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Item 1
Cover Page
Form ADV Part 2A
Oak Ridge Investments, LLC
10 South LaSalle, Suite 2130
Chicago, Illinois 60603
312-857-1040 www.oakridgeinvest.com
This brochure provides information about the qualifications and business practices of Oak Ridge
Investments, LLC. If you have any questions about the contents of this brochure, please contact us
at 312-857-1040. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority.
Additional information about Oak Ridge Investments, LLC also is available on the SEC’s website
at www.adviserinfo.sec.gov.
Oak Ridge Investments, LLC is an investment adviser registered with the SEC. This registration
does not imply a certain level of skill or training.
December 1, 2025
Item 2
Material Changes
Since our last brochure dated March 26, 2025, we have made the following material changes:
Item 10 has been updated to remove references to our affiliation with North Square Investments.
As of November 2025, North Square Investments no longer has a minority interest in Oak Ridge
Investments, LLC.
Item 14 has been amended to reflect that Oak Ridge does not have any active client referral
arrangements.
Item 3
Table of Contents
Item 1
Cover Page ................................................................................................................................ 1
Item 2 Material Changes ...................................................................................................................... 2
Item 3
Table of Contents ...................................................................................................................... 3
Item 4
Advisory Business .................................................................................................................... 4
Item 5
Fees and Compensation ............................................................................................................ 6
Item 6
Performance-Based Fees and Side-by-Side Management ........................................................ 8
Item 7
Types of Clients ........................................................................................................................ 8
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 9
Item 9
Disciplinary Information ........................................................................................................ 13
Item 10 Other Financial Industry Activities and Affiliations ............................................................... 13
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 14
Item 12 Brokerage Practices ................................................................................................................ 15
Item 13 Review of Accounts ................................................................................................................ 18
Item 14 Client Referrals and Other Compensation .............................................................................. 19
Item 15 Custody ................................................................................................................................... 19
Item 16
Investment Discretion ............................................................................................................. 20
Item 17 Voting Client Securities .......................................................................................................... 20
Item 18 Financial Information ............................................................................................................. 22
Additional Information – Privacy Notice ................................................................................................. 23
Item 4
Advisory Business
Oak Ridge Investments, LLC (“Oak Ridge,” “We” or the “Firm”) is an investment advisory firm
founded in 1989. Our founder and CEO, David Klaskin, is a majority owner of the Firm. We
focus, and predominantly limit, our direct advice to analyzing and recommending equity stocks
traded on United States stock exchanges for our clients, currently in the strategies described
below.
Equity Strategies
As of the date of this document, the Firm manages five diversified equity strategies (the “Equity
Strategies”) for separately managed accounts and manages, or is available to manage, unified
managed accounts:
• Small/Mid Cap Growth invests in securities with a market cap range at the time of
initial purchase similar to its benchmark, the Russell 2000® Growth Index.
• Mid Cap Growth has a market capitalization guideline at the time of initial purchase
of being in line with its benchmark, the Russell Midcap Growth® Index.
• Large Cap Growth holds stocks with a market capitalization of over $3 billion at the
time of purchase. The strategy’s benchmark is the Russell 1000® Growth Index.
• All Cap Growth purchases securities with a market capitalization of $500 million or
greater. The strategy’s benchmark is the Russell 3000® Growth Index.
• Dividend Growth is a concentrated portfolio, holding 25-35 securities, with a
minimum capitalization of $5 billion. The benchmark for this strategy is the S&P 500
Index and the portfolio’s goals include seeking to buy stocks with a growing dividend
per share and exceeding the dividend yield rate for the index.
The primary objective of our Equity Strategies is long-term capital appreciation. Our Dividend
Growth investment strategy also has dividend yield as a primary objective. We generally
maintain accounts fully invested in equity securities, which we define as holding less than 10%
in cash and equivalents. Additional information about the Equity Strategies can be found in
Item 8, Methods of Analysis, Investment Strategies and Risk of Loss.
