GIVERNY CAPITAL ADVISORS

Firm Brochure (Part 2A of Form ADV) Giverny Capital Advisors LLC 182 Nassau Street, Suite 201 Princeton, NJ 08542 T: (609) 759-1250 F: (609) 751-9074 pleger@givernycapital.com This brochure provides information about the qualifications and business practices of Giverny Capital Advisors LLC. If you have any questions about the contents of this brochure, please contact us at: (609) 759-1250, or by email at pleger@givernycapital.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Disclaimer: Registration as a “Registered Investment Advisor” does not necessarily imply a certain level of skill or training with regulatory authorities. Additional information about Giverny Capital Advisors LLC is available on the SEC’s website at www.adviserinfo.sec.gov 03/30/26 Giverny Capital Advisors LLC  Material Changes Annual Update Giverny Capital Advisors filed its last Annual Amendment to the Firm Brochure on March 30, 2025. The Material Changes section of this brochure will be updated annually when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update The Firm continues to conduct its business activities and provide investment advisory services in substantially the same manner as described in the last update to the Firm Brochure. The ensuing is only a list of changes since the last update that are or may be considered material. It does not identify every change to the Firm Brochure since the last update. In addition, there have been minor word enhancements and clarifications throughout the Firm Brochure. In item 17, the information regarding proxy voting was updated to disclose that the Firm uses an online platform from a third party services provider. Full Brochure Available Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at: (609) 759-1250 or by email at: pleger@givernycapital.com. i Giverny Capital Advisors LLC  Table of Contents Material Changes............................................................................................................ i Annual Update ............................................................................................................ i Material Changes since the Last Update .................................................................... i Full Brochure Available ............................................................................................... i Item 4: Advisory Business ........................................................................................... 1 Item 4A: Firm Description .......................................................................................... 1 Item 4B: Types of Advisory Services ......................................................................... 1 Item 4C: Tailored Relationships ................................................................................. 2 Item 4D: Wrap Fee Programs .................................................................................... 2 Item 4E: Client Assets ................................................................................................ 2 Investment Advisory Agreement ................................................................................ 2 Item 5: Fees and Compensation .................................................................................. 3 Item 5A: Description ................................................................................................... 3 Item 5B: Fee Billing .................................................................................................... 3 Item 5C: Other Fees .................................................................................................. 4 Item 5D: Prepayment ................................................................................................. 5 Item 5E: Compensation for Sale of Securities ........................................................... 5 Item 6: Performance-Based Fees & Side-by-Side Management ................................ 6 Item 7: Types of Clients ................................................................................................ 6 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................... 7 Item 8A: Methods of Analysis .................................................................................... 7 Item 8B: Investment Strategies .................................................................................. 7 Item 8C: Risk of Loss ................................................................................................. 7 Item 9: Disciplinary Information ................................................................................... 9 Legal and Disciplinary ................................................................................................ 9 Item 10: Other Financial Industry Activities and Affiliations ..................................... 9 Item 10A: Registrations .............................................................................................. 9 Item 10B: Other Registrations .................................................................................... 9 Item 10C: Affiliations .................................................................................................. 9 Item 10D: Other Advisers ......................................................................................... 11 TOC 1 Giverny Capital Advisors LLC  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................................................................................... 11 Item 11A: Code of Ethics ......................................................................................... 11 Item 11B, 11C, 11D: Participation or Interest in Client Transactions ....................... 11 Item 12: Brokerage Practices ..................................................................................... 13 Item 12A: Selecting Brokerage Firms ...................................................................... 13 Item 12B: Order Aggregation ................................................................................... 15 Item 13: Review of Accounts ...................................................................................... 16 Item 13A: Periodic Reviews ..................................................................................... 16 Item 13B: Review Triggers ....................................................................................... 16 Item 13C: Regular Reports ...................................................................................... 16 Item 14: Client Referrals and Other Compensation .................................................. 16 Item 14A: Other Compensation................................................................................ 16 Item 14B: Referrals .................................................................................................. 16 Item 15: Custody ......................................................................................................... 17 Item 16: Investment Discretion .................................................................................. 18 Item 17: Voting Client Securities................................................................................ 19 Item 17A: Proxy Votes ............................................................................................. 19 Item 18: Financial Information ................................................................................... 19 Items 18A, 18B, 18C: Financial Information ............................................................. 19 Additional Disclosure: Business Continuity Plan .................................................... 19 Additional Disclosure: Information Security Program ............................................. 