(MENAFN- ValueWalk) >Tweedy Browne Insider + Value ETF's commentary for the third quarter ended September 30, 2025.

Table of Contents

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• Approach And Process
• Portfolio Positioning
• Attribution
• Purchases And Sales
• New Fund Launch: Tweedy, Browne International Insider + Value ETF (ICPY)
• Outlook

It was another extraordinarily buoyant period for global equity markets during the third quarter, with both US and non-US equity markets continuing to achieve new record highs as measured by broad market-capitalization weighted indices such as the S&P 500 Index (“S&P 500”), the MSCI World Index and the MSCI EAFE Index. The S&P 500 finished the third quarter up 8.12% and is up 14.83% year-to-date. Popular valuation metrics such as the“Buffett Indicator”1 and the CAPE-Shiller P/E2 are now at or near record highs as of September 30. And this has come on the heels of the S&P 500's back-to-back 26% and 25% calendar year end returns in 2023 and 2024. Non- US equity markets also were up solidly during the quarter but soared well ahead of US equity returns for the year-todate measurement period.

In this continued“risk on” environment, the Tweedy Browne Insider + Value ETF (“COPY”) experienced positive returns but trailed its benchmark index for the quarter (5.05% versus 7.27% for the MSCI World Index). Over the year-to-date period, COPY outperformed its benchmark, producing a return of 22.45% versus 17.43% for the MSCI World Index, and since inception the Fund is up 23.12% versus the benchmark's 15.25% return.

While US equities performed extraordinarily well over the year-to-date period, the good news for investors in COPY is that non-US equities, particularly European equities, have performed well in US dollars over the same period, producing returns that exceeded those of the S&P 500. We still believe valuations are more compelling outside the US, and as of quarter end, COPY was overweight non-US equities versus its benchmark index (COPY: 71.0% of non-US equities versus MSCI World: 30.4% non-US equities). While currency played a significant role in the outperformance of non-US equities in US dollars, we welcome the value recognition in non-US equities that has occurred year-to-date, which in our opinion, is long overdue.

Aside from currencies' role, it is hard to know for sure what is driving this resurgence in non-US equities. We believe that perhaps the decline in so-called US exceptionalism, and for sure, a weakening US dollar, has played a significant role. In addition, we believe it could partly be due to the prospects for robust defense and infrastructure spending in Europe, and/or the valuation gap that has existed for over a decade and continues to persist between US and non-US equities (see the chart that follows). This gap remains significant despite the outperformance of non-US equities year-to-date. We believe that in a world where inflation remains persistent and interest rates are normalizing at levels far above the zero bound of the not-too-distant past, price once again matters in investing.

Relative Valuations Of International Indexes vs S&P 500 Trailing P/E Ratios / P/E Ratio Of S&P 500

Approach And Process

Tweedy's new ETF is distinguished not only by its valuation discipline, informed by decades of the firm's steadfast adherence to a Benjamin Graham-based, price-driven investment philosophy, but also by its emphasis on coattailing the purchase behavior of knowledgeable C-suite executives. These are corporate insiders who are buying shares in their own companies or returning capital to shareholders through meaningful share buybacks. When paired with our proprietary multi-factor value model, this insider-focused lens has enabled us to build a portfolio of fundamentally sound and undervalued businesses with management teams that think like owners-in our view, a rare yet valuable combination.

This focus on insider purchase behavior also helps us capitalize on what we refer to as the“insider's edge,” i.e., the unique insights that senior executives and informed directors can have regarding the prospects for improvement in their company's condition, and ultimately, its share free price. Empirical evidence from academic and professional studies, including our own proprietary research, supports the efficacy of this common-sense approach that pairs insider buying with undervaluation.

While COPY's investment approach is largely quantitative and factor-driven, combining insider purchase data and value-oriented statistical metrics to identify investment candidates across multiple geographies and market capitalizations, the research process does employ a light qualitative review to ensure data integrity. This review helps ensure that insider purchases were free-will (voluntary) purchases, and that there were no overarching issues that our model may have failed to address.

