdings and, based on that model, the Sponsor exercises investment discretion and executes each investor’s portfolio transactions based on the Sponsor’s own investment judgment. When Davis Advisors provides a Sponsor model portfolio holdings, the Sponsor provides investment advice to its clients based on their individual needs. Typically, in a managed money/wrap account, equity securities transactions are executed without a commission charge or at a fixed commission amount per trade and fixed income securities transactions are executed with mark-ups or mark-downs that are incorporated into the purchase or sale prices, rather than separate commission charges. Normally, managed money/wrap accounts offer all of these services for a single, all-inclusive fee the client pays to the Sponsor. Davis Advisors generally is paid a portion of the wrap fee for its services. In a typical managed money/wrap account arrangement, the client enters into an investment advisory agreement with the Sponsor and Davis Advisors enters into a sub-advisory agreement with the Sponsor. Davis Advisors’ fees for managing a managed money account may be less than the fees Davis Advisors receives for managing similar accounts outside of a managed money program. However, clients should be aware that the total fees associated with a managed money program may be greater than those which might be available if the services were acquired separately. In determining the suitability of a particular Davis Advisors’ investment style to the individual needs and financial situation of each managed money/wrap account, Davis Advisors relies on the Sponsor’s suitability determination and Sponsor-gathered information on the prospective client. This typically includes, among other things, a personal interview of the client and/or a written questionnaire completed by the client, which provides certain financial and other relevant data, including the client’s investment objectives, risk tolerance, and investment restrictions, if any. Some Sponsors will not provide Davis Advisors with the financial information and other data relevant to the individual needs and financial situation of each client. Thus, under such managed money/wrap account programs, Davis Advisors cannot independently conclude that a client’s chosen investment style is suitable for that client. In such circumstances, Davis Advisors must and therefore will rely solely and exclusively on the Sponsor’s suitability determinations. Clients of such managed money/wrap accounts should contact their Sponsor for more information about the Sponsor’s role in making a suitability determination regarding the client’s chosen investment style(s). After an account has been established, Davis Advisors is available to communicate with the client or the client’s representative, as needed, on matters concerning the client’s investments that Davis Advisors is managing. Davis Advisors Provides Limited Services Davis Advisors does not provide financial planning services. Accordingly, Davis Advisors will provide investment management services only with respect to the securities, cash, and other investments held in a client’s account and, in

making recommendations with respect to the account, Davis Advisors will not consider any other securities, cash, or other investments owned by a client. In addition, Davis Advisors does not provide tax, accounting, or legal services or advice. Davis Advisors does not act as a Sponsor for any Wrap-Fee Program.

Fees for Advisory Services Advisory fees are earned based on a percentage of assets. The advisory fees charged depend on: (i) the services rendered (e.g., advisory versus sub-advisory, investment company versus private account, managed money/wrap account, etc.); (ii) the client’s investment objective and investment strategy (e.g., large-cap value companies, concentrated equity portfolio, multi-cap equity, financial services, international companies, global companies, real estate companies, balanced, government securities, government money market funds); (iii) the size of the account; and (iv) other factors. All fees are subject to negotiation based on the circumstances of the client and other factors, including but not limited to the type and size of the account and the type and amount of client-related services that Davis Advisors will provide. Investment Companies Fees for serving as investment adviser for equity-oriented investment companies (including ETFs) typically begin with a base of 0.55% of assets under management on an annual basis, and are reduced as assets increase. Fees for government money market investment companies typically begin with a base of 0.30% of assets. Fees for government bond investment companies begin with a base of 0.30%. All fees are subject to negotiation based on the circumstances of the client and other factors, including but not limited to the type and size of the account and the type and amount of client-related services that Davis Advisors will provide. Specific advisory fees and expense-related information may be found in the client’s prospectus or statement of additional information. Pooled Investment Vehicles Fees for serving as a sub-adviser or investment manager to other pooled investment vehicles typically range from 0.35% to 0.50% of assets under management on an annual basis, and may be reduced by breakpoints as assets increase. Fees are individually negotiated and are subject to vary. Private Accounts The fees charged for large-cap value, concentrated equity, multi-cap equity, financial services, international companies, global companies, real estate companies, and balanced private account clients are individually negotiated but are expected to range from 0.35% to 0.55% of the fair market value of the assets on an annual basis depending on the nature and size of the account, investment strategy and other factors. The fees charged to accounts that are associated with Davis Advisors, its employees, and affiliates may be significantly less than those shown, including accounts that are managed without an investment management fee. Managed money/wrap accounts Davis Advisors serves as discretionary or non-discretionary investment adviser for a number of managed money/wrap account programs. After consulting with the managed money/wrap account sponsor, some clients select Davis Advisors to manage security accounts. The managed money/wrap account sponsor provides the primary client contact with regard to such clients, and works with them to develop and update investment guidelines as needed and to determine the amount to be allocated to their account with Davis Advisors. These managed money/wrap accounts pay a single fee to the managed money/wrap account sponsor, covering the services rendered by both the sponsor and Davis Advisors. The managed money/wrap account sponsor pays Davis Advisors an annual fee on a quarterly basis, based on the value of all client accounts that Davis Advisors manages on its behalf. The fees that Davis Advisors receives for large-cap value, multi-cap equity, international companies, global companies, and real estate companies’ managed money/wrap accounts are subject to negotiation but are expected to range from 0.33% to 0.55% of the fair market value of assets on an annual basis. Fees are individually negotiated and are subject to substantial variation. Billing Generally, clients are billed for fees incurred on either a quarterly or monthly basis in arrears. While Davis Advisors does not require pre-payment of fees, some client agreements may call for the payment of fees in advance.