20 Brochure Supplement (Part 2B of Form ADV) .......................................................... 21 Patrick J. Leger (CRD# 5072630) ............................................................................ 21 Francois Rochon (CRD# 4763502) .......................................................................... 23 TOC 2 Giverny Capital Advisors LLC  Item 4: Advisory Business Item 4A: Firm Description Giverny Capital Advisors LLC, (“Giverny Capital Advisors”, “GCA”, “Firm” or “We”) was founded in 2009. Giverny Capital Advisors provides investment management services to individuals, trusts, and other institutional entities. The Firm’s investment management services are limited to the discretionary management of investment portfolios (mostly consisting of equity securities) in accordance with GCA’s long-term investment management strategy. We do not provide financial planning, insurance planning, estate planning, or any other related or unrelated consulting services. Giverny Capital Advisors is strictly a fee-only investment management firm providing independent investment management services. The firm does not receive commissions for purchasing or selling annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The Firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted and no finder’s fees are accepted. Giverny Capital Advisors does not act as a custodian of client assets and the client always maintains asset control. GCA’s third party custodian is Charles Schwab & Co., though a client may also use a custodian of their own choice if mutually-agreed upon. Giverny Capital Advisors places trades on behalf of clients under a limited power of attorney. The principal owners of the Firm are Patrick Leger (50%) and Giverny Capital, Management. (50%). Giverny Capital Management is entirely owned by Musee Giverny Capital, Inc. which is controlled by Francois Rochon. Item 4B: Types of Advisory Services Giverny Capital Advisors provides investment management services, on a continuing basis, with respect to the investment and reinvestment of all cash, securities, and other property in a client’s account. A client’s account will normally contain a relatively small number of securities positions (typically between 20 and 30 equity securities) and may not constitute a fully diversified or balanced portfolio that is suitable for investment of all of a client’s assets. Giverny Capital Advisors manages a client account without the obligation to consider other investment assets or accounts that the client may have or maintain away from the Firm. A client’s account will generally not contain fixed income investments but may do so based on individual client needs. The Firm offers and provides advice on the following types of investments and the Firm’s advice is limited to these types of securities:  Domestic equities International equities   Fixed income securities - 1 - Giverny Capital Advisors LLC   Exchange Traded Funds (ETFs)  Mutual Funds  Money Market securities or Cash funds Item 4C: Tailored Relationships We have considerable flexibility in accommodating any unique client needs and constraints through our third party custodians that hold the assets of our clients in individualized accounts. This customization may include, but is not limited to, the types of asset classes selected, the securities selected, the size of the allocation to a particular security, etc. Clients may also impose restrictions on investing in certain securities or types of securities. Item 4D: Wrap Fee Programs The Firm does not engage in any Wrap Fee Programs. Item 4E: Client Assets As of 12/31/25, Giverny Capital Advisors manages approximately $420,913,533 in assets for approximately 190 clients (293 accounts). Approximately $420,913,533 is managed on a discretionary basis (representing 293 accounts), and no assets are managed on a non- discretionary basis (representing 0 accounts). Investment Advisory Agreement The scope of work and fee for a client is agreed upon in an Investment Advisory Agreement that is signed by the client prior to the start of the management of any client assets. This agreement provides detailed information concerning what services are provided, the scope and limitations of these services, how fees are paid, disclaimers around the potential risks involved with investing, liability, confidentiality, etc. The annual Investment Advisory Agreement stipulates the fees related to GCA’s investment management services. The fee is based on a percentage of a client’s assets under management: .25% of assets per quarter (approximately 1% per annum) The management fee is negotiable under certain circumstances. Current client relationships may exist where the management fees are higher or lower than the fee listed above. Although the Investment Advisory Agreement is an ongoing agreement, the length of service to the client is at the client’s discretion. A client may terminate the investment advisory relationship by written notice at any time without penalty. At termination, management fees will be billed on a pro rata basis for the portion of the quarter during which client assets were under GCA’s discretion. - 2 - Giverny Capital Advisors LLC  Item 5: Fees and Compensation Item 5A: Description Giverny Capital Advisors bases its fees on a percentage of assets under management. Giverny Capital Advisors may charge a lesser or greater investment advisory fee based upon mutual agreement with the client and for certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). Lower fees for comparable services may be available from other sources. Item 5B: Fee Billing Clients engage Giverny Capital Advisors to provide investment management services on a fee-only basis. The Firm charges an annual investment management fee based upon a percentage of the market value of the assets managed by Giverny Capital Advisors. The annual investment management fee charged is approximately 1.00% of the market value of a client’s assets under management, inclusive of cash and accrued income. Lower fees for comparable services may be available from other sources. GCA’s annual investment management fee is paid in arrears on a calendar quarterly basis (i.e. January 1, April 1, July 1, and October 1) and calculated based on .25% (approximately 1% per year) of the market value of a client’s assets under management on the last trading day of the prior calendar quarter. Unless otherwise directed by the client, GCA’s management fee is debited directly by the custodian from the client’s account on a quarterly basis. If the investment management relationship begins subsequent to the beginning of a calendar quarter, then the initial fee is prorated over the remaining days in the initial calendar quarter and debited on the first day of the following quarter. In the event that the client terminates the engagement prior to the end of a calendar quarter, the investment management fee is debited from the client’s account on a prorated basis using the number of days in the calendar quarter that the client’s account was under management and the market value of the account on the day the engagement was terminated. GCA’s fees are not adjusted to reflect account deposits or withdrawals during a quarter, except if the deposit or withdrawal equals or exceeds 10% of the market value of the account (measured before the deposit or withdrawal). In the event of such a significant deposit or withdrawal, Giverny Capital Advisors calculates its fees by separating into separate periods the portion of the quarter occurring before the event and the portion of the quarter following it, and then calculating fees for each period pro rata based on the number of days in the given period and the market value of the account at the end of the - 3 - Giverny Capital