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Strong ethics and integrity are foundational values of Diamond Hill and help guide our culture. We place our fiduciary duty to our clients at the top of our corporate objectives, and we invest the capital you entrust to us with the same care that we invest our own capital. The collective purpose of all our associates is to be trusted stewards of capital for outstanding client outcomes. In support of that goal, we believe it is important to be as transparent as possible regarding our business practices, governance and oversight.

Code of Ethics and Alignment of Interests

We believe that all employees owe a fiduciary duty, meaning a duty of loyalty, fairness and good faith, to our clients. Our Code of Ethics prohibits all associates from purchasing individual equity or fixed income securities as well as third-party mutual funds within the same Morningstar categories with which we compete, minimizing conflicts of interest. Each of our portfolio managers has a significant personal investment in the strategy they manage. By investing heavily alongside our clients, we ensure that portfolio managers will treat their strategies as though it were their own money – because it is.

Code of Ethics

Personal Holdings Disclosure

We voluntarily disclose the personal investments of our portfolio managers, research analysts and officers. Because of our investment team's shared investment philosophy and contribution to all strategies, we believe our collective investments across all strategies are the most meaningful indication of our alignment of interests with those of our clients. Collectively, Diamond Hill associates have over $160 million* invested in Diamond Hill Funds and all associates are owners in Diamond Hill Investment Group, Inc. ("DHIL").
*As of September 30, 2021

Personal Holdings Disclosure

CFA Institute's Asset Manager Code of Conduct

Diamond Hill Capital Management has adopted and complies with the CFA Institute's Asset Manager Code. The Code outlines the ethical and professional responsibilities of firms that manage assets on behalf of clients. Annually, we reaffirm our compliance with the Code across six broad categories including: loyalty to clients, investment process and actions, trading, risk management, compliance and support, performance reporting and valuation, and disclosures.

Political Contribution Disclosure

Diamond Hill has not and does not make political contributions. Our employees are prohibited from making political contributions without receiving prior approval from the Chief Compliance Officer to ensure that such contributions comply with relevant rules and regulations.

Portfolio Manager Authority to Close Strategies

The key consideration in estimating a strategy's capacity is to determine what asset size may hinder our ability to add value over a passive alternative. The investment team reevaluates each strategy's capacity on a regular basis. Portfolio managers have the sole authority to close their strategies before assets reach a size where they believe it will impact their ability to achieve the strategy's investment return goals. Portfolio managers have previously exercised this authority to close three strategies in order to protect the interests of existing clients.

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We define sustainability as ensuring the long-term viability of the firm by managing our business to help our clients meet their financial goals without impeding the ability of future generations to meet their economic, social, and environmental needs. We believe maintaining a long-term perspective while considering the implications of how our business decisions could affect relevant stakeholders will ensure we can continue to add value for shareholders over time. We also believe we should demonstrate a commitment to the same principles we expect of the companies in which we invest, which include a long-term perspective, sustainable competitive advantages, and stakeholder-focused management teams.

Diamond Hill's sustainability efforts at the firm level encompass four areas:

Corporate Governance

  • The Diamond Hill Investment Group, Inc. Board of Directors (the "Board") represents the interests of Company shareholders and has responsibility to other relevant stakeholders. The Board's purpose is to ensure the Company is fulfilling its fiduciary duty and it regularly interacts with management to ensure that the firm is being managed with a long-term perspective in mind. Six of seven members of the Diamond Hill Investment Group board of directors are independent.
  • The Diamond Hill Funds Board of Trustees represents the interests of Fund shareholders and provides oversight of the management of the Funds. All members of the Diamond Hill Funds Board of Trustees are independent.
  • All independent directors of Diamond Hill Investment Group, Inc. and trustees of the Diamond Hill Funds have deep industry experience, which we believe helps ensure strong oversight of our operations.
  • The objective of our Compliance Program is to protect the interests of our clients, while also preventing violation of federal securities laws. We also strive to eliminate or mitigate potential conflicts of interest. At Diamond Hill, all employees are responsible for compliance and we pride ourselves on maintaining a strong commitment to compliance throughout the firm.
  • Our Information Security Program is designed to protect the privacy and personal information of clients, shareholders, and employees, as well as secure the overall network and operating infrastructure to ensure that Diamond Hill can continue to operate seamlessly without material disruption.
  • Our Code of Ethics prohibits the purchase of any individual securities or competing firms' funds in segments of the market in which Diamond Hill has an investment strategy. As such, the majority of our employees' personal investments are in the same portfolios in which our clients invest. This policy significantly reduces potential conflicts related to personal security trading.