Termination Client investment advisory agreements provide for termination without penalty generally on sixty days’ notice by the client or Davis Advisors. The agreements provide for automatic termination in the event of an assignment. Terminated accounts will be charged advisory fees by Davis Advisors through the date assets are transferred. Upon termination, Davis Advisors is under no obligation to recommend any action with regard to the securities or other property held in a client’s account. Davis Advisors generally does not collect fees in advance; however, on those accounts where payment is made in advance, a pro-rata amount will be refunded to a client upon termination of the account. The refunded amount is determined by the length of time remaining in the billing cycle. Related Fees and Expenses Clients may incur other fees or expenses in connection with the account managed by Davis Advisors, such as custodian fees paid to the bank, trust or brokerage firm holding client assets, or mutual fund operating expenses. These fees are generally not paid to Davis Advisors. Clients will incur brokerage and other transaction costs. See Item 12 for a more detailed discussion of brokerage and other transaction costs. Davis Advisors Does Not Accept Compensation for the Sale of Securities Neither Davis Advisors nor any of its supervised persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. An affiliate of Davis Advisors, Davis Distributors, LLC, serves as principal underwriter of Davis Funds, Selected Fund, and Clipper Fund. As principal underwriter, Davis Distributors, LLC may receive asset-based sales charges or service fees for the sale of these funds.

Davis Advisors manages client accounts on a discretionary basis in the following investment strategies:

Large-cap value; Concentrated equity; Multi-cap equity; Financial services; International companies; Global companies; Real estate companies; Balanced; Government securities; and Government money market funds.

A brief description of the Davis Investment Discipline, factors which may contribute to differences in performance among similarly managed accounts, and each of these investment strategies is provided below. Following the description of the investment strategies is a more detailed description of Principal Risks and Additional Information about Investments. The Davis Investment Discipline Davis Advisors manages equity accounts using the Davis Investment Discipline. Davis Advisors conducts extensive research to try to identify businesses that possess characteristics which Davis Advisors believes foster the creation of long-term value, such as proven management, a durable franchise and business model, and sustainable competitive advantages. Davis Advisors aims to invest in such businesses when they are trading at discounts to their intrinsic worth. Davis Advisors emphasizes individual stock selection and believes that the ability to evaluate management is critical. Davis Advisors routinely visits managers at their places of business in order to gain insight into the relative value of different businesses. Such research, however rigorous, involves predictions and forecasts that are inherently uncertain. Over the years, Davis Advisors has developed a list of characteristics that it believes help companies to create shareholder value over the long term and manage risk. While few companies possess all of these characteristics at any given time, Davis Advisors searches for companies that demonstrate a majority or an appropriate mix of these characteristics. Competitive Advantages Non-Obsolescent products Dominant or growing market share Global presence and powerful brands First-Class Management Proven track record Significant alignment of interests in business Intelligent allocation of capital Financial Strength Strong balance sheet Low cost structure High returns on invested capital After determining which companies Davis Advisors believes that an account should own, it then turns its analysis to determining the intrinsic value of those companies’ equity securities. Davis Advisors seeks equity securities which can be purchased at attractive valuations relative to their intrinsic value. Davis Advisors’ goal is to invest in companies for the long term. Davis Advisors considers selling a company’s equity securities if the securities’ market price exceeds Davis Advisors’ estimates of intrinsic value, or if the ratio of the risks and rewards of continuing to own the company’s equity securities is no longer attractive. Sustainable Investing Considerations As an investment adviser with a long-term investment horizon, Davis Advisors defines sustainability in terms of a company’s ability to generate durable, resilient shareholder value over the long term and recognize that the factors

that impact the economic sustainability of a business go way beyond mere financial and competitive considerations. While a company may create short-term profits at the expense of other valuable constituencies or stakeholders, such as customers, the environment, their communities, their regulators, or their employees, such profits are unlikely to be sustainable for the long term. Most commonly, profits generated at the expense of the social good are reduced over the long term by regulation, litigation, taxation and societal changes. As a result, in order to fulfill our long–term fiduciary duty, we must distinguish between businesses that generate profits through unsustainable exploitation of other constituencies or stakeholders and those that create sustainable shareholder value by delivering value to the world or, put more technically, increasing social utility. This distinction is a central objective of our investment discipline. Investing in securities involves a risk of loss that clients should be prepared to bear. Factors which may Contribute to Differences in Performance among Similarly Managed Accounts Davis Advisors serves as investment adviser for a number of institutional private accounts, sub-advised investment companies, offshore funds, managed money/wrap accounts, and other pooled investment vehicles whose portfolios are patterned after model portfolios or designated mutual funds managed by Davis Advisors. The portfolio holdings and transactions of these institutional private accounts, sub-advised investment companies, offshore funds, managed money/wrap accounts, and other pooled investment vehicles are similar to, but not exactly the same as, the model portfolios or designated mutual funds. In addition to differences in performance, these differences may also lead to an increase in the concentration risk for a given account. The investment performance of accounts managed using similar investment strategies are expected to be similar, but not identical to one another. Factors which may cause the holdings and performance to vary in accounts managed using similar investment strategies include, but are not limited to: 1.

Different Investment Restrictions. To provide an example of different investment restrictions, certain clients may be prohibited from investing in identified classes of securities or are subject to limitations on the percentage of assets which may be invested in identified classes of securities.