Our clients in the Equity Strategies can access our portfolio management through multiple
channels, including directly through the Firm or through one or more programs sponsored by
unaffiliated entities (“Sponsored Programs”). The unaffiliated entities (each a “Sponsor”) can
be a bank, broker-dealer or investment advisor. There are three types of Sponsored Programs:
1) Dual Contract programs where the client signs separate agreements with the Sponsor and
with Oak Ridge; 2) Sub-advised programs, including wrap fee programs, in which the client
signs an agreement only with the Sponsor and the Sponsor has the discretion to engage Oak
Ridge to advise a separate account on behalf of clients within the program; or 3) Unified
Managed Account (“UMA”) programs in which Oak Ridge provides a Sponsor with a model
portfolio, but does not have discretion over client assets, records of individual client holdings
and typically information about individual clients.
Oak Ridge invests discretionary assets for each account in the Equity Strategy(ies) chosen by a
client using Oak Ridge’s Equity Strategy model portfolio. Oak Ridge also considers each
client’s objectives, individual needs and restrictions. Oak Ridge manages the equity holdings
and the overall asset allocation between equities and cash, but does not select money market
funds, mutual funds or ETFs for clients. You, your custodian, broker-dealer or investment
advisor should select a money market fund or cash equivalent that is appropriate for your Oak
Ridge account.
We will accept accounts with reasonable restrictions (see Item 16, Investment Discretion) and
will follow client direction for individualized treatment of securities, such as for tax gain or loss
sales or certain limited other purposes. We will also work with clients on restrictions for clients
who desire their accounts be managed in a socially responsible way as however the clients may
want to define that. Oak Ridge will also provide input on managing an account, if requested, in
accordance with environmental, social and governance standards (“ESG”) as the client may
want to define or design that. Oak Ridge will also consider other circumstances, such as ticket
charges if applicable, when trading client portfolios. You should contact us, either directly or
through your Program Sponsor, to inform us of any changes in your circumstances or
restrictions that would affect how we manage your account.
Wrap Fee and Sponsored Programs – Wrap fee accounts and other Sponsored Program accounts
may be billed to you as a single fee by the Sponsor. The Sponsor will pay Oak Ridge’s
investment advisory fee out of the wrap fee it collects, with the remainder being retained as its
fees and/or advisory or consulting fees and in lieu of the Sponsor’s commissions and custody
fees. Cash needs in these accounts may be slightly higher than in other accounts due to the
combined fees (for the Sponsor and Oak Ridge) periodically deducted directly from the
portfolio assets. Additional information about fees can be found in Item 5, Fees and
Compensation.
In determining whether to establish a Sponsored Program account, whether a wrap fee program
or otherwise, you should be aware that the overall costs may be higher or lower than you might
incur by accessing the same services outside of the Sponsored Program. In evaluating whether
or not a wrap fee program or arrangement is appropriate for your needs, you should consider
factors such as the size of the account, the expected frequency of transactions by the advisor in
the investment strategy or due to cash flows initiated by you, and your investment objectives.
Rebalancing transactions due to cash flows in or out of your account, especially in smaller
accounts, may affect performance and could incur higher than normal trading expenses
(including commissions if in place) both in amount and as a percentage of your account value.
These factors could influence your decision whether or not to choose a wrap account or even
whether to engage in cash flow transactions on as frequent a basis.
UMA Programs – Oak Ridge has agreements with other investment advisors who use model
portfolios provided by the Firm as the basis for investment strategies that they offer to their
clients. Oak Ridge does not create these models for any specific individual(s) or the particular
needs of any client; but based upon what Oak Ridge believes is an appropriate allocation and
weighting of securities for each strategy. The UMA investment advisor has discretion to
determine when, how and to what extent to act upon Oak Ridge’s recommendations.
Assets under Management; Assets under Administration
As of December 31, 2024 we had assets under administration of approximately $2.09 billion
which included discretionary client assets under management of approximately $1.31 billion
and an additional approximately $787 million advised on a non-discretionary basis in UMA
accounts.
Item 5
Fees and Compensation
Clients pay Oak Ridge asset-based investment advisory fees. Fees are determined by agreement
with the client or with a Program Sponsor. Oak Ridge does not charge performance-based fees
to clients in our Equity Strategies or currently to any of its clients.
The fees shown in the table below are those that are listed in the Firm’s standard investment
management agreement for separately managed accounts, including some Sponsored Program
clients who have their firm negotiate fees directly with Oak Ridge. See below for fee
information for other Sponsored Programs.
