Double Bottom Line Investing
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From our beginning in 1993, The Rose Inc. has been committed to integrating social and environmental considerations into the research process. What was then known as SRI (Socially Responsible Investing) has morphed into ESG (Environmental, Sustainability & Governance) today. Our commitment to considering these issues remains strong.
Investment Process & Philosophy
We spend the majority of our time in research; reading, writing and consulting colleagues. We are style agnostics, and not true believers in any particular investment approach. We believe we can learn from those who hold a ‘value’ and/or a ‘growth’ oriented bias. With The Rose Inc., you’ll find that we often take a contrarian position—a leadership position—that places us at odds with ‘consensus’ sentiment.
We Believe
- Investing in common stock is an effective way to build and preserve wealth over time.
- In well diversified portfolios as a means of managing risk.
- It is possible to find stocks worth owning in all market cycles; up, down or flat.
- In considering ESG (Environmental, Social & Governance) criteria as part of the stock selection process.
- The greatest reward is often achieved by investing when the economic horizon is clouded with doom and gloom.
- Holding on to equity positions during adverse market conditions is a prudent course of action.
- In a ‘long only’ investment strategy combined with a ‘fee only’ business model.
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As a company, we have a strong equity bias—we like stocks. We believe there is a broad universe of investment options available in the global offering of publicly traded securities for corporate ownership through common, preferred and convertible stock. We don’t engage in trading strategies or attempt to time markets. Positions are typically held for an intermediate term of 5-10 years. As a consequence, portfolio turnover is relatively low over time.
The Rose Inc., doing business as The Rose Investment Management, adopts this code of ethics as a guideline for employees in the conduct of its daily business.
The Rose Inc. affirms a fiduciary standard of service placing the firm’s clients’ economic interest first. The firm owes its clients a duty of undivided loyalty placing our client’s interest ahead of that of the firm or its employees.
For the purpose of this code, ethical conduct and business practice are understood as a standard of performance that exceeds compliance with rules and regulations. Ethical conduct in this sense accepts a requirement to perform in a manner that complies with the ‘spirit’ or intent of a rule as well as the more literal sense of the ‘letter’ of the law. In this regard, The Rose Inc. functions as a steward of client investments, information, goals and trust.
- This code of ethics requires The Rose Inc., its owners and employees to comply with all applicable federal and state securities laws and attendant regulations. Compliance with these regulations and the firm’s code is mandatory.
- The code prohibits all personnel from engaging in fraudulent, manipulative or deceptive conduct in connection with personal trading of any securities that are held by The Rose Inc. and in client accounts.
- No person subject to the code will engage in an outside business activity without prior disclosure and approval from the appropriate supervisory personnel.
- All persons subject to the code will file an acknowledgement of receipt of the code and agree to abide by its provisions.
- All investment personnel are prohibited from receiving any gift or other thing of more than de minimis value from any person or entity that does business with, or on behalf of the firm.
- The personal trading rules and restrictions delineated below must be adhered to strictly.
Personal Trading
- Employees are permitted to maintain personal securities accounts. The firm maintains records of the personal transactions in all accounts of the firm, its owners and employees. Duplicate or original statements and confirmation are kept on file by the Compliance Officer and maintained as part of the books and records of the firm.
All transactions must contain the following information:
- Name, ticker symbol or CUSIP, number of shares or dollar amount of the security involved.
- An explanation of the purchase or sale, relative to its applicability to client holdings or potential holdings.
- Date of the transaction.
- Nature of the transaction, i.e. purchase or sale.
- Names of the executing broker/dealer or custodian.
- All personal securities transactions, including ETFs are covered and must be pre-cleared with the firm’s Compliance Officer. Transactions in direct obligations of the US Government, Agency or corporate bonds, bank CDs, open-ended mutual funds and money market funds need not be pre-cleared.
- An initial holdings report must be provided within 10 days of hire and the information must be current as of no more than 45 days prior to the date of hire. This requirement applies to all personnel.
- Personnel must document and disclose gifts or entertainment in excess of a ‘de minimis’ amount defined for these purposes as greater than $100.00 for each individual, couple, from any person or entity that does business or seeks to do business with the firm.
- Personnel must notify the firm when they open a brokerage account and arrange for duplicate confirmations and statements to be sent to the firm’s compliance officer.
- Personnel must certify annually as to their understanding and compliance with the firm’s code of ethics.
- All employee holdings and transactions are reviewed periodically by the Compliance officer.
Recordkeeping
The firm keeps copies on file of its code of ethics, written acknowledgement of receipt of the code, records of violations of the code and records of action taken as a result of violations.
Insider Trading
Given the size of the firm and the nature of its customer base, it is not likely that personnel will encounter ‘insider’ information. However, the firm’s policy prohibits any employee from acting upon, misusing or disclosing any material non-public information, known as insider information.
Any employee who thinks they may have received non-public information from a friend, business associate, or acquaintance must immediately report that finding to the compliance officer.