2.

Different Timing of Cash Flows. The timing of when portfolio securities are purchased or sold in response to cash flows may have a material impact on performance.

3.

Allocation of Investment Opportunities. Clients are not assured of participating equally or at all in particular investment allocations. The nature of a client’s investment style may exclude it from participating in many investment opportunities, even if the client is not strictly precluded from participation based on written investment restrictions. For example: (i) large-cap value clients are unlikely to participate in initial public offerings of small-capitalization companies; (ii) Davis Advisors may allocate short-term trading opportunities to clients pursuing active trading strategies rather than clients pursuing long-term buy-and-hold strategies; (iii) minimum block sizes may be optimal for liquidity, which may limit the participation of smaller accounts; (iv) it is sometimes impractical for some custodians to deal with securities which are difficult to settle; and (v) private accounts and managed money/wrap accounts generally do not participate in direct purchases of foreign securities, but may participate in ADRs, GDRs, or common shares registered and actively traded in the United States.

4.

Limitations on Aggregate Investments in a Single Company. Davis Advisors’ policy is not to invest for the purpose of exercising control or management of other companies. In extraordinary circumstances, Davis Advisors may seek to influence management. In such an event, appropriate government and regulatory filings would be made. Federal and state laws, as well as company documents (sometimes referred to as “poison pills”), may limit the percentage of a company’s outstanding shares which may be purchased or owned by Davis Advisors’ clients. This is especially true in heavily regulated industries such as insurance, banking, and real estate investment trusts. Unless it can obtain an exception, Davis Advisors will not make additional purchases of these companies for its clients if, as a result of such purchase, shares in excess of the applicable investment limitation (for example, 9.9% of outstanding voting shares) would be held by its clients in the aggregate.

5.

Effects of Currency Exchange. Clients not using the U.S. Dollar as their base currency may experience different performance when asset values are converted back into their base currency.

6.

Different Operational Mechanics. Davis Advisors may have clients that follow a similar investment strategy, but in different legal structures (e.g., exchange traded fund compared to a mutual fund). While both clients

may follow a similar investment strategy, the accounts can be very different and may be treated separately for a number of reasons. For example, exchange traded funds are subject to different regulatory requirements and generally sell and redeem shares with authorized participants via in-kind transactions.

Large-Cap Value Investment Objective Long-term growth of capital. Principal Investment Strategy Davis Advisors uses the Davis Investment Discipline to invest a client’s assets principally in common stocks (including indirect holdings of common stock through depositary receipts) issued by large companies with market capitalizations of at least $10 billion. Historically, the Large-Cap Value strategy has invested a significant portion of its assets in financial services companies and in foreign companies, and may also invest in mid- and small-capitalization companies. Benchmark Index Standard & Poor’s 500® Index and/or Russell 1000® Value Index Principal Risks (See a detailed description of each risk in the section titled “Principal Risks”) You may lose money investing in the Large-Cap Value investment strategy. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in value. This section describes what Davis Advisors believes are the most significant factors (but not the only factors) that can cause a client’s investment performance to suffer:

China risk Common stock risk Depositary receipts risk Emerging market risk Exposure to industry or sector risk Fees and expenses risk Financial services risk Focused portfolio risk Foreign country risk Foreign currency risk Headline risk Large-capitalization companies risk Manager risk Mid- and small-capitalization companies risk Stock market risk

Concentrated Equity Investment Objective Long-term growth of capital; or Long-term growth of capital and capital preservation. Principal Investment Strategy Davis Advisors uses the Davis Investment Discipline to invest a client’s portfolio principally in common stocks (including indirect holdings of common stock through depositary receipts) issued by large companies with market capitalizations of at least $10 billion. The Concentrated Equity strategy is non-diversified and, therefore, is allowed to focus its investments in fewer companies than a strategy that is required to diversify its portfolio. A client’s portfolio generally contains between 15 and 35 companies, although the precise number of its investments will vary over time. Historically, the Concentrated Equity strategy has invested a significant portion of its assets in financial services companies and in foreign companies, and may also invest in mid- and small-capitalization companies.

Benchmark Index Standard & Poor’s 500® Index and/or Russell 1000® Value Index Principal Risks (See a detailed description of each risk in the section titled “Principal Risks”) You may lose money investing in the Concentrated Equity investment strategy. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in value. This section describes what Davis Advisors believes are the most significant factors (but not the only factors) that can cause a client’s investment performance to suffer:

Common stock risk Depositary receipts risk Fees and expenses risk Financial services risk Focused portfolio risk Foreign country risk Foreign currency risk Headline risk Large-capitalization companies risk Manager risk Mid- and small-capitalization companies risk Stock market risk

Multi-Cap Equity Investment Objective Long-term growth of capital. Principal Investment Strategy Davis Advisors uses the Davis Investment Discipline to invest a client’s portfolio principally in common stocks (including indirect holdings of common stock through depositary receipts). The Multi-Cap Equity strategy may invest in large, medium, or small companies without regard to market capitalization and may invest in issuers in foreign countries, including countries with developed or emerging markets. Benchmark Index Standard & Poor’s 1500® Index Principal Risks (See a detailed description of each risk in the section titled “Principal Risks”) You may lose money investing in the Multi-Cap Equity investment strategy. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in value. This section describes what Davis Advisors believes are the most significant factors (but not the only factors) that can cause a client’s investment performance to suffer:

