Bridgeway Capital Management, LLC: investment adviser

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.

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 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 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.

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.

Ultra-Small Company Market – Bridgeway’s Ultra-Small Company Market strategy seeks to provide long-term capital appreciation through a broadly diversified, low turnover approach to investing in the smallest publicly traded stocks. 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 with similar sector and size composition as the universe of the smallest 10% of U.S.-listed stocks. However, Bridgeway may exclude companies that it views as likely to underperform the ultra-small company market. Investments in ultra-small companies generally carry greater risk than is customarily associated with large, small and even micro13

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 purchase stock market index futures and ETFs in order to equitize cash.

Small-Cap Value – Bridgeway’s Small-Cap Value strategy seeks to provide long-term total return on capital, primarily through capital appreciation. For purposes of this strategy, Bridgeway defines small-cap as those companies with a market capitalization of less than $15 billion at the time of purchase. Bridgeway intends to invest in small-cap companies that it determines are in the lowest 10% of total market capitalization or smaller than the 1,000th largest U.S. company when ranking these stocks in order of market capitalization. Bridgeway selects stocks in the small-cap value category using a statistical approach. Value stocks are those that Bridgeway believes are priced cheaply relative to some financial measures of worth, such as price to earnings, price to sales, or price to cash flow. 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. Investing in value stocks carries the risk that the market will not recognize a security’s book value or that a stock thought to be under-valued is appropriately priced. 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.

Omni Small-Cap Value - Bridgeway’s Omni Small-Cap Value strategy seeks to provide long-term total return on capital, primarily through capital appreciation. The benchmark for this strategy is the Russell 2000 Value Index. Bridgeway selects stocks in the smallcap value category using a statistical approach. For purposes of this strategy, Bridgeway considers small-cap stocks to be those of companies that have a market capitalization generally in the lowest 10% of total market capitalization or smaller than the 1000th largest U.S. company, whichever results in the higher market capitalization break. Using a market capitalization weighted approach, this strategy invests in a broad and diverse group of small-cap stocks determined to be value stocks. Value stocks are those that Bridgeway determines are priced cheaply relative to some financial measures of worth, such as the ratio of price to book, price to earnings, price to sales, or price to cash flow. Investing in value stocks carries the risk that the market will not recognize a security’s book value or that a stock thought to be under-valued is appropriately priced. 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 foreign securities. Investment in foreign securities can be more volatile than investments in U.S. securities.

Blue Chip – Bridgeway’s Blue Chip investment strategy seeks to provide long-term, total return of capital through price appreciation and some dividend income. The income objective of this style is achieved almost exclusively from dividends paid by some invested stocks. The benchmark for this strategy is the S&P 500 Index. The selection of stocks for accounts in the Blue Chip strategy uses a statistical approach. The portfolio invests in approximately 35 of the largest U.S. domiciled companies measured by stock market capitalization. The distinctive attributes of the strategy are its low cost structure and roughly equal weighting of stocks held. Large companies tend to exhibit less price volatility than small companies; however, historically they have not recovered as fast from a market decline. Therefore, this strategy may expose clients to higher inflation risk than some other stock market investments.

Other Risks In addition to the strategy specific risks identified above, client accounts are subject to general market risks. Client accounts could lose value if the individual securities in which they have invested and/or the overall stock markets on which the stocks trade decline in price. Stocks and stock markets may experience short-term volatility (price fluctuation) as well as extended periods of price decline or little growth. Individual stocks are affected by many factors, including: corporate earnings; production; management; sales; and market trends, including investor demand for a particular type of stock, such as growth or value stocks, small-or large-cap stocks, or stocks within a particular industry. Market risks, including political, regulatory, market, economic and social developments, and developments that impact specific economic sectors, industries or segments of the market, can affect the value of the investments in client accounts. In addition, turbulence in financial markets and reduced liquidity in the markets may negatively affect many issuers, which could adversely affect client accounts. These risks may be magnified if certain social, political, economic and other conditions and events (such as natural disasters, epidemics and pandemics, terrorism, conflicts and social unrest) adversely interrupt the global economy; in these and other circumstances, such events or developments might affect companies world-wide and therefore can affect the value of the investments in client accounts. Securities purchased and held in client accounts may decline in value because of a general decline in the market. Securities markets also move in cycles, with periods of rising prices followed by periods of falling prices. The value of the securities held in client accounts will tend to increase or decrease in response to these movements. Client accounts are also subject to investment style risk. A client account