Portfolio Positioning

As of September 30, COPY was diversified by issue, country, industry, and market capitalization. The portfolio consisted of equity securities from the United States, Europe, the United Kingdom, and across Asia, and it included the more developed of the emerging markets. While the Fund has benefited from this diversified posture, its portfolio constituents bear little resemblance to its benchmark index, and as of September 30 had an“Active Share”3 of 96.9. Its regional, country, industry, and market capitalization exposures also vary considerably from those of the benchmark.

As of September 30, the Fund was invested in 181 individual equities across 22 countries, including the US These holdings spanned 10 sectors, and 48 industries, as classified by GICS4. The largest country allocations were the US (29.4% of equities), the UK (13.7%), and Canada (10.7%), followed by Germany (7.4%), South Korea (6.6%), and Sweden (5.2%).

From a sector standpoint, the Fund's largest weightings were in Financials (29.2% of equities), Consumer Discretionary (14.7%), and Industrials (11.8%). Notable industry weightings included banks (15.7% of equities), oil & gas (10.0%), insurance (5.4%), capital markets (4.9%), metals & mining (4.2%), media (3.1%), and automobile components (3.1%).

While market capitalizations will vary over time, the Fund currently skews toward small- and medium capitalization companies, with 78% of the equity holdings having market capitalizations of $25 billion or less.

As of quarter end, the Fund had a weighted average price-to-earnings ratio (2026 estimated earnings) of 11.7X, an average annual dividend yield5 of 3.59%, an active share of 96.9%, and assets under management totaling approximately $158.8 million.

Attribution

The Fund's results were led by holdings in the Financials, Energy, and Materials sectors. Financials benefited from strength in US and Canadian banks and insurers. Energy holdings advanced, while Materials names such as diversified miners and metals producers also contributed positively. At the country level, strong results in the United States, Canada, and Spain were partly offset by weaker performance in Germany and France, where a few industrial and media-related holdings detracted.

Among individual holdings, Resideo Technologies, DPM Metals, Ionis Pharmaceuticals, and Samsung Electronics were notable contributors, while Crocs, CNH Industrial, and Prosiebensat.1 Media detracted. We believe these short-term fluctuations do little to alter our long-term investment case.

From a currency perspective, the US dollar strengthened modestly during the quarter, resulting in a slight headwind to overall returns. The Fund's currency unhedged structure meant that weakness in the euro, British pound, and Canadian dollar dampened results, though this was partially offset by strength in several emerging-market currencies.

Purchases And Sales

During the quarter, we initiated several new positions that, in our opinion, met our criteria for both insider conviction and undervaluation. We've highlighted a few below:

• Vertex Pharmaceuticals – President & CEO Reshma Kewalramani purchased $3.9 million worth of shares on 6 August 2025 at $389.58 and Director Bruce Sachs purchased $1.9 million worth of shares on 6 August 2025 at $389.68. We believe the company's leadership in cystic fibrosis treatment and promising gene therapy pipeline remains underappreciated relative to its intrinsic value.
• Allison Transmission Holdings – COO Frederick Bohley purchased $266k worth of shares on 14 August 2025 at $88.50. Allison designs and manufactures transmissions for largely commercial and some defense vehicles. Allison's core addressable market are Class 6-7 trucks (like beverage delivery vehicles, dump trucks, etc.) where they have a high market share. While their transmissions are sold at a high margin, they also improve reliability and resale value. According to our calculations, at initial purchase, Allison was trading at less than nine times trailing twelve month (TTM) earnings.
• Western Union – President & CEO Devin McGranahan purchased $1.5 million worth of shares on 21 August 2025 at $8.49. Western Union is a leader in cross-border, cross-currency movement that sends money and/or payments around the world. The company's brand is recognized globally, and the company claims the brand represents speed, reliability, trust, and convenience. At our initial purchase, Western Union was trading at less than four times TTM earnings, and less than six times enterprise value to EBITA (earnings before interest, taxes, and amortization).
• Fugro NV – CEO Mark Heine purchased $134k worth of shares on 1 August 2025 at EUR 11.56, and Chairman S.S. Vollebregt purchased $230k worth of shares on 1 August 2025 at EUR 11.45. This Dutch company collects, processes, and interprets geological data which is used in the building of offshore oil platforms, tunnels, roads, pipelines, factories, and communication cables, and to explore for oil, gas and minerals. the stock has come under pressure recently because of a recalibration of the offshore wind-market in the United States and an unfavorable oil and gas market supply/demand balance. At our initial purchase, Fugro was trading at approximately ten times TTM earnings.
• Elevance Health – President & CEO Gail Boudreaux purchased $2.4 million worth of shares on 18 July 2025 at $286.94, and Director Susan DeVore purchased $375k worth of shares at $312.15 after the company was added to the ETF. Elevance Health, formerly known as Anthem, operates as one of the US' largest for-profit managed health-care insurers. Like UnitedHealth, which has also been added to the ETF after recent insider purchases, Elevance has been hit by elevated utilization and a mismatch in rates. Since Q1, Centene, Molina, and now Elevance have materially revised 2025 guidance. Elevance leads in its 14 Blue Cross / Blue Shield states where it is the exclusive licensee of the Blue Cross / Blue Shield brand. Elevance's management is targeting 12% long-run compounded adjusted EPS growth per annum. At our initial purchase, Elevance was trading at approximately nine times TTM earnings.

Conversely, we trimmed or exited positions in Ligand Pharmaceuticals, U-Haul Holding Company, HighPeak Energy, ProFrac Holding, and Polestar Automotive, largely for valuation reasons or to reallocate capital toward higher-conviction ideas.

These portfolio actions reflect our ongoing efforts to exploit meaningful discrepancies between price and value and to invest where management's actions align with shareholders.

New Fund Launch: Tweedy, Browne International Insider + Value ETF (ICPY)

In early September, we launched the Tweedy, Browne International Insider + Value ETF (ICPY), a new international counterpart to COPY. Like the global version, ICPY combines our traditional value discipline with evidence-based insights drawn from corporate insider activity and share repurchase behavior. The Fund applies the same rules-based investment framework but focuses exclusively on non-US companies. In our opinion, ICPY represents a natural extension of our investment philosophy and provides investors with an efficient, globally diversified way to participate in our insider-informed value approach. We are encouraged by the early response to COPY and view ICPY as an important complement for investors seeking long-term international exposure within a disciplined value framework coupled with strong corporate engagement.

For more information, see the International Insider + Value ETF Prospectus

All investing involves the risk of loss, including the loss of principal.

Outlook

Looking ahead, we are encouraged by the resurgence of non-US equity returns and believe the Insider + Value ETF is extraordinarily well positioned for whatever may lie ahead. If there has indeed been a sea change in our global equity markets favoring non-US equities, COPY will likely continue to participate. However, should global equity markets face a long overdue come-uppance, we take comfort in the Fund's price driven investment approach and the collateral value backing up the Fund's portfolio constituents. In our long experience, Tweedy's value-oriented portfolios have typically gained the most ground against indexes in challenging investment environments. While there are no guarantees that this will hold true for COPY, in the event of a downturn, we are hopeful that pattern will persist. We believe that a diversified portfolio of well-capitalized, competitively advantaged companies purchased at attractive valuations, and informed by the purchase behavior of knowledgeable corporate“insiders” may provide the best defense against market uncertainty and resultant volatility. If the past is prologue, that positioning should continue to serve us, and our investors, well over time.

We thank you for your continued trust and confidence.

Roger R. de Bree, Andrew Ewert, Frank H. Hawrylak, Jay Hill,

Thomas H. Shrager, John D. Spears, Robert Q. Wyckoff, Jr.

Investment Committee

Tweedy, Browne Company LLC

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