Common stock risk Depositary receipts risk Emerging market risk Fees and expenses risk Foreign country risk Foreign currency risk Headline risk Large-capitalization companies risk Manager risk Mid- and small-capitalization companies risk Stock market risk

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Davis Advisors provides discretionary portfolio management services, serving as investment adviser or sub-adviser for registered investment companies (including the Davis ETFs, Davis Funds, Selected Fund, and Clipper Fund), unregistered investment companies, offshore funds, private accounts, and other pooled investment vehicles. Davis Advisors also works with sponsors to serve as investment adviser for managed money/wrap account programs. In certain managed money/wrap account programs, Davis Advisors will provide non-discretionary investment management services (generally in the form of a model portfolio). Subject to negotiation and exceptions, there is a minimum size of $50,000 for managed money/wrap accounts and $10,000,000 for sub-advised accounts and private accounts. Minimum account sizes for fund investments are disclosed in the applicable prospectus, statement of additional information, or other disclosure document.

Davis Advisors does not charge performance based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client. Davis Advisors is not subject to the potential conflicts of interest which arise when accounts which pay performance-based fees are managed side-by-side with accounts which pay an asset based fee.

Davis Selected Advisers, L.P. See Item 4 Advisory Business. Davis Selected Advisers–NY, Inc. See Item 4 Advisory Business. Davis Distributors, LLC Davis Distributors, LLC, a registered broker-dealer, is a wholly owned subsidiary of Davis Advisors. Davis Distributors, LLC’s sole activity is to underwrite and distribute shares of registered investment companies and offshore funds that Davis Advisors advises. Davis Distributors, LLC provides underwriting services for Davis Funds, Selected Fund, and Clipper Fund. A number of officers and employees of Davis Advisors serve as officers or employees of Davis Distributors, LLC. Davis ETFs, Davis Funds, Selected Fund, Clipper Fund Davis Selected Advisers, L.P. and Davis Selected Advisers–NY, Inc. provide advisory and sub-advisory services for Davis ETFs, Davis Funds, Selected Fund, and Clipper Fund.

Offshore Funds Davis Advisors serves as investment adviser for Davis Funds SICAV (which is an offshore fund registered in Luxembourg) and other offshore funds that are not available for investment by U.S. citizens. Sub-Advised Funds Davis Advisors serves as a sub-adviser to registered and unregistered investment companies. Conflicts of Interest Having a number of different clients creates conflicts of interest which Davis Advisors seeks to address through a number of compliance procedures, including trading procedures (see Item 12 Brokerage Practices). Investors have the opportunity to access Davis Advisors’ investment advisory services through a number of different service providers, at a variety of different prices, and receive a number of different related services associated with different service providers. Certain Portfolio Managers may serve on the board(s) of public companies where they, from time to time, may have access to material, non-public information (“MNPI”). Davis Advisors has instituted policies and procedures to ensure that these Portfolio Managers will not be able to utilize MNPI for their own benefit or for any of the accounts they manage.

Trading All Davis Advisors’ employees with regular access to trading information are subject to a variety of restrictions on their personal security transactions. Employees may, subject to certain restrictions, invest in securities that are recommended to clients by Davis Advisors. Personal trading creates conflicts of interest, including the possibility of “front-running” (trading ahead of clients to obtain better prices). Davis Advisors has adopted written policies pursuant to Rule 17j-1 of the Investment Company Act of 1940 and Rule 204A-1 of the Investment Advisers Act of 1940. These policies are designed to prevent and detect possible conflicts of interest with clients. Subject to certain exceptions, employees (i) are required to pre-clear all non-exempt purchases and sales with respect to which they are regarded as beneficial owners; (ii) are required to make up the difference on any day that his/her trade receives better execution than a client trading on the same day; and (iii) are not allowed to profit on any transaction where the security has been held less than 60 days. All Davis Advisors employees are prohibited from trading on inside information. A copy of Davis Advisors’ current Code of Ethics is available upon request to any client or prospective client. Davis Advisors serves as investment adviser for the Davis ETFs, Davis Funds, Selected Fund, and Clipper Fund. If Davis Advisors or its employees recommend that an investor invest in these funds, it creates a conflict of interest as Davis Advisors earns advisory fees for managing these funds. Davis Advisors and its affiliates, owners, officers, and employees have invested substantial amounts of their own capital in some client accounts (notably the Davis ETFs, Davis Funds, Selected Fund, and Clipper Fund), but do not invest their own capital in every client’s account.

Portfolio Transactions Davis Advisors is primarily a discretionary investment adviser. Accordingly, Davis Advisors generally determines the securities and quantities to be bought and sold for each client’s account. On a quarterly basis, or as requested, clients receive itemized account statements reflecting present holdings and transactions for the account’s stated period. Best Execution Davis Advisors follows procedures intended to provide reasonable assurance of best execution. However, there can be no assurance that best execution will in fact be achieved in any given transaction. Davis Advisors seeks to place portfolio transactions with brokers or dealers who will execute transactions as efficiently as possible and at the most favorable net price. In determining what constitutes best execution, the Adviser not only considers quantitative factors, (i.e., the possible transaction cost), but also whether the transaction represents the best qualitative execution. In placing executions and paying brokerage commissions or dealer markups, Davis Advisors considers, among other factors, price, commission, timing, aggregated trades, capable floor brokers or traders, competent block trading coverage,