invested in one of Bridgeway’s investment strategies, as described above, involves the risk that the investment strategy may underperform other investment styles or the overall market. Bridgeway’s investment process involves statistical research and modeling. Extensive computer programming is required to implement that process. Although Bridgeway seeks to hire skilled professionals and to provide appropriate oversight and training, the complexity of the tasks and the limited ability to represent market conditions during testing increases the probability of a model error. Such errors could result in losses in a client’s portfolio and would generally not be subject to reimbursement. While Bridgeway’s strategies primarily utilize statistical models and automated processes, the activities and decisions of the Bridgeway's staff play a vital role in the Bridgeway's investment approach. Bridgeway’s staff make subjective decisions in designing, implementing, monitoring, and executing its investment strategies, including determinations in connection with developing and making changes to statistical models (e.g., the timing of implementation, the level of testing required, the setting of various parameters, implementing risk limits). Bridgeway does not offer any products or services that guarantee rates of return on investments for any time period to any client. All clients assume the risk that investment returns may be negative or below the rates of return of other investment advisers, market indices or investment products. Use of futures to manage risk or equitize cash may not always be successful, futures prices can be highly volatile, they may not always successfully manage risk and they could lower total return. ESG Risk The incorporation of ESG considerations in certain of Bridgeway’s strategies may cause Bridgeway to make different investment decisions than if ESG considerations were not incorporated into the investment process. As with the use of any considerations involved in investment decisions, there is no guarantee that the ESG investment considerations used by Bridgeway will result in the selection of securities that will outperform other securities or help reduce risk in the strategy. Bridgeway’s strategies may underperform strategies that do not incorporate these considerations. However, as noted above, ESG information is just one investment consideration and ESG considerations are not solely determinative in any investment decision made by Bridgeway.

Natural Disaster/Epidemic/Pandemic Risk Natural or environmental disasters, such as earthquakes, fires, floods, hurricanes, tsunamis and other severe weather-related phenomena generally, and widespread disease, including pandemics and epidemics, have been and can be highly disruptive to economies and markets, adversely impacting individual companies, sectors, industries, markets, currencies, interest and inflation rates, credit ratings, investor sentiment, and other factors affecting the value of client accounts. Given the increasing interdependence among global economies and markets, conditions in one country, market, or region are increasingly likely to adversely affect markets, issuers, and/or foreign exchange rates in other countries, including the U.S. These disruptions could prevent Bridgeway from executing advantageous investment decisions in a timely manner and negatively impact Bridgeway’s ability to achieve the investment objectives of its investment strategies. Any such event(s) could have a significant adverse impact on the value of client accounts and the risk profile of Bridgeway’s investment strategies. Cybersecurity Risk Bridgeway and its service providers rely on information technology and electronic communications to conduct business, which introduces the risk of cybersecurity breaches. Cybersecurity breaches, amongst other risks, could cause a business disruption and/or allow unauthorized access to confidential information and client data. While Bridgeway and its service providers have controls designed to reasonably protect against cybersecurity breaches, not all cyber incidents are preventable. As a result of investment in a portfolio, clients may be impacted by such cybersecurity breaches. Artificial Intelligence Risk Bridgeway uses certain Artificial Intelligence (“AI”) tools in its investment process for risk management purposes. These AI tools include Bayesian Shrinkage, Non-Linear Shrinkage, Hard Thresholding and Singular Value Decomposition and are overseen by Bridgeway’s Investment Management Team. These AI tools are not applied in an automated fashion to systematically make investment decisions but rather are applied manually and on a discretionary basis to identify and understand market risks. Bridgeway also receives data from a third-party vendor that uses a structured approach to natural language processing to transform qualitative language from financial reports, earnings-call transcripts and other corporate disclosures into usable data. The Investment Management Team may incorporate data from this vendor into the ongoing assessment of portfolio positions on a discretionary basis. Bridgeway also uses AI software for meeting transcription and notetaking. Given the rapidly evolving nature of AI tools, Bridgeway may begin using AI for other purposes in the future. Use of AI and machine learning technology can result in enhanced productivity and efficiency, however use of such technology also leads to additional risk to Bridgeway and its clients. AI tools could potentially rely on outdated, inaccurate, incomplete or biased data which

could create inaccurate output. Use of AI tools creates risk around security, privacy and confidentiality of data entered into AI tools. Additionally, because of the evolving nature of AI technology and common uses by businesses in the financial service industry, AI use could be subject to rapidly evolving regulatory environment which may impact if and how Bridgeway is able to use AI in the future. Finally, Bridgeway’s service providers may utilize AI tools, potentially without Bridgeway’s knowledge, despite efforts to oversee such service providers, leading to additional AI risk exposure. Bridgeway maintains an Artificial Intelligence Policy to govern the use of AI which aims to ensure any risks or conflicts of interest associated with such tools are evaluated and mitigated. The Artificial Intelligence Policy includes provisions for the review and approval of AI tools prior to their use, a requirement for human oversight of the output of any AI tool, controls around maintaining the confidentially of data associated with AI tools and a requirement that Bridgeway employees be appropriately trained on AI use and related risks. Other Information When Bridgeway manages multiple accounts within a strategy, the investment return and tax efficiency of an account may be higher, lower or similar to the total returns and tax efficiency of other accounts within the strategy. Bridgeway maintains investment and trade allocation policies and procedures designed to address potential conflicts of interest such as securities being held in client accounts overlapping across strategies or favoring certain strategies based on whether the strategy is open or closed to client investments.

Omni Small-Cap Value Fund

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

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 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

above). In order to determine which group of accounts will be executed first, the trader will activate the automated Chart Order function within Charles River Development (“CRD”), Bridgeway’s trade order management system. A random number is assigned to each order by CRD and the trader executes the order with the lowest value first. Any exceptions to the random chart order process are documented and reviewed. Trade Allocation for U.S. Strategies The following information applies when Bridgeway is responsible for trading of the client account. Trades for accounts can be executed by multiple brokers, platforms and/or networks at different prices. Trades for brokerage accounts are generally placed through the broker/custodian firm for a specific account unless Bridgeway determines it is in the brokerage account’s best interest to trade elsewhere in the pursuit of best execution. In either case, Bridgeway may receive full or partial fills resulting in a variation of prices received for execution of a given security. In order to minimize the number of trade tickets generated and maintain the efficiency of the trading process, Bridgeway does not average all trades executed by multiple brokers on a given trading day. Bridgeway utilizes the random trade allocation function within its trade order management system to allocate executed trades to client accounts. The random allocation of trades applies to partial and completed execution situations, with the exception of partial fills involving inter-portfolio trades which are allocated pro rata. Fills received from broker/custodians are allocated to the designated brokerage accounts. Under certain circumstances, Bridgeway’s policies permit deviation from the practices described above. Exceptions to trade allocation procedures are documented and reviewed by the Best Execution Committee and Compliance. Trade Aggregation and Allocation for International Strategies The Emerging Markets Small-Cap private fund invests in physical securities and is the only account managed to the Emerging Markets Small-Cap strategy and is not aggregated nor allocated with any other accounts. Trade Aggregation and Allocation for Absolute Return Strategies Accounts managed in an Absolute Return strategy which includes both client and proprietary accounts invest only in swaps and generally trade in a basket therefore trades in these strategies are generally not aggregated nor allocated with any other account managed in another Absolute Return strategy or in an International or U.S. strategy as such strategies invest in physical securities. Client accounts managed in an Absolute Return strategy employ a trade rotation policy when investment management determines it is appropriate for more than one client account to be traded. Client accounts are prioritized over proprietary accounts managed in an Absolute Return strategy. In certain circumstances, for example when there is potential for a short squeeze in an underlying security held short across multiple Absolute Return strategies and/or accounts (including both

