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Dave Butler
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Gerard O’Reilly
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Co-Chief Executive Officer
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Co-Chief Executive Officer and Chief Investment Officer
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Reporting Code and Standard of Conduct Violations
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6
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Certification Requirements
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6
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Sanctions
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6
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Who Is Subject to the Code?
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8
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Covered Accounts
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8
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New Accounts
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9
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Authorized Brokerage Firms—U.S. Employeesand U.S. Persons Subject to the Code
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9
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Non-Reportable Accounts
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10
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Personal Securities Transactions
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10
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Private Placements
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11
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Reportable Transactions (transactions that do not requirepre-clearance but must be reported)
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11
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Personal Trading Restrictions and Prohibited Activities
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12
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Reporting Requirements
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14
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Summary of Reporting Obligations
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14
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Communications with Disinterested Trustees and Outside Directors
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15
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Japan Supplement | 15 |
DIMENSIONAL FUND ADVISORS
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4
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Outside Activities
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16
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Guidelines
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17
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Approval Process
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17
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Gifts and Business Entertainment
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18
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Gifts
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18
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Business Entertainment
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19
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Political Contributions
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20
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Other Policy Highlights
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22
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Policy Against Bribery and Corruption
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22
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Privacy Policies
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22
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Glossary of Terms
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23
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Appendix A—List of Authorized Brokerage Firms
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27
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honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and
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full, fair, accurate, timely, and understandable disclosure in reports and documents filed with relevant global regulatory agencies and in other public communications made by Dimensional;
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compliance with applicable governmental laws, rules, and regulations;
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the prompt internal reporting of violations of the Code and the Standard of Conduct to the Global Chief Compliance Officer (“Global CCO”), Chief Compliance Officer for the U.S. registered funds, or a Designated
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accountability for adherence to the Code and the Standard of Conduct.
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DIMENSIONAL FUND ADVISORS
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6
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The Global CCO and/or Designated Officer
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General Counsel or
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a member of the Ethics Committee
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verbal or written warnings,
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letters of reprimand,
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suspension of personal trading activity,
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DIMENSIONAL FUND ADVISORS
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7
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disgorgement and forfeiture of profits,
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suspension, and/or
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termination of employment
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Covered Accounts
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Brokerage Accounts
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Discretionary/Robo-advised Accounts1
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Employee Stock
Compensation Plans
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Retirement Accounts
(IRAs, 401(k) or local equivalent)
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Transfer Agent Accounts
(such as a Computershare account)
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Mutual Fund Accounts
(i.e., collective investment schemes)
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Wrap Accounts
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UTMAs or UGMAs
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Treasury Direct Accounts
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Cryptocurrency Accounts
(excluding Wallets)
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529 Accounts
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1. |
Discretionary Accounts including those advised or sub-advised by Dimensional) must be disclosed and approved by Compliance. Supporting documentation must be provided to Compliance as part of your
approval request.
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DIMENSIONAL FUND ADVISORS
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9
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Other Covered Accounts
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Contract for Difference Accounts
(CDAs) (UK-specific) |
Self-Invested Personal Pensions (SIPPs)
and Stock and Shares ISAs (UK-specific) |
Superannuation Accounts (managed,
SMSF, or Super Wrap)
(Australia-specific) |
Nippon (Japan) Individual Savings
Account (NISA) (Japan-specific) |
Personal Retirement Savings Accounts
(PRSA) (Ireland-specific) |
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Local supplementary or mandatory provident funds or retirement schemes
(i.e., CPF accounts in Singapore; MPF accounts in Hong Kong) |
DIMENSIONAL FUND ADVISORS
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10
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Dimensional 401(k) account (or local equivalent);
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Dimensional Health Savings Accounts (HSAs);
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Dimensional Managed Fund accounts established through Fund Operations; and
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If applicable, holdings in Dimensional’s privately issued shares.
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Covered Securities
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Stocks/Shares
(common, preferred, or restricted)
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Fixed Income Securities (excluding
certain Sovereign Government issuances)
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Exchange-Traded Funds (ETFs) must be pre‑cleared if the aggregate daily trade value of the security, across all accounts, is >$50,000 (USD) per ETF per day
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2. |
The Designated Officer is required to receive prior written approval of his/her personal securities transactions from Dimensional’s Global CCO. The Global CCO is required to receive prior approval of
his personal securities transactions from one of the Dimensional Co-Chief Executive Officers.