Advisors LLC  period. The fees for each of the periods are then totaled to arrive at the quarterly fee. If a client has more than one account with Giverny Capital Advisors on which investment advisory fees are charged, then the fees computed will be based on the combined market value of those accounts, and the management fee can be charged to any of the client’s underlying accounts as deemed most appropriate by the Firm. In the situation where multiple accounts exist under the same household, then all accounts will be treated on a combined basis for the purpose of calculating fees, account size, and the previously mentioned 10% deposit and 10% withdrawal thresholds. Giverny Capital Advisors reserves the right to negotiate the management fee under certain circumstances. Giverny Capital Advisors does not impose a per client minimum for investment management services but does have the discretion to do so if the initial account value is deemed too small to cover expenses related to the management of the account. The Firm considers accounts of less than $250,000 as small in proportion to their associated expenses. Giverny Capital Advisors is authorized to receive its management fee directly from a client’s custodian. The custodian does not determine whether the fee has been properly calculated. Giverny Capital Advisors reserves the right to terminate any client relationship for any reason. Such termination is done in writing by the Firm and the management fee would be prorated according to the number of days that a client’s assets were under management by the Firm. Fees are withdrawn directly from client accounts held at our custodian. The custodian is sent an invoice to process the debiting of fees from client accounts, unless an alternate arrangement has been made by the client. Clients are sent a copy of the management fee invoice along with their quarterly statements from Giverny Capital Advisors. The availability of this invoice to the client occurs in a timely manner but isn’t exactly contemporaneous with the custodian receiving an invoice for the purpose of processing a deduction of management fees. Our custodian provides a list of all transactions on the monthly statements it sends to our clients, including all management fees paid on an account. Our clients provide written authorization to Giverny Capital Advisors and to our custodian to directly deduct management fees. Item 5C: Other Fees We buy and sell client securities primarily through Charles Schwab & Co., or other custodians and executing brokers, depending on each client. There are commission charges assessed to these transactions which are debited directly from the client’s account by the custodian. Client may choose their own custodian and broker if they prefer. Please refer to Item 12 for additional information on brokerage. - 4 - Giverny Capital Advisors LLC  Charles Schwab & Co. does not charge any fees for maintaining custody of our client assets. Although Giverny Capital Advisors typically selects individual equity securities on behalf of clients, and therefore avoids additional management fees, a portion of a client’s account may be invested in money market or other types of mutual funds (“Funds”). These Funds charge investment management fees. The advisory fees paid by a client to the Firm are distinct from, and in addition to, the fees and expenses paid or allocated to a client as a shareholder of a Fund. A complete explanation of fees and expenses charged by the Funds is contained in the prospectus delivered by each Fund. In addition to commissions, there may be other fees assessed by the client’s custodian which are also debited directly from the client’s account by the custodian. Those commissions, fees and other charges are determined by the client’s contract with the custodian and disclosed in more detail by the custodian in its account opening and other documentation. Clients may choose their own custodian and broker if they prefer. Please refer to Item 12 for additional information on brokerage. Item 5D: Prepayment No clients pay fees in advance to the Firm. Item 5E: Compensation for Sale of Securities No person at our firm accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Our compensation is based on a percentage of the assets we manage. 1. We do not see any conflict of interest from our compensation method. We receive more compensation when the value of our accounts increases and less when they decrease. We invest directly in individual stocks when we construct client portfolios and we do not invest in mutual funds or other funds that charge fees to clients and compensate us in any way. The only additional fees that are assessed to client accounts are for trading commissions and are paid directly to our custodian, Charles Schwab & Co. Under no circumstance do we receive compensation as a result of trading commissions. As such, we do not believe any conflicts of interest exist as a result of our compensation arrangement and we do not believe that our judgment is affected in any way that may compromise the integrity of our decision-making and in the types of investments we recommend for our clients. 2. Our clients can choose their own custodian and their own broker if they wish to not use Charles Schwab & Co. This is explicitly stated in our Investment Advisory Agreement and is to be mutually-agreed upon. - 5 - Giverny Capital Advisors LLC  3. We do not receive commissions and other compensation for the sale of investment products. 4. Advisory fees (or management fees) are the only fees that our Firm assesses on a client account. Item 6: Performance-Based Fees & Side-by-Side Management Our management fee structure does not change based on a share of the capital gains or capital appreciation of managed securities. No fees are considered performance-based fees. Giverny Capital Advisors does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for an advisor to recommend an investment that may carry a higher degree of risk to the client. Certain client accounts may have higher asset-based fees than other accounts. When the Firm and its investment personnel manage more than one client account a potential exists for one client account to be favored over another client account. The Firm and its investment personnel have a greater incentive to favor client accounts that pay the Firm (and indirectly the portfolio manager) higher fees. The Firm manages multiple client accounts. Accordingly, the Firm has adopted and implemented policies and procedures intended to address conflicts of interest relating to the management of multiple accounts and the allocation of investment opportunities.” Item 7: Types of Clients Giverny Capital Advisors generally provides investment management services to individuals, trusts, and other institutional entities. Client relationships vary in scope and length of service. Giverny Capital Advisors does not impose a strict per client minimum for investment management services but does have the discretion to do so if the initial account value is deemed too small to cover expenses related to the management of the account. The Firm considers accounts of less than $250,000 as small in proportion to their associated expenses. - 6 - Giverny Capital Advisors LLC  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Item 8A: Methods of Analysis Our objective is to achieve superior risk-adjusted investment returns for our clients over the long term. Our primary method of analyzing securities suitable for our clients is fundamental research and our investment approach is based on Value Investing. Fundamental research entails analyzing information that is pertinent to evaluating and estimating the intrinsic value of a company. This can include, among other things, a company’s annual