Standard Fee Schedule
All Cap Dividend Growth
First $10 million
Next $15 million
Next $25 million
Over $50 million
Mid Cap
0.85
0.75
0.70
0.65
Small/Mid Cap
0.95
0.90
0.80
0.70
Large Cap
0.65
0.55
0.50
0.45
0.80
0.70
0.65
0.60
0.75
0.65
0.60
0.55
Fees are negotiable and may vary based on the size of the account, related clients, and other
factors. Clients can choose to be billed directly or to have fees paid through their investment
account. If they choose the latter, Oak Ridge will communicate directly with the custodian for
payment. Some arrangements will depend on the cooperation of the custodian chosen by the
client. As a result of being negotiable, final fees charged are usually different than these listed
fees.
Fees are generally billed quarterly in advance based on assets as of the end of the previous
calendar quarter. Assets in the account include securities, cash or cash equivalents and accrued
income. New accounts billed in advance will be billed based on their beginning assets and
prorated for the remainder of the quarter. The Firm may also charge a prorated fee for material
deposits to an account during a billing period. If you terminate your account during a quarter, a
prorated portion of the quarterly fees billed in advance will be refunded to you or if billed in
arrears you will be billed for the pro-rata portion of the fee for the period your account was
managed by Oak Ridge during the quarter. Typically, the refunds are issued after the end of the
quarter or when a Sponsor provides required information to Oak Ridge, but if a client wants the
refund earlier a client can request it of Oak Ridge or their Sponsor. Some clients and programs
prefer to be billed in arrears based upon the account’s value at the end of the quarter or other
relevant period (including in some cases monthly) and, depending on the circumstances, the
Firm is amenable to those billing arrangements.
The Oak Ridge fees do not include custodial fees, transaction fees, commissions, trading
markups or mark-downs, wire fees or any other fees that may be charged by brokers for
execution of trades or by custodians for holding and administering the assets in your account.
For additional information about brokerage and related expenses, see Item 12, Brokerage
Practices. There are instances where, for best execution purposes, Oak Ridge will trade
accounts, in particular for smaller or less liquid stocks, at a firm other than the Sponsor, even
for wrap accounts. This may result in a transaction charge for that trade that is not covered by
the wrap fee and clients would be paying that charge (see Item 12, Brokerage Practices). If your
account holds mutual funds, including money market funds and ETFs, those funds will pay their
own additional fees to their service providers. These fees will not be paid by the wrap sponsor
and are in addition to the investment advisory fees charged by Oak Ridge and the Sponsor.
Further information about fees paid by mutual funds, money market funds and ETFs in your
account can be found in each third-party fund’s prospectus. Oak Ridge does not hold mutual
funds in its separately managed accounts and only holds ETFs in those accounts in very limited
circumstances upon request by a client, generally limited to a period of time during a tax loss
sale waiting period.
Sponsored Programs
If Oak Ridge manages your money through a Sponsored Program, including wrap fee separately
managed account programs and UMAs, and you do not negotiate the fee directly with Oak
Ridge, Oak Ridge’s investment management fees are negotiated between Oak Ridge and the
Sponsor. Oak Ridge receives its fees directly from the Sponsor as a portion of the fee the
Sponsor charges you for the Sponsored Program or UMA. You should consult the Sponsor’s
Form ADV Part 2A (Brochure) or Wrap Brochure, as applicable, for additional information on
the fees charged, billing practices and other charges related to that account.
ERISA Account Fees and Compensation
Oak Ridge acknowledges that it is a fiduciary for assets in client accounts for employee benefit
plans governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”).
The information below is provided to comply with the disclosure requirements of ERISA
Section 408(b)(2). The information summarizes the direct and indirect compensation that Oak
Ridge reasonably expects to receive in connection with providing investment advisory services
to employee benefit plans subject to ERISA.
Direct Compensation – For clients who have a contract directly with Oak Ridge, the Firm
receives an investment management fee which is billed to the plan fiduciary. This fee may be
paid from the plan assets or by the plan sponsor or beneficiary, in accordance with the plan
documents. The fee is based on the assets in the account and is set forth in the fee schedule of
the agreement between the client and Oak Ridge. Upon request, Oak Ridge can provide details
on the direct compensation paid to the Firm and such amounts are generally reflected on client
account statements and reports from your custodian.
