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Policies & Disclosures

Operating with ethics and integrity is foundational to our client-centric approach. We place our fiduciary duty to our clients at the top of our corporate objectives and believe it is important to be as transparent as possible regarding our business policies and practices.

Ethics and alignment

Information security and business continuity

Business practices, policies and conflicts

Social media

Ethics and alignment

A culture of client alignment

Client alignment is core to who we are and critical to generating excellent, long-term investment outcomes and building enduring partnerships.

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Code of ethics

We believe our associates owe a fiduciary duty of loyalty, fairness and good faith to our clients. Our code of ethics is designed to ensure that client interests come first and 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 he/she manages. By investing heavily alongside our clients, our portfolio managers are aligned with clients.

Code of ethics

CFA Institute's Asset Manager Code of Conduct

Diamond Hill 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.

Thoughtful approach to proxy voting

Our key objective in proxy voting is maximizing the long-term value of our clients' investments. As a company, we 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.

Learn more about our proxy voting policy

Proxy Voting Summary

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 such contributions comply with relevant rules and regulations.

Information security and business continuity

Information security program (cybersecurity)

Our information security program protects the privacy and personal information of clients, shareholders and associates, as well as secures 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 for Standardization related to information security.


Business continuity

Diamond Hill's business continuity plan is designed to protect clients' 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 disclosure statement

Business practices, policies and conflicts

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.

Social media

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.

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