ability to position, capital strength and stability, reliable and accurate communication and settlement processing, use of automation, knowledge of other buyers or sellers, arbitrage skills, administrative ability, underwriting and provision of information on the particular security or market in which the transaction is to occur, research, the range and quality of the services made available to clients, and the payment of bona fide client expenses. To the extent that clients direct brokerage, Davis Advisors cannot be responsible for achieving best execution. Davis Advisors may place orders for portfolio transactions with broker-dealers who have sold shares of funds for which Davis Advisors serves as adviser or sub-adviser. However, when Davis Advisors places orders for portfolio transactions, it does not give any consideration to whether a broker-dealer has sold shares of the funds which Davis Advisors serves as adviser or subadviser. The applicability of specific criteria will vary depending on the nature of the transaction, the market in which it is executed and the extent to which it is possible to select from among multiple broker-dealers. Orders that result in small or minimum allocations can under certain circumstances cause an account to incur additional trade ticket charges from its custodian bank. In seeking best execution, Davis Advisors does not take into account the fees that may be assessed by a client’s custodian. Client-Directed Brokerage Clients may designate the use of a specified broker-dealer, whether because the broker provides services to the client or for other reasons. If a client specifies the broker to be used for executing a portion of or all portfolio transactions, then Davis Advisors is not responsible for achieving best execution, regardless of whether or not the client specifies that such direction is subject to achieving best execution. Best execution can only be verified after the fact. Clients who designate the use of a particular broker-dealer should consider whether such a designation may result in certain costs or disadvantages to the client, such as costing more money, higher commissions, and/or less favorable executions. These costs and disadvantages may include: (i) losing the possible advantage that non-designating clients derive from aggregation of orders for several clients as a single transaction for the purchase or sale of a particular security; (ii) losing the ability of Davis Advisors to effectively negotiate the commission rate, which may result in a higher commission on some transactions; (iii) losing the opportunity to participate in an allocation of a new issue if that new issue is provided by another broker; (iv) Davis Advisors may not begin to execute client securities transactions with brokers which have been directed by clients until all non-directed brokerage orders are completed; and (v) clients directing commissions may not generate investment returns equal to clients who do not direct commissions. Accordingly, the client should be satisfied that the broker can provide adequate price and execution of transactions prior to designating the broker. Directed Brokerage in Managed Money/Wrap Account Programs Securities transactions in client accounts participating in managed money/wrap account programs are effected “net,” i.e., without commission, and a portion of the wrap fee is generally considered as being in lieu of commissions. Most securities recommended by Davis Advisors are listed on an exchange, and executing transactions away from the program sponsor would result in the client being charged an additional commission without improving the execution. Because trades are generally executed only with the program sponsor or broker whom the client has selected, the client may pay a higher commission and/or receive less favorable net prices on transactions. A client should ensure that he or she is satisfied that the broker performing the trading in their managed money/wrap account program can provide adequate price and execution of transactions. Additional information is provided below under the heading Managed money/wrap accounts. See your program sponsor’s Wrap Fee Program Brochure for a description of its managed money/wrap account program. Referred Accounts If a client is referred to Davis Advisors by a broker, or if a client has opened a custodial account with a broker, it is Davis Advisors’ practice not to negotiate commission rates with such broker unless expressly requested to do so. Clients are free to choose or change brokers at their discretion unless there is reason to believe the chosen brokerage firm cannot offer adequate service. In such an event, Davis Advisors might be unable to accept management of the account. When a client is referred by a particular broker, and Davis Advisors is directed to effect brokerage transactions through that broker, Davis Advisors may have a conflict of interest between its duty to the client to obtain the most favorable brokerage commission rates available under the circumstances and its desire to obtain future referrals from that broker. Davis Advisors may have an incentive to select or recommend a broker-dealer based on its interest in receiving client referrals, rather than on its clients’ interest in receiving most favorable execution.

