Tweedy, Browne Company LLC (the “Firm”) is registered with the SEC as an investment adviser. It is the
successor to Tweedy & Co., which was established in 1920 as a dealer in closely held and inactively traded
securities. The Firm has been registered with the SEC as an investment adviser since 1975. The Firm’s 100-
year history is grounded in undervalued securities, first as a market maker, then as an investor and
investment adviser. (The Firm ceased operations as a broker-dealer effective October 1, 2014.) The Firm is
majority owned by Affiliated Managers Group, Inc. (“AMG”) through a wholly-owned subsidiary, AMG
TBC, LLC, by its Managing Directors, and by certain other employees. AMG is a New York Stock Exchange
listed company that owns interests in a diverse group of investment management firms. The Firm’s
Management Committee, which is composed of Thomas H. Shrager, John D. Spears, Robert Q. Wyckoff,
and Jay Hill, is responsible for the day-to-day operation and overall supervision of the Firm. AMG does
not generally have any active role in the day-to-day management of the Firm. The Firm’s Investment
Committee, which is composed of Roger R. de Bree, Andrew Ewert, Frank H. Hawrylak, Jay Hill, Thomas
H. Shrager, John D. Spears and Robert Q. Wyckoff, Jr., is the body responsible for making investment
decisions for client accounts. (See Part 2B for more information on the Investment Committee.) William
H. Browne acts as Senior Advisor to the Investment Committee.
The Firm manages accounts on a discretionary basis. As of December 31, 2023, the Firm managed
approximately $8,770,000,000 in discretionary client assets. (This figure includes the net assets of all pooled
vehicles managed and sponsored by the Firm, as described on pages 5 and 6 herein, as well as all separately
managed accounts. As prescribed by SEC rules, the Firm’s Form ADV Part 1 lists the Firm’s regulatory
assets under management as of December 31, 2023, which reflect the gross assets of all such vehicles and
accounts.) Assets under management are as of the date indicated, subject to fluctuation, and
not necessarily
representative of current assets under management.
The Firm offers investment advisory services that are concentrated in one strategy -- value investing (see
Item 8 below for more information about the Firm’s value investing methodology.) The Firm focuses its
investment advice on equity securities of U.S., international, and global issuers, and the Firm's advice is
generally limited to those types of investments. The Firm also uses forward currency contracts to hedge
perceived foreign currency exposure, where practicable, for clients that invest in foreign securities and
request that the Firm do so. The Firm may also provide advice with respect to other investments on a
more limited basis.
All client accounts managed by the Firm are invested according to a value investment strategy, with a focus
(at each client’s direction) on international, global, global high dividend, or U.S. and ADR equity
investments. Thus, international client accounts will primarily invest in securities issued by companies
that are located outside, or that derive a large portion of their revenues from activities outside, the United
States; while global and global high dividend client accounts will primarily invest in securities issued by
companies that are located, or derive a large portion of their revenues from activities, both outside and
within the United States. U.S. Equity/ADR client accounts will primarily invest in securities of issuers
located in the United States and in American depositary receipts, which represent shares of non-U.S.
companies that trade in the U.S. financial markets, and may, to a limited extent, invest in other foreign
securities. The Firm’s value strategy may be tailored to some extent to meet individual client needs. For
example, clients may request that their accounts be restricted from investing in certain securities or types
of securities. Clients should be aware that imposing such restrictions could cause their accounts to
underperform or perform differently than other client accounts that are managed without such restrictions.