Indirect Compensation – Employee benefit plans that utilize Oak Ridge’s services through a
Sponsored Program may pay fees to the Sponsor and not directly to the Firm. In those cases,
the Sponsor pays a portion of its fees to Oak Ridge, as described more fully above and in the
Sponsor’s Form ADV or Wrap Brochure.
Oak Ridge may recognize an indirect benefit in the form of research and execution services
acquired through trading with or payment of soft dollars (trade commissions or markups/mark-
downs on trades) to research service providers. Proprietary research generally includes access
to conferences, analysis, forecasts and in-house research. These services do not have an
identifiable monetary value. To the extent Oak Ridge were to use other services, such as third-
party research services paid for by a broker, an estimated allocation of monetary value can
usually be made. Additional information about Oak Ridge’s use of soft dollar services can be
found in Item 12, Brokerage Practices.
Item 6
Performance-Based Fees and Side-by-Side Management
Oak Ridge does not charge any performance-based fees to clients invested in the Equity Strategies,
or any other client at this time.
Item 7
Types of Clients
Our clients consist of individuals, pension and profit-sharing plans, retirement accounts, trusts,
estates, corporations and other business entities, charitable organizations, and banks and thrift
institutions. Clients can access our portfolio management by opening an account directly with us
(with custody to be at a brokerage firm), with a Sponsor in a program we sub-advise or in a UMA
program. All accounts, other than UMA accounts, are discretionary, which means that Oak Ridge
has been granted the ability to make and implement, and Oak Ridge makes and implements,
investment decisions without consulting with the client.
The minimum account size for direct separately managed accounts is listed as $1 million, although
that is negotiable based on expected growth, total relationship size and other factors. As a result of
negotiation, account sizes are usually lower than that amount. Wrap fee and UMA stated program
minimums vary and are generally lower than Oak Ridge’s minimum and are often as low as
$100,000. They are negotiated between the Sponsor and Oak Ridge or set by the Sponsor’s program.
Details on the minimum account sizes for those programs can be found in the respective Sponsor’s
Form ADV.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our portfolio managers and analysts focus predominantly on fundamental research in selecting
stocks for our clients. We perform bottom-up analysis of companies to evaluate if they meet our
investment criteria and we consider cyclical and other factors to in part determine sector and
industry weightings. The Equity Strategies invest in common stocks that are traded on United States
securities exchanges. Most stocks we purchase are based in the United States, but we may invest a
portion of the accounts in stocks or more likely ADRs (American Depository Receipts) of non-U.S.
based companies which trade on a United States securities exchange.
We believe earnings growth, teamed with strong fundamentals and reasonable valuations, are the
primary determinant of long-term stock price appreciation. Stocks are purchased using a long-term
horizon and as a result, our annual portfolio turnover tends to be somewhat lower than many other
actively managed equity portfolios.
The initial position weight is usually 2.5% or less, except for Dividend Growth which is more
concentrated. Sector weights in the Equity Strategies may be as high as twice the sector benchmark
weight of a larger sector and may be as low as 0% in certain smaller sectors.
Key Risks
Investing in securities involves risk of loss that clients should be prepared to bear. Past performance
is not a guarantee of future results. In addition to the general risks of investing in the stock market,
our portfolios bear additional risk. We note that buying a portfolio of securities is usually thought
to reduce the risk of buying one or only a few stocks. The description below is an overview of the
risks entailed in Oak Ridge’s investment strategies and is not intended to be complete. All investing
involves the risk of loss and the investment strategy offered by Oak Ridge could lose money over
short or long periods. Performance could be hurt by a number of different market risks including
but not limited to:
Equity Risk. (All strategies) The value of equity securities may fall due to general market and
economic conditions, perceptions regarding the industries in which the issuers participate, or factors
relating to specific companies. Equity investments are volatile and will increase or decrease in value
based upon issuer, economic, market and other factors. Small capitalization stocks generally involve
higher risks in some respects than do investments in stocks of larger companies and may be more
volatile.
Small & Medium Cap Company Risk. (Small/Mid Cap Growth, All Cap Growth) Smaller
companies may be subject to more abrupt or erratic market movements and may have lower trading
volumes or more erratic trading than larger, well-established companies. Securities of companies
with small and medium market capitalizations are often more volatile and less liquid than larger
companies' investments. Small and medium cap companies may face a higher risk of business
failure, increasing the client's portfolio's volatility. While smaller companies generally have the
potential for rapid growth, they often involve higher risks because they may lack the management
experience, financial resources, product diversification, and competitive strength of larger
companies. In addition, in many instances, trading frequency and volume may be substantially less
than is typical of larger companies. As a result, the securities of smaller companies may be subject
to broader price fluctuations.