Cross Trades When the Adviser deems it to be advantageous, one client may purchase or sell securities directly from or to another client account which is managed by the Adviser. This may happen due to a variety of circumstances, including situations when one client of the Adviser must purchase securities due to holding excess cash and, at the same time, a different client of the Adviser must sell securities in order to increase its cash position. Cross trades are only executed when deemed beneficial to both clients. The Adviser has in place procedures to ensure fairness to both clients. Investment Allocations Davis Advisors considers many factors when allocating securities among clients, including but not limited to the client’s investment style, applicable restrictions, availability of securities, available cash, anticipated liquidity, and existing holdings. Davis Advisors employs several portfolio managers, each of whom performs independent research and develops different levels of conviction concerning potential investments. Client accounts managed by the portfolio managers performing the research may receive priority allocations of limited investment opportunities that are in short supply, including private offerings and initial public offerings (“IPOs”). Clients are not assured of participating equally or at all in any particular investment opportunity. The nature of a client’s investment style may exclude it from participating in many investment opportunities, even if the client is not strictly precluded from participation based on written investment restrictions. For example: (i) large-cap value clients are unlikely to participate in initial public offerings of small-capitalization companies; (ii) Davis Advisors may allocate short-term trading opportunities to clients pursuing active trading strategies rather than clients pursuing long-term buy-and-hold strategies; (iii) minimum block sizes may be optimal for liquidity which may limit the participation of smaller accounts; (iv) it is sometimes impractical for some custodians to deal with securities which are difficult to settle; and (v) private accounts and managed money/wrap accounts generally do not participate in direct purchases of foreign securities, but may participate in American Depositary Receipts (“ADRs”), European Depositary Receipts (“EDRs”) and Global Depositary Receipts (“GDRs”). Davis Advisors attempts to allocate limited investment opportunities, including private offerings and IPOs, among clients in a manner that is fair and equitable when viewed over a considerable period of time and involving many allocations. Generally, Davis Advisors allocates investments to clients utilizing a pro rata methodology. When Davis Advisors is limited in the amount of a particular security it can purchase, due to a limited supply, limited liquidity, or other reason, Davis Advisors may allocate the limited investment opportunity to a subset of eligible clients. Davis Advisors would then allocate the next limited investment opportunity to a different subset of eligible clients, rotating among subsets as limited investment opportunities are identified. Davis Advisors normally does not participate in private offerings or IPOs on behalf of managed money/wrap accounts, which may cause those accounts to be invested differently than similarly managed mutual funds or individually managed institutional accounts. In all cases, these differences reflect the portfolio management teams’ best efforts to manage each product in a common style and manner that is equitable to all investors over time, and take account of each product’s inherent differences from the others. Davis Advisors serves as investment adviser for a number of clients and may deal with conflicts of interest when allocating investment opportunities among its various clients. For example: (i) Davis Advisors receives different advisory fees from different clients; (ii) the performance records of some clients are more public than the performance records of other clients; and (iii) Davis Advisors and its affiliates, owners, officers and employees have invested substantial amounts of their own capital in some client accounts (notably the Davis ETFs, Davis Funds, Selected Fund, and Clipper Fund), but do not invest their own capital in every client’s account. The majority of Davis Advisors’ clients pursue specific investment strategies, many of which are similar. Davis Advisors expects that, over long periods of time, most clients pursuing similar investment strategies should experience similar, but not identical, investment performance. Many factors affect investment performance, including but not limited to: (i) the timing of cash deposits and withdrawals to and from an account; (ii) the fact that Davis Advisors may not purchase or sell a given security on behalf of all clients pursuing similar strategies; (iii) price and timing differences when buying or selling securities; and (iv) the clients’ own different investment restrictions. Davis Advisors’ trading policies are designed to minimize possible conflicts of interest in trading for its clients. Limitations on Aggregate Investments in a Single Company Davis Advisors’ policy is not to invest for the purpose of exercising control or management of other companies. In extraordinary circumstances Davis Advisors may seek to influence management. In such an event appropriate government and regulatory filings would be made.

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Davis Advisors Does Not Receive Third-Party Payments Davis Advisors does not receive cash payments, sales awards, prizes, or other economic benefits from third-parties who are not its clients for providing investment advice or other advisory services to its clients. Employee Compensation Davis Advisors may pay some employees a commission and/or bonus for bringing clients and assets to Davis Advisors.

Compensation to Solicitors Davis Advisors may pay fees based on a percentage of assets to a non-employee soliciting clients. Any clients who are solicited by non-employees receiving a fee from Davis Advisors will receive separate written disclosure of this solicitation arrangement. No solicitation payments may be made before Davis Advisors or its affiliate receive a signed copy of the solicitation agreement and client acknowledgment that contains the applicable referral fee disclosures and acknowledgement of the fee arrangement. Fees Paid to Consultants and Other Financial Intermediaries Davis Advisors actively seeks to educate consultants, broker-dealers, and other financial intermediaries (jointly referred to in this section as “Consultants”) about its advisory services. Davis Advisors sponsors educational events where its representatives meet with Consultants and/or their clients. Davis Advisors may pay some of the costs associated with educational events, which provide Davis Advisors’ representatives with an opportunity to meet with Consultants and/or clients. These fees are paid by Davis Advisors from its own resources, which include the management fees received from the clients. Clients should confer with their Consultant regarding the details of the payments they may receive from Davis Advisors. Service Fees Davis Advisors or Davis Distributors, LLC may pay service fees to broker/dealers and other eligible parties who introduce Davis Advisors to clients and assist Davis Advisors in maintaining the client’s account by keeping records and performing other services, which Davis Advisors would otherwise have to perform itself. Broker-dealers and other financial intermediaries may charge Davis Advisors (or an affiliate) substantial fees for selling accounts managed by Davis Advisors and providing continuing support to clients. These charges may include: (i) sales commissions from sales charges paid by purchasing shareholders; (ii) distribution and service fees from 12b1 distribution plans; (iii) record-keeping fees for providing record-keeping services to investors who invest through dealer-controlled omnibus accounts; and (iv) other fees, described below, that may be paid by Davis Advisors or an affiliate from their own resources. Some intermediaries may, as a condition to distributing shares managed by Davis Advisors, request that Davis Advisors or an affiliate, pay or reimburse the intermediary for: (i) marketing support payments including business planning assistance, educating personnel about the investment type, shareholder financial planning needs, placement on the dealer’s list of offered funds, and access to sales meetings, sales representatives and management representatives of the dealer; and (ii) financial assistance charged to allow Davis Advisors or an affiliate to participate in and/or present at conferences or seminars, sales or training programs for invited registered representatives and other employees, client and investor events and other dealer-sponsored events. These additional fees are sometimes referred to as “revenue sharing” payments. A number of factors are considered in determining fees paid to intermediaries, including the dealer’s sales and assets, and the quality of the dealer’s relationship with Davis Advisors or an affiliate. Fees are generally based on the value of assets held by the dealer or financial institution for its customers or based on sales of fund shares by the dealer or financial institution, or a combination thereof. Davis Advisors may use its profits from the advisory fee it receives from an account to pay some or all of these fees. Some dealers may also choose to pay additional compensation to their registered representatives. Such payments may be associated with the status of a fund on a financial intermediary’s preferred list of funds or otherwise associated with the financial intermediary’s marketing and other support activities. The foregoing arrangements may create an incentive for the brokers, dealers or other financial institutions, as well as their registered representatives, to recommend Davis Advisors rather than other managers. In addition, Davis Advisors or an affiliate may, from time to time, pay additional cash compensation or other promotional incentives to authorized dealers or agents who sell shares of funds managed by Davis Advisors. In some instances, such cash compensation or other incentives may be offered only to certain dealers or agents who employ registered representatives who have sold or may sell significant amounts of shares of funds managed by Davis Advisors during specified periods of time. Service fees, which are paid solely at the discretion of Davis Advisors, are based on the assets under management and the actual services performed. The amount of the fee is separately negotiated with each service provider and cannot be determined in advance. Clients should contact the service provider with whom they deal for information concerning

