Bares Capital Management, Inc. Bares Capital Management, Inc. (“BCM”) was founded in 2000 by Brian T. Bares. The firm, located in Austin Texas, was originally registered with the States of Texas and Nebraska due to the amount of assets under management. In 2005 as assets under management passed $30 million, BCM became a registered investment adviser with the SEC. BCM is entirely owned by the principals of the firm, of which Mr. Bares is the only owner of 25% or more of the firm. BCM provides investment management services predominantly for institutional, pooled investment vehicle, family office clients, a small subset of high-net-worth individuals, mutual funds and trust programs. We manage our client accounts in long-only concentrated Small-Cap and Mid/Large-Cap equity strategies. In these strategies we invest in the equity of publicly traded companies predominantly domiciled in the United States. Our typical client in these strategies utilizes a number of other managers that specialize in different investment strategies from ours. This diversification at the manager level alleviates us from the need for a diversified portfolio in the traditional definition and allows us to remain invested in 8-12 of our best investment ideas in each Small-Cap and Mid/Large-Cap portfolio. We also offer less concentrated versions of the strategies mentioned above, called Small-Cap Extended and Mid/Large-Cap Extended strategies. In these strategies we hold 20-30 stocks and 15-20 stocks, respectively. Additionally, we manage a global concentrated equity strategy for a single client. This strategy is not actively marketed. BCM has been hired as a sub-adviser for a non-diversified mutual fund. More information can be found at: https://www.bbhfunds.com/us/en/our-funds/bbh-partner-funds/bbh- partner-fund-small-cap-equity.html

BCM serves as an investment adviser to the BCM Focus Small/Micro-Cap Fund, a series of the BCM Focus Funds Trust, a registered open-end investment company. Additional information can be found at: https://bcmfocusfunds.com/ As a manager of separate accounts, we have the ability to accommodate certain client- specific investment guidelines. Some clients have added Environmental, Social and Governance criteria, and others have specified maximum position size limits. These minor accommodations allow clients a certain level of account customization while still leveraging our existing investment and operational processes. We identify candidates for investment using fundamental research. We consider the financial condition of the candidate as well as qualitative factors relevant to the future performance of the candidate. Our qualitative research focuses on the competitive aspects of the business under consideration and an evaluation of management capability. In performing its services BCM is not required to verify any information received from the client or from the client’s other professionals. The investment advice we offer is limited to the equity or debt of publicly traded companies, mutual funds, and exchange traded funds we invest in. We do not offer tax planning advice or financial planning services. Clients have the right to impose restrictions on investing in certain securities or types of securities. This must be done in writing and be signed by the client and BCM. We will, no less than annually, send clients a market commentary that will generally include opinions and outlooks for specific investments or the market in general. This commentary will usually accompany one of the periodic quarterly portfolio statements. BCM does not sponsor or participate as a manager in any wrap fee program. Assets under management of BCM are held by independent custodians, including Charles Schwab, State Street, or others, in the client’s name. We do not act as a custodian of client assets, although we are at times considered by the SEC to technically have “custody” over certain accounts held at independent custodians. This occurs primarily because we are typically given authority to deduct management fees directly from client accounts. We will generally have discretionary authority over client accounts when implementing the investment strategy. See Item 16 Investment Discretion for more information about BCM’s discretionary authority. As of December 31, 2023, BCM managed $2,719,027,004 in regulatory assets under management, all on a discretionary basis.