Large Cap Company Risk. (Large Cap Growth, All Cap Growth, Dividend Growth) Larger, more
established companies may be unable to attain the high growth rates of successful, small
companies during periods of economic expansion.
Foreign Investment Risk. (All strategies) Prices of foreign securities (including ADRs) may be
more volatile compared to U.S. securities due to economic and social conditions abroad, political
developments, and changes in regulatory environments. They are more likely to be subject to
currency fluctuation risks. Some of the same considerations apply for U.S. based businesses with
significant operations abroad. The securities of non-U.S. issuers also involve a high degree of risk
because of, among other factors, the lack of public information with respect to such issuers, less
governmental regulation of stock exchanges and issuers of securities traded on such exchanges and
the absence of uniform accounting, auditing and financial reporting standards. The non-U.S.
domicile of such issuers and currency fluctuations may also be factors in the assessment of financial
risk to the investor. Foreign securities markets are often less liquid than U.S. securities markets,
which may make the disposition of non-U.S. securities more difficult. Emerging markets can be
subject to greater social, economic, regulatory, and political uncertainties and can be extremely
volatile.
Sector Concentration Risk. (All strategies) We may overweight certain sectors, making the
portfolios more susceptible to negative events affecting those sectors.
Management and Strategy Risk. (All strategies) Investment strategies used by the Firm may not
be successful. Portfolio management decisions require judgment and are based on imperfect
information.
Fundamental Analysis. The Firm utilizes an investment process based upon fundamental business
and credit analysis; capital structure and liquidation analysis, a review of all legal documentation
surrounding an issuer’s securities and identification of an investment catalyst.
In making its investment decisions, the Firm will rely on internally generated research, derived from
annual reports, prospectuses, filings with the SEC, corporate press releases, inspections of corporate
activities, conversations with the firm and/or competitors, financial newspapers, magazines and
other sources. The Firm may also use research materials prepared by others in making an
investment decision. During the research process, the Firm makes an assessment of the quality of
the security in question by examining among other things financial metrics of the relevant company,
the integrity and strategic vision of the management team and the ability to execute such strategy,
as well as the attractiveness and risks of the company’s industry.
The Firm then determines what is believed to be a fair valuation for the security based on a
combination of its future earnings, operating cash flow, free cash flow, liquidation value and
revenues. If the public market price for the security is significantly below its fair valuation, the
Firm may attempt to purchase the security for a client’s portfolio. If the security is deemed to be
priced significantly above its fair valuation and it is currently included in a client’s portfolio, the
Firm will generally sell some or all of the position in the security. Performing this combined
qualitative and quantitative approach to stock selection encompass the majority of the Firm’s daily
activity.
Market Risk. The success of Client portfolio activities will be affected by general economic and
market conditions, such as interest rates, availability of credit, inflation rates, commodity prices,
economic uncertainty, changes in laws, trade barrier, currency fluctuations and controls, and
national and international political circumstances. These factors may affect the level of volatility of
securities prices and the liquidity of investments in Client portfolios. Such volatility or illiquidity
could impair profitability or result in losses.
Cash Management Risks. The Firm may invest some of a client’s assets temporarily in money
market funds or other similar types of investments, during which time an advisory account may be
prevented from achieving its investment objective.
Environmental, Social and Governance Matters. While environmental, social or governance
(“ESG”) is only one of the many factors the Firm will consider in making an investment, there is
no guarantee that the Firm will successfully implement and make investments in companies that
create positive ESG impact while enhancing long-term shareholder value and achieving financial
returns. To the extent that the Firm engages with companies on ESG-related practices and potential
enhancements thereto, such engagements may not achieve the desired financial and social results,
or the market or society may not view any such changes as desirable. Successful engagement efforts
on the part of the Firm will depend on the Firm’s skill in properly identifying and analyzing material
ESG and other factors and their impact-related value, and there can be no assurance that the strategy
or techniques employed will be successful. Considering ESG qualities when evaluating an
investment may result in the selection or exclusion of certain investments based on the Firm’s view
of certain ESG-related and other factors, and carries the risk that the Firm may underperform funds
that do not take ESG-related factors into account because the market may ultimately have a different
view of a particular company’s performance than that anticipated by the Adviser.