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DIMENSIONAL FUND ADVISORS
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11
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Depositary Receipts (ADRs or GDRs)
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Closed-End Funds and REITs
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Derivatives
(options, futures, forwards, etc.)
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Voluntary Corporate Actions
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Private Placements (documentation
must be provided)
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Limited Partnerships and Limited
Liability Company Interests
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Warrants & Rights
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Convertible Securities
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Exempt Securities
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Shares of U.S. registered open-end
investment companies
(i.e., open-end mutual funds)
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Bankers’ acceptances, bank certificates
of deposit, commercial paper, and high
quality short-term debt instruments
(including repurchase agreements)
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Direct obligations of the U.S.
Government, or direct obligations
of a Sovereign Government
(e.g., Government of the United
Kingdom, Commonwealth
Government of Australia)
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Shares issued by a unit investment
trust that are invested exclusively in
one or more registered open-end
investment companies (none of which
are Dimensional Managed Funds)
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Shares of money market funds
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Privately issued shares of the Advisor
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Dimensional Managed Funds (through a third-party service provider or financial advisor);
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Investments in any funds sub-advised by Dimensional;
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529 Accounts that hold or are exclusively made up of Dimensional Funds;
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DIMENSIONAL FUND ADVISORS
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12
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Automatic Investment Plans (including dividend reinvestment plans) in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation; and
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Exchange-Traded Funds (ETFs) where the aggregate daily trade value per security is less than or equal to USD $50,000 per ETF per day.
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Limit orders that expire after the T+1 pre-clearance period (including limit orders with no expiration date);
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Transactions on margin;
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Initial public offering (IPO) or initial coin offering (ICO) investments;
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Short selling of securities;
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Transactions in securities that are subject to firmwide restriction; and
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Transactions in a security while in possession of insider information. Such transactions are unethical and may be illegal and will be dealt with decisively (reference the Global Insider Trading Policy, the
EU Anti-Market Abuse Policy, the Singapore Supplemental Insider Trading Policy, and the Japan
Insider Trading Management Policies).
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A pre-clearance request involving a covered security will be denied if Dimensional has traded in the same or equivalent security within the past seven (7) calendar days, and the pre-clearance request is for an amount over USD $10,000. Any
transaction in a covered security for an amount less than or equal to USD $10,000 still must be pre-cleared and reported, with the exception that transactions in ETFs only require pre-clearance where
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Compliance will monitor trading activity for seven (7) calendar days following the pre-clearance approval date for conflicts of interest on non-Discretionary Accounts.
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DIMENSIONAL FUND ADVISORS
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13
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Access Persons cannot profit from the purchase and sale (or sale and purchase) of the same or equivalent security, across all accounts, within sixty (60) calendar days.
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Gains are calculated based on a last-in, first-out (LIFO) method within a sixty (60) calendar day period.
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If you purchase or sell a digital currency considered to be a “security” within the meaning of the U.S. federal securities laws (or any other applicable laws for non-U.S. personnel), you need to pre-clear the transaction just
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As with any initial public offering (IPO), your participation in an Initial Coin Offering or Initial Token Offering (ICO), is not permitted under the Code.
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Holding or transacting in actual cryptocurrency that has been determined not to constitute a security within the meaning of the U.S. federal securities laws (or any other applicable laws for non-U.S. personnel), including holding or
transacting in Bitcoin or Ethereum, does not require pre-clearance or reporting to Compliance.
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DIMENSIONAL FUND ADVISORS
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14
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New Hires
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All Employees
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Upon joining the firm
(Due in 10 calendar days)
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Quarterly and Annually
(Due 30 calendar days after
each quarter)
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New Hire Questionnaire
(Disciplinary Action Disclosure)
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Quarterly and Annual
Compliance Questionnaires
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Initial Holdings Report
(include private placements)
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Quarterly Transaction Reports and
Annual Holdings Certification
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Provide Covered Account
statement(s) (current, within
45 days prior to start date)
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Covered Account(s) Certification;
report new accounts upon opening
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Code of Ethics, Insider Trading
and Compliance
Manual Acknowledgements
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Code of Ethics, Insider Trading
and Compliance
Manual Acknowledgements
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DIMENSIONAL FUND ADVISORS
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15
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DIMENSIONAL FUND ADVISORS
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17
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As a general matter, directorship or (an equivalent position) in an unaffiliated public company (or companies reasonable expected to become public companies) will not be authorized because of the potential conflicts.
