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.
Ethics, Alignment and Sustainability
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. All Diamond Hill associates have personal investments in Diamond Hill Investment Group, Inc. ("DHIL") and Diamond Hill Funds.
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.
We take a holistic view of sustainability and are transparent in communicating to clients and shareholders how we approach issues related to sustainability. In the administration of our business, we believe the long-term viability of the firm is dependent upon our ability to help our clients meet their financial goals without impeding the ability of future generations to meet their economic, social and environmental needs. In portfolio management, we believe being a good corporate steward and maintaining a long-term perspective is good for the long-term valuation of a company.
Information Security and Business Continuity
Information Security Program (Cybersecurity)
We 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.
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
Investment Governance and Stewardship
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.
The key objective of our Proxy Voting Policy is to maximize the value of the securities held in our clients' portfolios. We recognize that a company's management is entrusted with the day-to-day operations and longer-term strategic planning of the company, subject to the oversight of the company's board of directors. Ordinary business matters are primarily the responsibility of management and should be approved solely by the corporation's board of directors. However, we recognize that the company's shareholders have the final say over how management and directors are performing and how shareholders' rights and ownership interests are handled, especially when matters could have substantial economic implications. Therefore, in exercising our proxy voting responsibilities, we pay close attention to matters regarding management accountability, alignment of management and shareholder interests, and transparency.
Proxy Voting Policy
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.
Corporate and Fund Governance
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.
Business Practices, Policies, and Conflicts
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