Consideration of ESG factors may affect the Firm’s exposure to certain companies, sectors, regions,
countries or types of investments, which could negatively impact the Firm’s performance depending
on whether such investments are in or out of favor. Applying impact investing goals to investment
decisions is qualitative and subjective by nature, and there is no guarantee that the criteria utilized
by the Firm or any judgment exercised by the Firm will reflect the beliefs or values of any particular
investor. In evaluating a company, the Firm is dependent upon information and data obtained
through voluntary or third-party reporting that may be incomplete, inaccurate or unavailable, which
could cause the Firm to incorrectly assess a company’s ESG practices and/or related risks and
opportunities. ESG-related practices differ by region, industry and issue and are evolving
accordingly, and a company’s ESG-related practices or the Firm’s assessment of such practices may
change over time.
Further, ESG practices are evolving rapidly and there are different principles, frameworks,
methodologies, and tracking tools being implemented by other asset managers, and the Firm’s
adoption and adherence to various such principles, frameworks, methodologies and tools is
expected to vary over time. There is also a growing regulatory interest across jurisdictions in
improving transparency regarding the definition, measurement and disclosure of ESG factors. The
Firm’s ESG policies could become subject to additional regulation in the future, and the Firm cannot
guarantee that its current approach will meet future regulatory requirements.
General Risk of Loss. Investing in securities involves the risk of loss. Clients should be prepared
to bear such loss.
Risk of Infectious Diseases and Pandemics. Any spread of an infectious illness, public health
threat, or similar issue could reduce consumer demand or economic output, result in market closures,
travel restrictions or quarantines, social unrest, significant volatility in financial markets,
commercial disruption on a global scale and generally have a significant impact on the economies
of the affected country and other countries with which it does business, which in turn could cause
financial market disruptions and adversely affect clients’ investments in that country and other
affected countries.
Portfolio Turnover Risk. Portfolio turnover refers to the rate at which investments are replaced.
The higher the rate, the higher the transactional and brokerage costs associated with the turnover
which may reduce the return, unless the securities traded can be bought and sold without
corresponding commission costs. Active trading of securities may also increase your realized capital
gains or losses, which may affect the taxes you pay.
Cybersecurity and Disaster Recovery Risk. With the increased use of technologies such as the
Internet and the dependence on computer systems to perform necessary business functions, Oak
Ridge, and its service providers, may be susceptible to operational, information security and related
risks. These systems are subject to a number of different threats or risks that could adversely affect
the clients and their accounts, despite the efforts of the Firm and service providers to adopt
technologies, processes and practices intended to mitigate these risks and protect the security of
their computer systems, software, networks and other technology assets, as well as the
confidentiality, integrity and availability of information belonging to the clients and the investors.
In general, cyber incidents can result from deliberate attacks or unintentional events. Unintentional
events may have similar effects. The risks associated with unintentional acts include power outages
and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. Cyber-attacks
include, but are not limited to, gaining unauthorized access to digital systems (e.g., through
“hacking” or malicious software coding) for purposes of misappropriating assets or sensitive
information, stealing or corrupting data, or causing operational disruption. Cyber-attacks may also
be carried out in a manner that does not require gaining unauthorized access, such as causing denial-
of-service attacks on websites (i.e., efforts to make network services unavailable to intended users).