the existence and amount of any service fees paid in respect to their account. The payment, or non-payment, of service fees will not result in any increase or decrease of the advisory fee charged to the client.

Davis Advisors has not had any reportable legal or disciplinary events during the past ten years.

Davis Advisors serves as investment adviser for many different types of accounts. See Item 7 Types of Clients. Different types of client accounts and accounts managed in different investment styles are reviewed differently. Davis Advisors’ Compliance department, overseen by the Chief Compliance Officer, regularly reviews all accounts to ensure compliance with investment limitations and reasonable application of Davis Advisors’ trading and brokerage policies. See Item 12 Brokerage Practices. Davis Advisors serves as investment adviser for a number of accounts whose portfolios are patterned after model portfolios or designated mutual funds managed by Davis Advisors. The portfolio holdings and transactions of these accounts are similar to, but not exactly the same as, the model portfolios or designated mutual funds. Davis Advisors’ Trading Department periodically reviews these accounts to ensure a reasonable match between these accounts and the model portfolios or designated mutual funds. Davis Advisors’ Portfolio Review Committee meets, generally on a monthly basis, to review Davis Advisors’ LargeCap Value, Concentrated Equity, Financial, Balanced, Multi-Cap Equity, International, and Global investment strategies. Davis Advisors’ Portfolio Review Committee reviews (i) portfolio manager allocations (including review of the investment performance of individual portfolio managers and research analysts), (ii) portfolio risk (including among other things, a review of portfolio liquidity), and (iii) investment operations. Andrew Davis oversees Davis Advisors’ Real Estate investment strategies. Erik Jones oversees Davis Advisors’ Government Securities and Government Money Market investment strategies. Reports to Clients The nature and frequency of reports to clients are determined primarily by the particular needs of each client. Investment companies and private accounts receive periodic written reports, which may include a list of current holdings, transactions for the period, account performance, investment outlook and/or other requested information. Clients in managed money/wrap account programs generally receive written reports from the program sponsor. Clients open accounts with qualified custodians of their choice. The custodian generally sends an account statement, at least quarterly, identifying the amount of funds and each security in the account at the end of the period and setting forth all transactions in the account during that period.

Davis Advisors does not have custody of client accounts. Clients open accounts with qualified custodians of their choice. The broker-dealer, bank, or other qualified custodian will generally send an account statement, at least quarterly, identifying the amount of funds and each security in the account at the end of the period and setting forth all transactions in the account during that period. Clients should carefully review these statements. In some instances Davis Advisors will send a client a schedule of holdings or other similar report. Clients should compare the account statements they receive from the qualified custodian to those reports they may receive from Davis Advisors.

Davis Advisors generally manages client accounts with discretionary authority. Davis Advisors has investment discretion when it is authorized to make purchase and sale decisions for client accounts. Clients may impose reasonable investment limitations and restrictions on specific securities, industry sectors, etc. Davis Advisors retains the right to refuse to accept a client for any reason, including unreasonable investment limitations or restrictions. Davis Advisors generally requires a written investment advisory agreement with clients, which will include a clause granting Davis Advisors investment discretion. Clients may grant Davis Advisors discretionary authority through contractual language that is a part of the advisory agreement or via a separate power of attorney form. Davis Advisors may occasionally provide non-discretionary investment advisory services to certain clients. For example, Davis Advisors may provide a program sponsor with non-discretionary recommendations to assist the sponsor in the development of one or more portfolios that the sponsor may deem suitable for its end investors.

Clients have the right to vote their portfolio securities. Some clients have directed Davis Advisors to vote their portfolio securities in conformance with Davis Advisors’ Proxy Voting Policies and Procedures. Clients may direct Davis Advisors to vote either all or none of their portfolio securities; Davis Advisors does not accept directions on how to vote specific portfolio securities. A client that is interested in voting specific portfolio securities or voting proxies in a way that is inconsistent with Davis Advisors’ Proxy Voting Policies and Procedures should retain the right to vote their portfolio securities. Davis Advisors has adopted Proxy Voting Policies and Procedures to address conflicts of interest between Davis Advisors and its clients with respect to voting client’s portfolio securities. Davis Advisors’ Proxy Voting Policies and Procedures are summarized below. Clients may obtain a copy of Davis Advisors’ Proxy Voting Policies and Procedures upon written request as described below. Summary of Davis Advisors’ Proxy Voting Policies and Procedures Davis Advisors votes on behalf of its clients in matters of corporate governance through the proxy voting process. Davis Advisors takes its ownership responsibilities very seriously and believes the right to vote proxies for its clients’ holdings is a significant asset of the clients. Davis Advisors exercises its voting responsibilities as a fiduciary, solely with the goal of maximizing the value of its clients’ investments. Davis Advisors votes proxies with a focus on the investment implications of each issue. For each proxy vote, Davis Advisors takes into consideration its duty to clients and all other relevant facts known to Davis Advisors at the time of the vote. Therefore, while these guidelines provide a framework for voting, votes are ultimately cast on a case-bycase basis. Davis Advisors has adopted written Proxy Voting Policies and Procedures and established a Proxy Oversight Group to oversee voting policies and deal with potential conflicts of interest. In evaluating issues, the Proxy Oversight Group may consider information from many sources, including the Portfolio Managers for each client account, management of a company presenting a proposal, shareholder groups, and independent proxy research services. While the Proxy

