Bridgeway Capital Management LLC

Item 5         Fees and Compensation

General Fee Information

Bridgeway charges clients an advisory fee based either on a percentage of the account’s market
value (“asset-based fee”) or a combination of asset-based and performance-based fees (fees based
on a share of capital gains or capital appreciation of the assets of a client). Asset-based fees are
typically billed quarterly in advance, while performance-based fees are billed quarterly in arrears.
Fees are pro-rated for partial periods. Performance-based fees are based on the performance of
the account relative to a stock market index or a hurdle rate. Fees are deducted directly from
client accounts or paid directly based on client written direction. 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 as
in accordance with the client’s investment advisory agreement and/or governing documents.

                                                                                          4479025v.2

                              Bridgeway Capital Management, LLC
                                      Form ADV Part 2A
                                        March 30, 2026

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                <$50M $50-$100M >$100M               Account       Minimum
                                                                           Asset         Annual
                                                                         Minimum          Fee
 Emerging Markets Small-Cap          1.25%        1.25%        1.25%     $10 million    $125,000
 Global Opportunities                1.25%        1.25%        1.25%     $10 million    $125,000
 Aggressive Investors 1              1.50%        1.50%        1.50%     $10 million    $150,000
 Ultra-Small Company Market          0.70%        0.65%        0.60%     $10 million     $70,000
 Small-Cap Value                     0.75%        0.65%        0.60%     $10 million     $75,000
 Omni Small-Cap Value                0.70%        0.65%        0.60%     $25 million    $175,000
 Blue Chip                           0.20%        0.15%        0.15%     $50 million    $100,000

For clients invested in separate accounts in the Emerging Opportunities strategy, Bridgeway
charges clients an asset-based fee of 1.00% per year and performance-based fees. Performance-
based fees amount to 10% 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’
...

Item 7         Types of Clients

Bridgeway provides investment management services to institutions, mutual funds, ETFs, high net
worth individuals, pension and profit sharing plans, corporations, trusts, estates, charitable/non-
profit organizations, collective investment trusts, private funds, government entities and model
manager accounts. All clients are required to enter into an investment advisory agreement prior
to Bridgeway providing any services. Client account minimums are disclosed in Item 5.

                                                                                           4479025v.2

                              Bridgeway Capital Management, LLC
                                      Form ADV Part 2A
                                        March 30, 2026

Bridgeway also manages separate accounts for family members of staff. These clients receive
standard client reporting and are not involved in day-to-day operations of the firm. 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 sub-
advised mutual funds and ETFs that Bridgeway manages.