reports, regulatory filings, analyst reports, information gathered during meetings with management, financial newspapers and company press releases. Item 8B: Investment Strategies We developed an investment process founded on the core principles of Value Investing: buying shares in companies with durable competitive advantages, when the intrinsic value of these businesses is meaningfully higher than their current share prices. Each suitable investment is then placed in a Master Portfolio, usually consisting of between 20-30 equity securities. Each security in the portfolio is allocated a certain weight in the portfolio. Each client account is then based on the Master Portfolio to determine the securities included in the client portfolio and their approximate weight within that portfolio. Each client’s account is individually managed and may experience performance dispersion from the Master Portfolio depending on a number of factors, including but not limited to, the timing of the opening of a client account, specific client needs, differences in the weight of a particular security that are deemed reasonable by the Firm, etc. Our investment strategy is long-term in nature which has the added benefit of keeping portfolio turnover low and minimizing capital gain and transaction costs relative to many more active strategies. Item 8C: Risk of Loss All forms of investing have certain risks that are borne by the client. While our investment approach keeps the risk of loss in mind, clients still face the following risks, among others:  Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events.  Value Investing Risk: A value stock may decrease in price or may not increase in price to the extent anticipated by the Firm if it remains undervalued by the market or the factors that the portfolio manager - 7 - Giverny Capital Advisors LLC  believes will cause the stock’s price to increase do not occur. Value investing may be out of favor with investors from time to time, and value stocks may underperform other securities (such as growth stocks) or the stock market in general.  Non-U.S. Securities: Foreign securities, foreign currencies, and securities issued by U.S. entities with substantial foreign operations can involve additional risks relating to political, economic, or regulatory conditions in foreign countries. These risks include fluctuations in foreign currencies, withholding or other taxes, trading, settlement, custodial, and other operational risks, and the less stringent investor protection and disclosure standards of some foreign markets. All of these factors can make foreign investments, especially those in emerging markets, potentially more volatile and less liquid than U.S. investments. In addition, foreign markets can perform differently from the U.S. market.  Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.  Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk.  Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.  Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the - 8 - Giverny Capital Advisors LLC  terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value.  Board Service: If a related person of the Firm serves on the board of directors of a company, the Firm may, from time to time, be limited in its ability to buy or sell securities that are held or under consideration by the company. Risk Acknowledgment: Giverny Capital Advisors does not guarantee the future performance of any client account or any specific level of performance, the success of any investment that the Firm may purchase for the client, or the success of the Firm’s overall management of the client’s account or accounts. The client understands that the investment decisions made for his/her account by the Firm are subject to various market, currency, economic, political and business risks, and that investment decisions will not always be profitable. Item 9: Disciplinary Information Legal and Disciplinary The Firm has no legal or disciplinary events to disclose. The Firm and its employees have not been involved in any legal or disciplinary events related to past or current investment clients, prospects or any other person or organization. Item 10: Other Financial Industry Activities and Affiliations Item 10A: Registrations Giverny Capital Advisors is not registered as a broker-dealer or as a representative of a broker-dealer. Giverny Capital Advisors is registered with the Securities and Exchange Commission (SEC). Item 10B: Other Registrations The Firm and its employees are not registered and does not have pending registration as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Item 10C: Affiliations 1. Broker-dealer: no affiliation 2. Investment company: no affiliation - 9 - Giverny Capital Advisors LLC  3. Other investment adviser: Giverny Capital Advisors is 50% owned by Giverny Capital Management Inc. which is owned by Musee Giverny Capital Inc. Musee Giverny Capital Inc. is controlled by Francois Rochon, a registered individual and owner of Giverny Capital, Inc. Giverny Capital Asset Management LLC is a registered advisory firm based in New York, NY. Giverny Capital Asset Management LLC is 50% owned by Giverny Capital Management Inc., which is owned by Musee Giverny Capital Inc. Musee Giverny Capital Inc. is controlled by Francois Rochon, a registered individual and owner of Giverny Capital, Inc. Giverny Capital Advisors LLC and Giverny Capital Asset Management LLC are under common control. The Firm collaborates with Giverny Capital, Inc., an SEC-registered advisor based in Montreal, Canada, on portfolio modeling and investment analysis, including in using a portfolio model developed by Giverny Capital, Inc. Notwithstanding such collaboration, neither the Firm nor its affiliates, Giverny Capital, Inc. and Giverny Capital Asset Management LLC, have discretion over or access to the other affiliates’ client accounts. In addition, the Firm is responsible for the implementation of such portfolio model for its clients and may deviate from such portfolio model. As a result, there may be material differences, including in timing and execution price, between the performance of the Firm’s client accounts and that of Giverny Capital, Inc.’s client accounts even when their respective holdings are similar or the same. Giverny Capital, Inc. collaborates in a similar fashion with Giverny Capital Asset Management LLC, an SEC-registered advisor based in New York, which is under common control with the Firm. The fact that, in the management of its clients’ accounts, the Firm uses a model portfolio developed by Giverny Capital, Inc. and used by Giverny Capital, Inc. and Giverny Capital Asset Management LLC could present potential conflicts of interest since the Firm, Giverny Capital, Inc. and Giverny Capital Asset Management LLC may be purchasing or selling the same securities for their respective clients’ portfolios at or around the same time. To ensure that one firm (and its clients) are not advantaged to the detriment of the others when executing a trade for their clients, the Firm, Giverny Capital, Inc. and Giverny Capital Asset Management LLC have implemented policies, procedures and controls that span across the three entities. Instructions regarding modifications to the Model portfolio, which may or may not be applied by the Firm to its client’s portfolios, are communicated at once to all entities. Because clients of Giverny Capital, Inc. use a different custodian and broker than clients of the Firm, individual and "batch" trades will not be executed at the same time or price for clients of - 10 - Giverny Capital Advisors LLC  the Firm and clients of Giverny Capital, Inc. (and Giverny Capital Asset Management LLC). These differences may be material. In the event that one firm receives material non-public information regarding a company, all three affiliated entities will be prohibited from trading in the respective company’s securities until the company is removed from the Restricted List of the three firms. For more information, see the Participation or Interest in Client Transactions and Personal Trading section in Item 11. 