Oversight Group may consider information from many sources, there is no requirement that it consider each source and the Proxy Oversight Group shall have the discretion in its professional judgement to determine each matter to be voted on. The Adviser may utilize research provided by an independent third-party proxy advisory firm. As a policy, the Adviser does not follow the voting recommendations provided by these firms. Clients may obtain a copy of Davis Advisors’ Proxy Voting Policies and Procedures, and/or a copy of how their own proxies were voted, by writing to: Davis Selected Advisers, L.P. Attn: Chief Compliance Officer 2949 East Elvira Road, Suite 101 Tucson, Arizona, 85756 Guiding Principles Creating Value for Existing Shareholders. The most important factors that we consider in evaluating proxy issues are: (i) the company’s or management’s long-term track record of creating value for shareholders. In general, we will consider the recommendations of a management with a good record of creating value for shareholders as more credible than the recommendations of managements with a poor record; (ii) whether, in our estimation, the current proposal being considered will significantly enhance or detract from long-term value for existing shareholders; and (iii) whether a poor record of long term performance resulted from poor management or from factors outside of managements control. Other factors which we consider may include: (a)

Shareholder Oriented Management. One of the factors that Davis Advisors considers in selecting stocks for investment is the presence of shareholder-oriented management. In general, such managements will have a large ownership stake in the company. They will also have a record of taking actions and supporting policies designed to increase the value of the company’s shares and thereby enhance shareholder wealth. Davis Advisors’ research analysts are active in meeting with top management of portfolio companies and in discussing their views on policies or actions which could enhance shareholder value. Whether management shows evidence of responding to reasonable shareholder suggestions, and otherwise improving general corporate governance, is a factor which may be taken into consideration in proxy voting.

(b) Allow responsible management teams to run the business. Because we try generally to invest with “owner oriented” managements (see above), we vote with the recommendation of management on most routine matters, unless circumstances such as long standing poor performance or a change from our initial assessment indicate otherwise. Examples include the election of directors and ratification of auditors. Davis Advisors supports policies, plans and structures that give management teams appropriate latitude to run the business in the way that is most likely to maximize value for owners. Conversely, Davis Advisors opposes proposals that limit management’s ability to do this. Davis Advisors will generally vote with management on shareholder social and environmental proposals on the basis that their impact on share value is difficult to judge and is therefore best done by management. (c)

Preserve and expand the power of shareholders in areas of corporate governance. Equity shareholders are owners of the business, and company boards and management teams are ultimately accountable to them. Davis Advisors supports policies, plans and structures that promote accountability of the board and management to owners, and align the interests of the board and management with owners. Examples include: annual election of all board members and incentive plans that are contingent on delivering value to shareholders. Davis Advisors generally opposes proposals that reduce accountability or misalign interests, including but not limited to classified boards, poison pills, excessive option plans, and repricing of options.

(d) Support compensation policies that reward management teams appropriately for performance. We believe that well thought out incentives are critical to driving long-term shareholder value creation. Management incentives ought to be aligned with the goals of long-term owners. In our view, the basic problem of skyrocketing executive compensation is not high pay for high performance, but high pay for mediocrity or worse. In situations where we feel that the compensation practices at companies we own are not acceptable, we will exercise our discretion to vote against compensation committee members and specific compensation proposals.

Davis Advisors exercises its professional judgment in applying these principles to specific proxy votes. Davis Advisors’ Proxy Procedures and Policies provide additional explanation of the analysis which Davis Advisors may conduct when applying these guiding principles to specific proxy votes. Conflicts of Interest A potential conflict of interest arises when Davis Advisors has business interests that may not be consistent with the best interests of its client. Davis Advisors’ Proxy Oversight Group is charged with resolving material potential conflicts of interest which it becomes aware of. It is charged with resolving conflicts in a manner that is consistent with the best interests of clients. There are many acceptable methods of resolving potential conflicts, and the Proxy Oversight Group exercises its judgment and discretion to determine an appropriate means of resolving a potential conflict in any given situation: (1) Votes consistent with the “General Proxy Voting Policies,” are presumed to be consistent with the best interests of clients; (2) Davis Advisors may disclose the conflict to the client and obtain the client’s consent prior to voting the proxy; (3) Davis Advisors may obtain guidance from an independent third party; (4) The potential conflict may be immaterial; or (5) Other reasonable means of resolving potential conflicts of interest which effectively insulate the decision on how to vote client proxies from the conflict.

Davis Advisors is a private limited partnership and considers its financial information to be confidential. Davis Advisors is financially strong and is unaware of any financial condition reasonably likely to impair its ability to meet its contractual commitments. Davis Advisors does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance.