The Small Cap Value Equity Composite has been examined for the period from January 1, 2011 through December 31, 2019. The examination report is available upon request.

The Cooke & Bieler Small Cap Value Equity Composite (Composite), whose inception date is August 1, 2008, includes all fully discretionary, fee paying, small cap value equity portfolios managed for more than one month. During 2012, the minimum market value for inclusion in the composite was $500,000. Prior to 2012, the minimum market value for inclusion was $2,500. For investment purposes, we generally define small cap equity securities as those of companies whose market capitalization is greater than $250m and within the Russell 2000® Index at initial time of purchase. Securities are selected using the firm’s fundamental, bottom-up approach. Portfolios are more concentrated, typically holding approximately 40-60 securities. The Composite was created in April 2010.

The standard fee agreement is 1% per annum on the first $20 million, 0.90 of 1% per annum on the next $20 million, 0.85 of 1% per annum on the next $20 million, and 0.80 of 1% per annum on the remaining balance, however fees are negotiable. Effective 7/1/2016, net of fee returns are calculated monthly by deducting one twelfth of the model fee rate of 1% across all accounts in the Composite. The Composite includes accounts that pay performance-based fees. Prior to 7/1/2016, net of fee returns reflect the deduction of actual management fees and are net of any performance-based fees. As of 12/31/20, less than 1% of composite assets are custodied with a broker that does not charge trading expenses. Accounts custodied with other brokers will incur trading expenses, which may reduce returns.

For comparison purposes, the Composite is measured against the Russell 2000® Value Index. The index returns are provided to represent the investment environment existing during the time periods shown and are not covered by the report of independent verifiers. Russell Investment Group is the source and owner of the trademarks, service marks and copyrights related to the Russell Indexes. Russell® is a trademark of Russell Investment Group.

Cooke & Bieler Additional Disclosures

Notes:

1. Cooke & Bieler, L.P. claims compliance with the Global Investment Performance Standards (GIPS^®) and has prepared and presented this report in compliance with the GIPS standards. Cooke & Bieler has been independently verified for the periods January 1, 1993 through December 31, 2019. The verification report is available upon request. A firm that claims compliance with the GIPS standards must establish policies and procedures for complying with all the applicable requirements of the GIPS standards. Verification provides assurance on whether the firm’s policies and procedures related to composite maintenance as well as the calculation, presentation, and distribution of performance, have been designed in compliance with the GIPS standards and have been implemented on a firm‐wide basis. Verification does not provide assurance on the accuracy of any specific performance report.
2. The Firm is defined as Cooke & Bieler, L.P., an independent investment management firm and is registered as an investment adviser under the Investment Advisers Act of 1940. Registration does not imply a certain level of skill or training.
3. Rates of return are expressed in U.S. dollars. Portfolios are valued monthly on a trade date basis. Portfolio returns reflect the reinvestment of dividend and interest income.
4. Performance returns are presented both gross and net of fees. Gross of fee returns do not reflect the deduction of investment advisory fees. Individual client returns will be reduced by investment advisory fees and other expenses that it may incur in the management of its investment advisory account. Investment advisory fees are described in Part 2A of Form ADV. On an exception basis, the actual fee charged may depend on the asset size, client location and type of portfolio.
5. The dispersion is measured using an asset weighted standard deviation of portfolio gross returns represented within the Composite for the full year. For those annual periods with less than five portfolios included for the entire year, dispersion is not presented as it is not considered to be meaningful.
   
6. A list of composite descriptions is available upon request. Policies for valuing investments, calculating performance, and preparing GIPS Reports are also available upon request.
   
7. For comparison purposes, each index is fully invested and includes the reinvestment of income. The returns for each index do not include any transaction costs, management fees or other costs.
8. The three-year annualized ex-post standard deviation measures the variability of the composite (using gross returns) and the benchmark for the preceding 36-month period. The three-year annualized ex-post standard deviation is not required to be presented for periods prior to 2011 or when 36 monthly composite returns are not available.
9. GIPS® is a registered trademark of CFA Institute. CFA Institute does not endorse or promote this organization, nor does it warrant the accuracy or quality of the content contained herein.
10. Past performance is not indicative of future results.