4. Futures commission merchant: no affiliation 5. Banking or thrift institution: no affiliation 6. Accountant or accounting firm: Giverny Capital Advisors utilizes the services of an accounting firm solely for tax preparation but there is no connection to client or marketing activities. 7. Lawyer or law firm: no affiliation 8. Insurance company or agency: no affiliation 9. Pension consultant: no affiliation 10. Real estate broker or dealer: no affiliation 11. Sponsor or syndicator of limited partnerships: no affiliation Item 10D: Other Advisers The Firm neither recommends or selects other investment advisers for its clients nor receives compensation directly or indirectly from those advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 11A: Code of Ethics The employees of Giverny Capital Advisors have committed to a Code of Ethics that is available for review by clients and prospective clients upon request. The Code of Ethics is an integral part of the Firm’s Compliance Manual. Item 11B, 11C, 11D: Participation or Interest in Client Transactions GCA and its employees may buy or sell securities that are also held by clients. GCA’s employees may not trade their own securities in personal accounts ahead of clients. However, the Firm or a related person/affiliated firm from time to time buys or sells securities for their respective clients’ accounts at or about the same time. This situation could create conflicts of interest since there could be a potential economic benefit for the Firm or - 11 - Giverny Capital Advisors LLC  employees or related persons to the detriment of the client under certain circumstances. In order to minimize the conflicts stemming from these situations, the Firm has specific provisions in its Compliance Manual with which all employees must comply. Moreover, Giverny Capital Advisors, Giverny Capital, Inc. and Giverny Capital Asset Management LLC have implemented policies, procedures and controls that span across the three entities. 1. If the Firm is purchasing or considering for purchase any security on behalf of a Firm’s client, Covered Persons’ personal accounts will transact in securities alongside client accounts, receive the average price that clients pay for securities transactions, and pay their share of transaction costs. In the event that an aggregated order including both employee and client accounts is only partially filled, the participating accounts will receive a pro rata allocation. In certain instances (e.g., new accounts, terminating accounts, add-on capital, partial withdrawals), the Firm may purchase or sell securities for employee accounts when other client accounts are not purchasing or selling the same security. With limited exceptions, employee accounts will not receive a more advantageous price than client accounts for a particular security purchased or sold on the same trading day. 2. Further, Covered Persons should not purchase or sell individual securities held in the Firm’s investment strategy unless it is through an account managed by the Firm, or in limited circumstances, the transaction is pre-cleared by the Chief Compliance Officer. Certain accounts of Covered Persons are treated as client accounts for purposes of the Firm’s procedures. 3. Since the Firm and its affiliated firms generally have the same investment strategy, the three advisors will occasionally purchase the same securities on behalf of their clients. In such cases, the three advisors will generally each place their orders with brokers at approximately the same time since it is not possible to use combined block transactions on behalf of these firms. Although the three firms collaborate in the management of their clients’ portfolio and make every effort to ensure that the managed accounts of one entity are not favored at the expense of the managed accounts of the other entities, the time and execution price of trades on behalf of the Firm and its affiliated firms may be materially different. Exceptions: 1. This policy has been established recognizing that some securities being considered for purchase and sale on behalf of the Firm’s clients - 12 - Giverny Capital Advisors LLC  trade in sufficiently broad markets to permit transactions to be completed without any appreciable impact on the markets of the securities. Under certain circumstances exceptions may be made to the policies stated above. Records of these trades, including the reasons for the exceptions, will be maintained by the Firm. 2. Open-end mutual funds and/or the investment subdivisions which may comprise a variable insurance product are purchased or redeemed at a fixed net asset value price per share specific to the date of purchase or redemption. As such, transactions in mutual funds and/or variable insurance products by Covered Persons are not likely to have an impact on the prices of the fund shares in which clients invest, and are therefore not prohibited by the Firm. 3. Some differences may exist between the Firm and its affiliated firm due to securities being purchased on different exchanges and/or at different times and other possible factors. Ad-hoc rebalancing of client portfolios, either based on a client request (for example, due to a deposit or withdrawal of fund) or for any reason deemed appropriate by the Firm, are not coordinated with its affiliated firms or necessarily combined with other transactions. Similarly, the Firm will not effect cross-transactions between client accounts. In accordance with Section 204A of the Investment Advisers Act of 1940, the Firm also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by the Firm or any person associated with the Firm. There are reporting requirements, detailed in the Firm’s Compliance Manual, regarding these policies. (For more information see section Other Financial Industry Activities and Affiliations under sub-section Affiliations.) The Chief Compliance Officer of Giverny Capital Advisors is Patrick Leger. He reviews all employee trades each quarter. The personal trading reviews ensures that the personal trading of employees does not affect the markets, and that clients of the Firm receive equal or preferential treatment. Item 12: Brokerage Practices Item 12A: Selecting Brokerage Firms To the extent that the client requests that the Firm recommend a broker- dealer/custodian for execution and/or custodial services, the Firm generally recommends that investment management accounts be maintained at Charles Schwab & Co. Prior to engaging the Firm to provide investment management services, the client will be required to enter into an Investment Advisory Agreement with the Firm setting forth the terms and conditions - 13 - Giverny Capital Advisors LLC  under which the Firm shall manage the client’s assets, and a separate custodial/clearing agreement with each designated broker-dealer/custodian. The Investment Advisory Agreement between the Firm and the client will continue in effect until terminated by either party by written notice in accordance with the terms of the Investment Advisory Agreement. Giverny Capital Advisors provides investment management services on a discretionary basis. Unless mitigating circumstances dictate otherwise, account positions are generally maintained over a long-term basis. Broker- dealers/custodians charge commissions and/or transaction fees for effecting certain securities transactions. In addition to the Firm’s investment management fee, brokerage commissions