client and proprietary accounts), Bridgeway may combine the orders and close out the position across all applicable accounts at the same time. The decision to combine orders to close out a position across all applicable accounts is based on a variety of factors including, but not limited to, factors related to a specific country, industry, and/or company or market news or movement impacting the security. Bridgeway will not combine orders to close out a position if it is anticipated that doing so would harm any client account, for example if there is low liquidity for the underlying security. Decisions to combine accounts for trading are documented and Bridgeway’s Best Execution Committee reviews reporting related to combined orders on a quarterly basis. Inter-Portfolio Trades Bridgeway may cross trades between two client accounts (“inter-portfolio trades”), including the Bridgeway Funds, when it is in the best interest of each client participating in the transaction. Bridgeway will not engage in inter-portfolio trades with ERISA clients or between a client account and the private fund managed by BCM or between a client account and a proprietary account. All inter-portfolio trades will be done in accordance with the Inter-Portfolio Trades Policy and are reviewed by the Best Execution Committee on a quarterly basis. Trade Errors It is Bridgeway’s policy that: (i) trade errors affecting client accounts be identified and, if necessary, corrected expeditiously; (ii) the interests of clients are paramount and come before the interests of Bridgeway or any director, officer or staff member of Bridgeway; and (iii) trade errors are handled in a manner that addresses conflicts of interest with Bridgeway and its clients. Trade errors will be addressed in a manner that is in compliance with Bridgeway’s written Trade Error Policies and Procedures. Generally, a trade error is an error made by a trader in the placement, execution or settlement of a trade for a client’s account or an operational related issue that requires a trade to be corrected. Trade errors do not include good faith errors in judgment or application in making particular investment decisions for clients. Trade errors do not include errors that occur in the development and maintenance of Bridgeway’s statistical models used in the investment management process. Process enhancements, errors or other incidents that occur in connection with Bridgeway’s design, programming or use of models and/or data sources in the investment management process are not considered trade errors. While it is not possible to describe all situations and possible solutions involving a trade error that Bridgeway may encounter, it is the responsibility of the trader(s), and Investment Operations Team, as appropriate, to promptly report each potential trade error to the Chair of the Best Execution Committee. The Chair of the Best Execution Committee is responsible to notify the Compliance Team and Investment Management Team of the potential error and to review each potential trade error on a case by case basis to determine a course of action, including any corrective action and whether compensation is required to a client, in consultation with the CCO, Investment Management Team, Investment Operations Team, and the Finance and Talent Team, as appropriate.

It is Bridgeway’s policy for clients to be made whole following a trade error. An identified trade error will generally be corrected as follows: (i) any gain accrues to the benefit of the client account; and (ii) any loss will be reimbursed to the client’s account, including any commission expenses. A trade error identified before the settlement date of the trade, in a rare circumstance may be run through a proprietary error account. The gain or loss associated with the trade error will generally be handled as follows: (i) any gain accrues to the benefit of the client; and (ii) any loss will be to the detriment of Bridgeway, including any commission expenses. On occasion, a custodian may have a de minimis policy where Bridgeway is not permitted to reimburse trade errors resulting in a loss below an amount determined by the custodian. In such circumstances, the custodian may absorb the loss and there is no financial impact to the client. Likewise, if a trade error results in a gain less than the de minimis amount, the custodian will keep the gain. All trade errors will be corrected within a reasonable period of time following discovery of the error.

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.

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.

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.

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.