We believe our corporate governance practices contribute to the long-term viability of the firm by reducing firm-level risk and promoting a culture of compliance among associates.

Social Responsibility

  • Diamond Hill has a long history of supporting local charitable causes. The Diamond Hill Charitable Foundation currently supports several community organizations focused on a variety of issues, including poverty, education, and children's needs.
  • We match employee charitable contributions up to $2,000 per year to further support the organizations that mean the most to our employees.
  • We evaluate our impact in the community and optimize our contributions to those groups we believe will have the most tangible impact.
  • The firm maintains an Equal Opportunity Employment Policy, which is designed to prevent discrimination when making hiring decisions.

We believe that having a positive impact in our community and helping our associates support the causes that are most important to them will help us maintain and improve upon our position as a good corporate neighbor.

Diversity

  • We believe that cognitive diversity, which we define as having a variety of viewpoints, perspectives, and ways of processing information, is beneficial for organizational decision making, problem solving, and team building, and is one of the primary goals of our diversity and inclusion efforts.
  • We actively seek diversity at Diamond Hill by recruiting women and other underrepresented groups for positions throughout the firm. Our efforts have been largely focused on women, and we work with several women's organizations to not only identify candidates for potential positions at Diamond Hill, but also to generate interest in our industry. Women make up half the world's population but are underrepresented in the asset management industry and we believe increasing the amount of women in asset management will benefit all industry participants.
  • When making new job postings available, we believe it is important to publicly post open positions before they are filled, and we insist on a diverse candidate slate for every position before we fill it.
  • We also believe that having diversity in the groups responsible for the oversight of our operations is important. Three out of seven Diamond Hill Investment Group, Inc. Board members are women, and four of six Trustees for the Diamond Hill Funds are women.

We believe increasing diversity at Diamond Hill and considering diverse candidates for open positions at the firm will enable us to make better decisions and operate more effectively over the long term.

Employee Engagement

  • We want to encourage ownership in decisions affecting the future of the company. We make an active effort to include a wide range of employees in discussions concerning the strategic direction of the firm, and we seek to leverage the intellectual capital of our associates by incorporating employee ideas and suggestions into our overall plans where possible.
  • We regularly participate in employee engagement surveys to determine how effective senior leadership is at articulating and communicating their vision for the firm, with the goals of continuously improving our strategy and how we communicate with employees, and maintaining a culture of shared responsibility throughout the organization.
  • We also have several internal groups focused on improving employee engagement and satisfaction. The Wellness Team is designed to promote increased awareness of healthy behaviors and well-being, provide opportunities for associate interaction and camaraderie, and enhance employee morale. The Appreciation Task Force is focused on improving our efforts at valuing employee contributions by recognizing both individual and collective accomplishments at Diamond Hill.
  • We believe that in order to attract and retain high-quality associates, we must be transparent about our compensation practices. We are committed to providing our employees with fair and competitive compensation with a significant long-term equity component, which means every employee at Diamond Hill is an owner. We believe this helps associates think broadly about our business and maintain a long-term focus.

We believe attracting and retaining an engaged, high-quality workforce will enable us to continue to add value for clients and shareholders over the long term.

Our Commitment to Investment Stewardship

As stewards of client capital, we are committed to generating excellent investment outcomes for our long-term partners. Through our deep, fundamental research, we thoroughly evaluate all material risks and opportunities that could impact the value of an investment over the long term, including issues related to sustainability and ESG factors.