and/or transaction fees, the client will also incur, relative to all money market mutual funds purchased by the Firm to hold account cash balances, charges imposed at the mutual fund level (e.g. fund management fees and other fund expenses). Factors which the Firm considers in recommending a particular broker- dealer/custodian to clients (including Charles Schwab & Co.) include financial strength, reputation, execution, pricing, research, and service. In return for effecting securities transactions through a designated broker- dealer/custodian, The Firm may receive certain investment research products and/or services which assist the Firm in its investment decision-making process for the client pursuant to Section 28(e) of the Securities Exchange Act of 1934. Although the commissions paid by Firm’s clients shall comply with the Firm’s duty to obtain best execution, a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where the Firm determines, in good faith, that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although the Firm will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client account transactions. The brokerage commission paid by a specific client that may be used to pay for research is exclusive of, and in addition to, the Firm’s investment management fee. A client may direct the Firm to use a particular broker-dealer (subject to the Firm’s right to decline and/or terminate the engagement) to execute some or all transactions for the client’s account. In such event, the client will negotiate terms and arrangements for the account with that broker-dealer, and the Firm will not seek better execution services or prices from other broker-dealers or be able to “batch” the client’s transactions for execution through other broker-dealers with orders for other accounts managed by the Firm. As a result, client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions - 14 - Giverny Capital Advisors LLC  for the account than would otherwise be the case. In the event that transactions for client accounts are effected through a broker-dealer that refers investment management clients to the Firm, the potential for conflict of interest may arise. The Firm does not engage in soft dollar transactions or benefit from soft dollars. The services the Firm receives from its custodians are related to the management of client accounts. For example, the custodial interface we use allows us to manage all our client accounts at one through a common IT interface. Our custodians also have a customer service organization that specifically works with our Firm to resolve client issues. Since our relationship with our custodians facilitate the management of our client accounts and is a benefit to us, there is a conflict of interest that arises from those benefits we receive which could affect our ability to select another broker dealer which could better serve our client needs. Item 12B: Order Aggregation Transactions for each client account can be effected independently but can also be purchased or sold for several clients at approximately the same time. The Firm may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among Firm’s clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which the Firm’s principal(s) and/or associated person(s) may invest, the Firm shall generally do so in accordance with the parameters set forth in SEC No-Action Letter, SMC Capital, Inc. The Firm shall not receive any additional compensation or remuneration as a result of the aggregation. Since the Firm conducts portfolio management decisions in collaboration with Giverny Capital, Inc., an SEC-registered advisor based in Montreal, Canada, which has a different custodian and broker than that of the Firm, individual and “batch” trades will not be executed at the same time or price for clients of the Firm and clients of Giverny Capital, Inc. These differences may be material. Further, given that the Firm may have multiple custodial relationships with Charles Schwab & Co. and other custodians that are maintained due to Client preference, the Firm will attempt to place trades at approximately similar times but there is no way to achieve the same trade executions given distinct organizations. When a Client-selected custodian is maintained at the request of a Client, trades at our recommended custodian, Charles Schwab & Co., will be completed first. The differences that arise from a Client-selected custodian versus our primary custodian may be material. - 15 - Giverny Capital Advisors LLC  Item 13: Review of Accounts Item 13A: Periodic Reviews A review of each account is conducted by the Firm on no less than a quarterly basis. Patrick Leger (Managing Partner and Chief Compliance Officer) reviews client accounts and reallocates and/or rebalances investment securities to meet client investment objectives. Item 13B: Review Triggers Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client’s own situation. Clients are advised that they are responsible to advise Giverny Capital Advisors of any changes in their personal objectives and/or financial situation, and all clients are encouraged to contact the Firm to review their account performance on a regular basis. To the extent that Giverny Capital Advisors relies on information provided by client consultants (accountants, attorneys, etc.), Giverny Capital Advisors assumes that such information is accurate and reflective of the client’s financial situation. Item 13C: Regular Reports Each client receives quarterly reports from the Firm which include an appraisal of the account or accounts, a performance history report that includes the performance of the account relative to our benchmark (the S&P 500), and a statement of management fees assessed to the account. Realized gains and losses information is provided at the end of each fiscal year for a client’s tax preparation. The custodian sends monthly statements to each client. Item 14: Client Referrals and Other Compensation Item 14A: Other Compensation GCA receives benefits from certain custodians, such as the interface that allows GCA to manage all of its client accounts and a customer service organization that works with GCA to resolve client issues. There is a conflict of interest that arises from those benefits that could affect GCA’s objectivity in recommending custodians to clients; for example, these benefits create an incentive for GCA to recommend certain custodians rather than others. GCA addresses this conflict of interest by disclosing it to clients. GCA may receive certain research or other products or services from broker- dealers through “soft-dollar” arrangements. These “soft-dollar” arrangements create an incentive for GCA to select or recommend broker-dealers based on GCA’s interest in receiving the research or other products or services and may - 16 - Giverny Capital Advisors LLC  result in the selection of a broker-dealer on the basis of considerations that are not limited to the lowest commission rates and may result in higher transaction costs than would otherwise be obtainable by GCA on behalf of its clients. Please see Item 12 for further information on GCA’s “soft-dollar” practices, including GCA’s procedures for addressing conflicts of interest that arise from such practices. 