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If you wish to accept a directorship, or (an equivalent position), you must obtain prior approval from the Boards of Directors of the Dimensional Entities in which you are an employee and/or an officer.
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If you wish to be involved with a private organization (non-Dimensional) in an official capacity (officer, directorship or an equivalent position), you must obtain approval from the Co-CEOs and the Global CCO.
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If you wish to be involved with a non-profit organization in an official capacity (directorship or an equivalent position), you must notify Compliance in writing, as further approval may be required.
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If you receive compensation from an outside organization, you must obtain prior written approval from your supervisor and Compliance.
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DIMENSIONAL FUND ADVISORS
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18
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You may not give (or accept) gifts in excess of USD $100 (or the local currency equivalent).
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You may not give (or accept) gifts in the form of cash or cash equivalents.
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Gifts valued in excess of USD $100 must be reported to Compliance and returned unless an exception is granted by the Global CCO or Compliance Designee.
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No exceptions will be granted for gifts subject to FINRA’s USD $100 gift limit.
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DIMENSIONAL FUND ADVISORS
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You may not accept any gifts from Broker Donors except gifts of de minimis value, such as non-lavish, logoed items or gifts of less than USD
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Attending business-related events with an expected value in excess of USD $100 per person (or the local equivalent);
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Meals or events in which family members or friends are present; and
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DIMENSIONAL FUND ADVISORS
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20
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Attending meals or events in which five (5) or more Dimensional employees are in attendance.
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You may not accept entertainment (such as sporting events) from Broker Donors. You may accept business meals from Broker Donors of less than USD $100 in anticipated value, and you must report those meals to your supervisor and Compliance.
You may accept business meals from Broker Donors of greater than USD $100 in anticipated value provided you first pre-clear the meal with your supervisor and Compliance.
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Japan Addendum to Gifts and Entertainment
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3. |
Political Contributions by Certain Investment Advisors, Rule 206(4)-5; Engaging in Distribution and Solicitation Activities
with Government Entities, FINRA Rule 2030.
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4. |
Contributions include, but are not limited to, monetary contributions, gifts, and loans (including in-kind contributions, such as donation of goods or services).
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DIMENSIONAL FUND ADVISORS
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Contributors are prohibited from making political or charitable contributions for the purpose of obtaining or retaining potential or existing public entity clients;
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Contributors are prohibited from making any contributions that create the appearance that Dimensional stands to benefit in its business relations because of such contribution; and
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Contributors from Dimensional’s non-U.S. based advisor affiliates are prohibited from making any political contributions to political action committees (PACs) federal, state, or local candidates for elective office in the United States.
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Covered Government Officials
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U.S. Political action committees (PACs)
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DIMENSIONAL FUND ADVISORS
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22
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Updated as of January 1, 2024
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(US_22035.14)
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any director/trustee or officer of the U.S. Registered Funds or Dimensional Entities;
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any officer of the Distributor who, in the ordinary course of business, makes, participates in, or obtains information regarding the purchase or sale of covered securities for any registered investment company for which the Distributor
acts as the principal underwriter;
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employees of Dimensional who, in connection with their regular functions or duties, make, participate in, or obtain information regarding the purchase or sale of covered securities, or other advisory clients for which the Advisors provide
investment advice, or whose functions relate to the making of any recommendations with respect to such purchases or sales;
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any natural persons in a control relationship with one or more of the
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any Supervised Person (which may include contractors or consultants) who has access to nonpublic information regarding client securities transactions, research, or portfolio holdings of any Dimensional Managed Funds.
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DIMENSIONAL FUND ADVISORS
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DIMENSIONAL FUND ADVISORS
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25
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Spouse, civil union or domestic partner;
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Any person(s) sharing the same household with the employee, including child, stepchild, grandchild, parent, stepparent, grandparent, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, sister-in-law,
adoptive relationships, and legal guardianships;
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someone who holds account(s) in which the employee is a joint owner, has trading authority, or Beneficial Ownership; and/or
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person(s) sharing the same household with the employee for whom the employee contributes to the maintenance of the household and the financial support of such person.
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DIMENSIONAL FUND ADVISORS
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Ameriprise
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Betterment
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Edward Jones
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Charles Schwab
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E*Trade
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Fidelity Investments
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LPL
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Merrill Lynch
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Morgan Stanley
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Raymond James
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USAA
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Vanguard
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Wells Fargo
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