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Information Security Program (Cybersecurity)

ISO-27001 Certification LogoWe have an Information Security Program in place to protect the privacy and personal information of clients, shareholders and associates, as well as secure the overall network and operating infrastructure to ensure that Diamond Hill can continue to operate seamlessly without material disruption. The Program consists of technical policies, user policies, employee training and an ongoing risk assessment and review. The Program is ISO 27001 certified, meaning a third party reviewed and certified that we follow the standards issued by the International Organization of Standards related to information security.

Certification

Business Continuity

Diamond Hill has developed and maintains a Business Continuity Plan that is designed to protect client interests by providing a stable and reliable operating infrastructure. The plan allows Diamond Hill to continue the management of client portfolios in the event of various business disruptions, ranging from intraday system interruptions to longer-term outages.

Business Continuity Plan

Independent Mutual Fund Board

The Board of Trustees of Diamond Hill Funds represents the interests of fund shareholders and provides oversight of the management and operation of the Funds. Our Fund Governance Guidelines require that all board members be independent and not affiliated with Diamond Hill. In addition, Trustee compensation is paid solely in shares of Diamond Hill Funds and must remain invested in such funds for each Trustee's entire tenure on the board. Click here to view more information regarding fund governance, including disclosure of each Trustee's personal holdings in Diamond Hill Funds.

Independent Corporate Board

The Board of Directors of Diamond Hill Investment Group, Inc. represents the interests of its shareholders by fostering a successful business that fulfills its fiduciary duty to its clients and shareholders. The Board is responsible for regularly monitoring the effectiveness of management policies and decisions, including the execution of its strategies and the fulfillment of its fiduciary duty. Our Corporate Governance Guidelines require an independent board chair and that a majority of our board members be independent, meaning that over 50% of our board is comprised of directors that cannot be an officer or employee of Diamond Hill and must be free from any relationship that could interfere with the exercise of independent judgment in carrying out the responsibilities of a director.

Corporate Governance

Compliance Program

We have adopted a series of policies and procedures that are designed to protect client interests and to prevent, detect and correct any violations of federal securities laws. Our overall Compliance Program was designed using a risk-based approach and includes policies, associate training, forensic testing and an annual assessment.

ADV Disclosure Brochure

As an investment adviser registered with the Securities and Exchange Commission, we are required to prepare Form ADV Part 2A, also referred to as our Disclosure Brochure. This brochure is the primary disclosure document that investment advisers provide to their clients. It describes and discloses our various business practices and conflicts of interest.

ADV Part 2A Disclosure Brochure

Form CRS

CFA Institute Global Investment Performance Standards (GIPS®) Verification

Diamond Hill complies with the CFA Institute's Global Investment Performance Standards (GIPS®). Verification is performed by an independent, third-party verifier who conducts testing of the firm and provides assurance that Diamond Hill policies and procedures related to specific GIPS® standards have been designed in compliance with those requirements and have been implemented on a firm-wide basis. Annually, we reaffirm our compliance with GIPS® through the CFA Institute.

The opinions, statements or views expressed by Diamond Hill Capital Management, Inc. ("Diamond Hill") are subject to change and are not intended to be a forecast of future events, a guarantee of results or investment advice. All information is provided for informational purposes only and should not be considered a recommendation to invest in any particular security, strategy or investment product. Investing involves risk, including the loss of principal.

Comments and opinions posted by users are the responsibility of the person who posted them. Diamond Hill does not adopt, endorse, or guarantee the accuracy of content posted by others, and such content does not represent the views of Diamond Hill.

The use of social media interactions such as "like," "retweet" or "share" are not intended to constitute an endorsement or testimonial of the item interacted with.

Diamond Hill reserves the right to remove and moderate comments. We reserve the right to remove posts and content that is deemed inappropriate or offensive or constitutes a testimonial, advice, recommendation or advertisement for securities, products, or services or is promotional in nature. Diamond Hill also reserves the right to block followers whose social media account contains offensive or inappropriate content, serves as a promotional site, or violates any of the conditions above.

We believe increasing diversity at Diamond Hill and considering diverse candidates for open positions at the firm will enable us to make better decisions and operate more effectively over the long term.

Workforce Demographics Table

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