Broad Run Investment Management LLC

Item 5 ‐ Fees and Compensation

Method of Compensation and Fee Schedule1
Asset‐Based Fee
An annualized asset-based fee will be assessed on each account under the firm’s supervision. Unless
otherwise negotiated, fees are calculated using the beginning account value for the quarter and are paid
quarterly, in advance, in accordance with the following table.

                       Assets Under Management*                                     Asset‐Based Fee Range
                               Up to $5,000,000                                     1.00% (100 basis points)
                        Amounts above $5,000,000                                     0.85% (85 basis points)

                      * Our minimum account size, subject to the firm’s discretion, is $1,000,000

Aggregating Account Fees
Our firm does not aggregate investment supervisory services accounts for the purpose of discounting its
asset‐based fee.

Negotiable Fees
Our firm reserves the right to negotiate fees at our discretion.

Client Payment of Fees
Client payment of advisory fees will be accomplished in the manner described in this section, unless
otherwise negotiated. Advisory fees will be assessed at the beginning of each quarter. The first billing cycle
will begin once the investment management agreement is executed with our firm and your account is
funded at the selected custodian.

If the investment management agreement begins on a date other than the beginning of a calendar quarter,
the first payment shall be (i) in arrears, payable upon completion of the first calendar quarter after the
agreement comes into effect; and (ii) prorated based upon the actual number of days during the quarter
that investment management services were provided. The account value for this computation shall be the
ending account value for the quarter.

After the first payment, or if the investment management agreement begins at the beginning of a calendar
quarter, fees shall be payable in advance on a quarterly basis. The account value for this computation shall
be the beginning account value for the quarter.

If the investment management agreement terminates on a date other than the end of a calendar quarter,
the fee payable shall be prorated based upon the actual number of days during the quarter that investment
management services were provided. The account value for this computation shall be the beginning
account value for the quarter. Any overpayment will be returned to the client.

  Our firm reserves the right to waive fees for its members and associates who maintain their accounts at our firm’s selected custodian(s); we may
offer a similar reduced fee to other firm related persons.

Broad Run Investment Management, LLC                            Form ADV Part 2A                                                     3/20/2026

Advisory fee assessments will be based on the account values as disclosed on the statement the client
receives from us. We will determine the value of both a client account’s assets and liabilities in the
following manner:

    •    Any security that is listed on a national securities exchange will be valued at its last sale price on the
         date of determination as recorded by the composite tape system, or, if the security is not included
         in such system, at its last sale price on such day on the principal national securities exchange on
         which such security is traded, as recorded by such exchange, or, if no sales occurred on such day, at
         the mean between the closing “bid” and “asked” prices on such day as recorded by such system or
         such exchange, as the case may be.

    •    Any security that is a National Market Security will be valued at its last sale price on the date of
         determination as reported by NASDAQ, or if no sale occurred on such day, at the mean between
         the closing “bid” and “asked” prices on such day as reported by NASDAQ.

    •    Any security not listed on a national securities exchange and not a National Market Security will be
         valued at the mean between the closing “bid” and “asked” prices on the day of determination as
         reported by NASDAQ, or, if not so reported, as reported in the over-the-counter market in the
         United States.

    •    All other securities shall be assigned a value by a portfolio manager of the firm or his/her designee
         in such manner as he/she may determine in good faith. Factors considered in valuing individual
         securities may include purchase price, estimates of liquidation value, existence of restrictions on
         transferability, prices received in recent significant private placements of securities of the same
         issuer, prices of securities of comparable public companies engaged in similar businesses, and
         changes in the financial condition and prospects of the issuer. Rights and options shall be valued in
         a manner consistent with market convention and a widely used quantitative valuation
         methodology.

For a more detailed discussion of advisory fee calculations please see our investment management
agreement.

By signing our firm’s investment management agreement and the selected custodian account opening
documents, you will be authorizing the withdrawal of transactional (see the following section) and firm
advisory fees from the account. All fees will be clearly noted on client account statements provided by the
custodian. Advisory fee payments will generally be assessed within 15 - 30 days following each billing cycle.

The withdrawal of advisory fees will be accomplished by the selected custodian, not by our firm, and the
custodian will remit our fee to our firm. Please note that the client will be responsible for verifying the
accuracy of the fee calculation; the custodian does not verify the accuracy of account fees.

Additional Client Fees
...

Item 7 ‐ Types of Clients

Description
Broad Run Investment Management, LLC will provide investment advisory services to both domestic and
foreign, taxable and tax-exempt individuals and institutions, including investment companies, trusts,
estates, families, charitable organizations, pension and profit‐sharing plans, other investment advisers,
state and municipal government entities, private investment funds, and other corporations and business
entities. Our firm provides investment advisory services to one mutual fund: the Hennessy Focus
Fund (the “Fund”). The Fund is established as a non‐diversified investment portfolio of Hennessy Funds
Trust, an open‐end series management investment company organized as a Delaware statutory trust.

Broad Run Investment Management, LLC            Form ADV Part 2A                                     3/20/2026

Our firm provides investment advisory services to certain third-party investment advisers’ clients. Our
suitability obligations with respect to such clients are limited only to investing the clients’ assets consistent
with a strategy determined to be suitable by the third-party investment adviser.

Account Minimums
Generally, the minimum amount of assets that a client must place under management to open a separate
account with us is $1,000,000, provided that such account minimums are subject to negotiation at the
firm’s sole discretion.