14B: Referrals Giverny Capital, Inc. does not directly solicit clients on behalf of Giverny Capital Advisors and does not directly provide any services to clients or prospective clients of Giverny Capital Advisors at this time. Some individuals who are considered Investment Adviser Representatives by FINRA who work for Giverny Capital, Inc. are also registered as Investment Adviser Representatives with Giverny Capital Advisors. The Firm, from time to time, compensates either directly or indirectly, third parties for client referrals. Any such referral arrangements will comply with the relevant portions of the "cash solicitation" rule (Rule 206(4)-3). In particular, third party referral arrangements will be pursuant to an agreement between Giverny Capital Advisors and the solicitor, and all required disclosures will be made by the party providing the referral. Item 15: Custody In addition to the quarterly statement sent by the Firm, each client with assets custodied Charles Schwab & Co. will receive a monthly statement from either of these custodians that includes an appraisal of the account or accounts, as well as a list of all transactions on the account or accounts. Tax reporting information is also sent by custodian at the end of the fiscal year. Client should compare the statements provided by their custodian with those from Giverny Capital Advisors to ensure accuracy. The Firm provides a performance history report to each client on a quarterly basis. This report included the performance of the account or accounts relative to our benchmark, the S&P 500. The Firm provides an appraisal of a client’s account or accounts on a quarterly basis. Giverny Capital Advisors, when authorized in writing by its clients, deducts advisory fees directly from their accounts held at the custodian and therefore has limited custody of these clients’ assets. In such cases, the client’s custodian will send the client periodic account statements indicating the amounts of any funds or securities in the account as of the end of the statement period and any transactions in the account during the statement period. Clients should receive at least quarterly statements from the custodian that holds and maintains the client’s investment assets. Giverny Capital Advisors urges clients to carefully review such statements and compare such official custodial records to the account statements that Giverny Capital Advisors provides. - 17 - Giverny Capital Advisors LLC  The Firm should not be considered to have custody of client assets since all of the following safeguards are met: a) The Firm has custody of the funds and securities solely as a consequence of its authority to make withdrawals from client accounts to pay its advisory fee. b) The Firm has written authorization from the client to deduct advisory fees from the account held with the qualified custodian. c) Each time a fee is directly deducted from a client account, the Firm concurrently: i. Sends our custodian an invoice or statement of the amount of the fee to be deducted from the client’s account; and ii. Sends the client an invoice or statement itemizing the fee. This invoice includes itemization of the formula used to calculate the fee, the value of the assets under management on which the fee is based, and the time period covered by the fee. Since this invoice is sent by US Mail and is being delivered to different parts of the country at different time, it should be noted that all clients also have immediate access to the management fee amount that was assessed on their account through our custodian’s online interface. d) We provide written notice to all state and federal regulatory bodies that require us to inform them that we comply with the above mentioned requirements. Item 16: Investment Discretion The Firm has discretionary authority to manage securities accounts on behalf of its clients. The Firm has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. This is agreed upon between the Firm and the client in the Investment Advisory Agreement. The client approves the custodian to be used and the commission rates paid to the custodian. Giverny Capital Advisors does not receive any portion of the transaction fees or commissions paid by the client to the custodian. Discretionary trading authority facilitates placing trades in accounts on a client’s behalf so that we may promptly implement the investment management of the client’s assets under the Firm’s discretion. A limited power of attorney is a trading authorization for this purpose. A client signs a limited power of attorney so that we may execute trades on the account. - 18 - Giverny Capital Advisors LLC  Item 17: Voting Client Securities Item 17A: Proxy Votes To the extent GCA has been delegated proxy voting authority on behalf of its clients, GCA seeks to comply with its proxy voting policy that is designed to ensure that in cases where GCA votes proxies with respect to client securities, such proxies are voted in the best interests of each client. A copy of GCA’s proxy voting policy is available upon request. A form from Charles Schwab & Co. regarding proxy voting is provided to each new client. By using this form, a client determines whether they wish to vote their own proxies. In summary, the Proxy Voting Policy details our approach to Proxy Voting. It includes a general philosophy towards proxy voting, as well as more detail regarding specific categories of issues that often are presented for shareholder vote. Our policy also describes how a log is kept at the Firm which provides information on how each issue was voted. Decisions on proxy voting are made with the goal of enhancing the value of GCA’s clients’ investments. In the case where a potential conflict of interest is identified between a client and a proxy-related action by the Firm, the client will be contacted to discuss such a conflict and determine an appropriate course of action regarding the proxies for that particular client. Client may obtain a copy of our proxy voting log at any moment by providing us with a written request. GCA uses an online platform from a third party services provider to record its votes. 18: Financial Information Items 18A, 18B, 18C: Financial Information A balance sheet is not required to be provided because Giverny Capital Advisors does not require prepayment of fees of more than $1200 per client, six months or more in advance. The Firm does not maintain custody of client funds or securities and does not require or solicit prepayment of more than $500 in fees per client, six months or more in advance and the Firm does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. The Firm has not been the subject of a bankruptcy petition. Additional Disclosure: Business Continuity Plan Giverny Capital Advisors has a Business Continuity Plan in place that provides detailed steps to mitigate and recover from the loss of office space, communications, services or key personnel. This Plan is included as part of the Firm’s Compliance Manual. The Business Continuity Plan covers natural disasters such as snow storms, hurricanes, tornados, and flooding. The plan covers man-made disasters such as loss of electrical power, loss of water pressure, fire, bomb threat, - 19 - Giverny Capital Advisors LLC  nuclear emergency, chemical event, biological event, Internet access outage, Internet outage, railway accident and aircraft accident. Electronic files are backed up daily and archived offsite. Alternate offices are identified to support ongoing operations in the event the main office is unavailable. It is our intention to contact all clients within five days of a disaster that dictates moving our office to an alternate location. Giverny Capital Advisors has a Business Continuation Agreement to support the Firm in the event of Patrick Leger’s, or any key personnel’s, serious disability or death. Additional Disclosure: Information Security Program Giverny Capital Advisors maintains an information security program to reduce the risk that your personal and confidential information may be breached. Giverny Capital Advisors has a long-standing policy of protecting the confidentiality and security of information we collect about our clients. We do not share nonpublic information about you ("Information") outside of the Firm