Last Updated April 2024

At Brown Advisory, we believe that you deserve frank and open communication on all aspects of our relationship. In this spirit, we provide this annual summary of our policies relating to confidentiality, privacy of client information, identity theft program, mutual funds, conflicts of interest, trading commissions, proxy voting and Form ADV annual notices.

Confidentiality and Privacy Policy 
(Regulation S-P and S-AM Notice)

Brown Advisory takes the confidentiality of your personal information and the privacy of your account very seriously. Our commitment to safeguard your personal information goes beyond our legal obligation to process your transactions accurately and securely. Whether we serve you online, in person, on the telephone or by mail, the principles that guide the way in which we conduct business are built upon our core values of trust and integrity.

To protect your personal information from unauthorized access and use, we use security measures that are designed to comply with federal law. These measures include physical, electronic and procedural safeguards that are designed to protect your personal information, including various measures to protect such information while it is stored electronically. We train and consistently remind all employees to respect client privacy (including the identity of our clients) and to recognize the importance of the confidentiality of such information. Those who violate our privacy policy are subject to disciplinary action.

Federal law (Regulations S-P and S-AM) requires us to inform you that we have on record personal information about you and that we obtain such information from you directly (e.g., information you provide to us on account applications and other forms, such as your name, email and mailing address, Social Security number, driver’s license numbers (or comparable), occupation, risk tolerance, assets and income) and indirectly (e.g., information on our computer systems about your transactions with us, such as your account balance and account holdings).

In addition to the personal information described above, we collect certain information about your use of our online services, such as IP addresses and the information on our websites that you access. As explained in more detail in our Cookie Policy, we use cookies to collect and store this and other information about your visit to, or use of, our online services.

Like all investment firms, in order to better serve clients, Brown Advisory needs to share certain non- public personal information in the normal conduct of our business with other members of the Brown Advisory corporate group and with unaffiliated companies with whom we have service agreements. We share your personal information in order to process transactions, maintain your account(s) and offer our services to you. This sharing allows us to: (i) provide better and more complete investment and strategic advice; (ii) develop new services that meet additional needs you may have; and (iii) comply with legal and regulatory requirements applicable to us and others in providing services to you. When we share information with unaffiliated companies that are under contract to perform services on our behalf, such as vendors that provide services directly related to your account relationship with us, we seek to require these companies to keep your information confidential and not use such information for any unrelated purpose. We may also be required to share non-public personal information to respond to court orders, regulatory requests and legal investigations and in connection with regulatory requirements and inquiries.

We do not sell information about you to third parties, we do not jointly market with non-affiliated companies, and we do not otherwise disclose information about you to non-affiliates so they can market to you.

For U.S. Persons Only: If you are a new client, we can begin sharing your information internally for marketing purposes 30 days from the date you are provided with this notice. When you are no longer our client, we continue to share your information as described in this notice. You may limit our ability to share information internally with other members of the Brown Advisory corporate group for marketing purposes by calling 410-537-5380 or by emailing [email protected]. If you opt out, your selection will be treated as permanent unless you tell us otherwise.

Additional information for UK and EU/EEA residents is available at https://www.brownadvisory.com/us/additional-information-uk-and-eueea-residents.

Pursuant to Section 503 of the Gramm-Leach-Bliley Act, this notice may be reduced or eliminated in future years. However, our Confidentiality and Privacy Policy will remain in effect and is available for your review at any time at https://www.brownadvisory.com/us/disclosures or by contacting your Client Service team. We will provide notice to you in case the Policy changes or as otherwise required by law.

Annual Notice

• Notice to Brown Advisory Clients

Form ADV Part 3

• Brown Advisory Customer Relationship Summary

Form ADV Part 2A

• Brown Advisory LLC
• Brown Advisory Investment Solutions Group LLC
• Brown Advisory Limited
• Signature Financial Management, Inc.

Disclosures for Clients of Brown Advisory Limited

• Brown Advisory Limited Pillar 3 Disclosure & Remuneration Code Disclosures
• Shareholder Rights Engagement Policy
• Complaints Disclosure

What Makes Brown Advisory Different

We founded Brown Advisory with a simple vision: to build a client-first investment firm. Today, we are fortunate to provide investment solutions to individuals, families and institutions in all 50 U.S. states and in 44 countries and territories around the world. We are deeply committed to our clients, and focus exclusively on helping them plan and implement thoughtful investment strategies. This focus extends to the retirees, students, nonprofit beneficiaries and many others who may never meet us but nevertheless depend on us as trusted stewards of capital.

Our Mission

Brown Advisory is a private, independent investment and strategic advisory firm. Our mission is to make a material and positive difference for our clients by delivering a combination of first-class investment performance, strategic advice and the highest level of service.

A Private Firm with a Shared Ownership Structure

Brown Advisory has been a private, independent and colleague-owned firm since 1998. Every colleague is an equity owner, and together our colleagues own approximately 70% of the firm. The remaining 30% is owned by select outside investors who provide insight, perspective and stability. All of these owners are aligned in the desire to build a firm that puts clients above all else.

Transparency

We are a firm of 750+ people, fourteen offices, six primary client segments, nearly 40 groups and countless teams. Transparency is critical so that we can all operate from the same playbook. We share meeting minutes from all operating committee meetings with all colleagues, so we collectively understand decision-making as it filters through the organization. Additionally, our intranet platform, B|Advised, draws on modern sharing and collaboration tools to enable rapid information transfer as well as open, firmwide conversations on topics ranging from investments to diversity and inclusion.

Sustainable Investing

It’s a path to investment performance, a way to reflect your values, an opportunity to make an impact on the world. We aim to deliver sustainable and mission-aligned investment solutions to our clients built on first-rate performance, thoughtful advice and the highest level of service.

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Diversity, Equity and Inclusion

Brown Advisory should be an environment that mirrors the fabric of the communities in which we work and live—one that supports colleagues in their effort to contribute at the highest level and reach their potential. We know that this will be a continuous journey—success is a progression, not a point in time. We will always be asking ourselves, “What's next?”

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Community and Impact

Creating impact—real impact—for the communities in which we live and work has been an essential part of Brown Advisory’s DNA since our beginnings. As we strive to make a positive and material difference for all of our stakeholders, we are cognizant of our responsibilities to our communities—we believe we have an obligation to contribute to and enhance the lives of others through financial, intellectual and hands-on partnership.

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A "Morning Meeting" Mindset

Our Morning Meeting is a cultural cornerstone at Brown Advisory. Every morning, we gather the entire firm—each office gathers in person, and all offices connect via video conference—to discuss a topic or idea that is relevant to our investment thinking or to the culture of the firm. We ring the bell to start the meeting at 8:35 a.m. Eastern Time. The meeting represents many facets of our culture that we hold dear: thoughtful discussion, active listening, flat organization, collegial atmosphere and encouragement of new ideas.

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