without your consent except for the specific purposes described below, in accordance with all applicable laws. This Notice describes the Information we may gather and the circumstances under which we may share it. We limit the collection and use of Information to the minimum we require to deliver superior service to you. Such service includes maintaining your portfolio accounting, processing discretionary transactions and those requested by you or other persons authorized by you, and administering our business. We get most Information directly from you or your representative. This Information may relate to your finances, employment, avocations or other personal characteristics, as well as transactions and interactions with or through us or with others. Our employees and investment adviser representatives acting on our behalf are required to protect the confidentiality of Information and to comply with our established policies. They may access Information only when there is an appropriate reason to do so. We also maintain physical, electronic, and procedural safeguards to protect Information, which comply with all applicable laws. Employees are required to sign a Confidentiality Agreement. Employees who violate our Privacy Policy will be subject to disciplinary process. We may disclose any Information when we believe it necessary for the conduct of our business, or where disclosure is required by law. For example, Information may be disclosed for audit or research purposes, to attorneys or other professionals, or to law enforcement and regulatory agencies to help, among other things, prevent fraud or money laundering. In addition, we may disclose Information to third party service providers to enable them to provide - 20 - Giverny Capital Advisors LLC  business services for us, such as performing computer related or data maintenance or processing services for us, to facilitate the processing of transactions, or for credit review or reporting purposes. We will not make any disclosures of information to other companies who may want to sell their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company or telemarketer. Even if you are no longer a Giverny Capital Advisors client, our Privacy Policy will continue to apply to you. This Privacy Policy applies to services provided by Giverny Capital Advisors and its employees. Upon your written request, we will make available for your review any file we may maintain for your personal Information; provided, however, that any Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available. If you notify us that any Information is incorrect, we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in any future disclosure of the disputed Information. We reserve the right to change this Privacy Policy at any time. The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive. This notice complies with a recent Federal law and regulations regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you. Brochure Supplement (Part 2B of Form ADV) Patrick J. Leger (CRD# 5072630) Item 1: Cover Page Patrick J. Leger (CRD# 5072630) Managing Partner & Chief Compliance Officer Giverny Capital Advisors 182 Nassau Street, Suite 201 Princeton, NJ 08542 (609) 759-1250 Date of Brochure Supplement: 03/30/25 This brochure supplement provides information about Patrick Leger that supplements the applicable Giverny Capital Advisors ADV brochure. You should have received a copy of that brochure. Please contact Patrick Leger if you did not receive Giverny Capital Advisors’ brochure or if you have any questions about the contents of this supplement. - 21 - Giverny Capital Advisors LLC  Additional information about Patrick Leger is available on the SEC’s website at www.adviserinfo.sec.gov. Item 2: Educational Background and Business Experience Name: Patrick J. Leger Born: 1974 Educational Background: McGill University, 1995, BA Vanderbilt University, 2002, MBA Finance Professional Designation: Chartered Financial Analyst (CFA) Chartered Financial Analysts are licensed by the CFA Institute to use the CFA mark. CFA certification requirements:  Hold a bachelor’s degree from an accredited institution or have equivalent education or work experience.  Successful completion of all three exam levels of the CFA Program.  Have 48 months of acceptable professional work experience in the investment decision-making process.  Fulfill society requirements, which vary by society. Unless you are upgrading from affiliate membership, all societies require two sponsor statements as part of each application; these are submitted online by your sponsors.  Agree to adhere to and sign the Member’s Agreement, a Professional Conduct Statement, and any additional documentation requested by CFA Institute. Business Background: Giverny Capital Advisors LLC, Managing Partner / CCO 03/2009 – Present Steginsky Capital LLC, Analyst 2005 – 2009 PricewaterhouseCoopers LLP, Manager 2003 – 2005 Item 3: Disciplinary Information No material legal or disciplinary events to disclose - 22 - Giverny Capital Advisors LLC  Item 4: Other Business Activities Part owner and provides CFO services to a family food business, First Field Inc. Item 5: Additional Compensation No additional compensation to disclose Item 6: Supervision Patrick Leger is currently the only employee of the Firm working in a supervisory position. As such, he is not directly supervised by an individual at the Firm. Francois Rochon (CRD# 4763502) Item 1: Cover Page Francois Rochon (CRD# 4763502) Founder & President Giverny Capital, Inc. 759 Square-Victoria Street, Suite 105 Montreal, QC Canada H2Y 2J7 1-888-GIVERNY Date of Brochure Supplement: 03/30/25 This brochure supplement provides information about Francois Rochon that supplements the applicable Giverny Capital Advisors ADV brochure. You should have received a copy of that brochure. Please contact Patrick Leger if you did not receive Giverny Capital Advisors’ brochure or if you have any questions about the contents of this supplement. Additional information about Francois Rochon is available on the SEC’s website at www.adviserinfo.sec.gov. Item 2: Educational Background and Business Experience Name: Francois Rochon - 23 - Giverny Capital Advisors LLC  Born: 1968 Educational Background: Ecole Polytechnique de Montreal, 1990, MS Engineering Professional Designation: None Business Background: Giverny Capital, Inc., Founder & President 1998 – Present Item 3: Disciplinary Information No material legal or disciplinary events to disclose Item 4: Other Business Activities Sits on the board, the art acquisition committee and the investment committee of the Albright-Knox Art Gallery in Buffalo, as well as on the board of trustees and the art acquisition committee of the Hirshhorn Museum in Washington, D.C. In Canada, he sits on the boards of the Musée National des beaux-arts du Québec, Musée Giverny Capital and Fondation Giverny pour l’art Contemporain as well as on the art acquisition committee of the Musée des beaux-arts de Montréal. Giverny Capital Inc.: Francois Rochon is the president and majority beneficial owner of Giverny Capital, Inc., an SEC-registered advisor based in Montreal, Canada. Giverny Capital Asset Management LLC: Francois Rochon is the ultimate beneficial owner of Giverny Capital Management Inc. which is part owner of Giverny Capital Asset Management LLC, an SEC-registered advisor based in New York. Item 5: Additional Compensation No additional compensation to disclose Item 6: Supervision Francois Rochon is the ultimate beneficial owner of Giverny Capital Management Inc. which is part owner of Giverny Capital Advisors LLC. Patrick Leger is the supervisor of all individuals, including Mr. Rochon, associated with Giverny Capital Advisors LLC. - 24 - Giverny Capital Advisors LLC