Third parties may also attempt to fraudulently induce employees, customers, third-party service
providers or other users of Oak Ridge’s systems to disclose sensitive information in order to gain
access to Oak Ridge’s data or that of the client. Cyber incidents affecting Oak Ridge and its
respective service providers have the ability to cause disruptions and impact business operations,
potentially resulting in financial losses, impediments to trading, fraudulent trading and transfer
activity, cause information and technology systems to become inoperable for extended periods of
time or to cease to function properly, the inability to transact business, violations of applicable
privacy and other laws, regulatory fines, penalties, financial losses, reputational damage,
reimbursement or other compensation costs, or additional compliance costs. There is also a risk that
cybersecurity breaches may not be detected. The information and technology systems of Oak Ridge
and its service providers may be vulnerable to damage or interruption from computer viruses,
network failures, computer and telecommunication failures, infiltration by unauthorized persons
and security breaches (e.g., “hacking” or malicious software coding), The failure of these systems
and/or of disaster recovery plans for any reason could cause significant interruptions in Oak Ridge
and/or service providers operations, potentially resulting in financial losses, the inability to transact
business, or a failure to maintain the security, confidentiality or privacy of sensitive data, including
personal information relating to clients. Such a failure could harm to the Firm’s reputation, subject
any such entity and their respective affiliates to legal claims and otherwise affect their business and
financial performance. While the Firm and its service providers have established business,
continuity plans in the event of, and risk management systems to prevent or reduce the impact of
cyber-attacks, there are inherent limitations in such plans and systems due in part to the ever-
changing nature of technology and cyber security attack tactics, including the possibility that certain
risks have not been identified and prepared for. Furthermore, Oak Ridge cannot control the cyber
security and business continuity plans and systems put in place by service providers or any other
third parties whose operations may affect our clients and could be negatively impacted as a result.
Although Oak Ridge and all of its service providers have implemented various measures to manage
risks relating to these types of events, if these systems are compromised, become inoperable for
extended periods of time or cease to function properly, the relevant party may have to make a
significant investment to fix or replace them.
Item 9
Disciplinary Information
Investment advisers are required to report material facts regarding legal or disciplinary events that
are material to a client’s evaluation of the firm. Oak Ridge has nothing to disclose under this item.
Item 10
Other Financial Industry Activities and Affiliations
We are not registered, and do not have an application pending to register, as a broker-dealer or
registered representative of a broker-dealer. Currently, none of our employees are registered
representatives of a broker-dealer.
Neither we nor any of our management persons are registered, or have an application pending to
register, as a futures commission merchant, commodity pool operator, commodity trading advisor,
or an associated person of the foregoing entities.
We do not have any relationships or arrangements with related persons that is material to our
advisory business or to our clients.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Oak Ridge has adopted a Code of Ethics (the “Code”) to address potential conflicts of interest
between personal conduct and fiduciary duty to our clients. All employees must read, understand
and acknowledge the terms of the Code at least annually. A copy of the Code is available upon
request by contacting us at 312-857-1040.
Our goal is to make employees aware that they have an ongoing duty of good faith to act in the best
interests of our clients in managing our clients’ accounts; that employees’ personal securities
transactions must be conducted consistent with the Code in a way that avoids or mitigates any
conflict of interest; and that no inappropriate advantage should be taken of any position of trust or
responsibility given to us by our clients. The Firm’s employees are required to follow the Code of
Ethics. The Code of Ethics is designed to assure that the personal securities transactions, activities
and interests of the employees of the Firm will not interfere with (i) making decisions in the best
interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts.
The Firm permits its supervised persons to engage in personal securities transactions. Personal
securities transactions by employees may raise potential conflicts of interests when such person’s
trade in a security that is owned or considered for purchase or sale by a client. Subject to satisfying
the provisions of the Code and applicable laws, officers, directors and employees of the Firm and
its affiliates may trade for their own accounts in securities which are recommended to and/or
purchased for Firm clients.
Firm employees may take investment actions that differ from the advice given or the timing or
nature of action with respect to any one client account.
Subject to the aforementioned restrictions, the Firm and its supervised persons may at any time hold,
acquire, increase, decrease, dispose of, or otherwise deal with positions in investments in which a
client account may have an interest from time to time.
Where the Firm or a supervised person is contemplating taking a position in a recommended security,
the Firm or its supervised persons will refrain from engaging in any security transaction inconsistent
with the Code and fiduciary responsibility to the Firm’s clients. Neither the Firm nor any supervised
person will affect the market in a security the Firm recommends that a client buy or sell.
Oak Ridge employees, for their own accounts, accounts of family members and other accounts
where employees have discretion to trade, are required to pre-clear most personal securities
transactions. Pre-clearance will not be granted when a strategy trade (one which is done across the
board in an Equity Strategy) is being actively considered or is in progress. Notwithstanding the
previous sentence, employees who have accounts that are managed by Oak Ridge in an Equity
Strategy (in a manner similar to other accounts in that strategy) will participate in trading along with
other accounts in that strategy.
Client accounts do not hold mutual funds other than money market funds and in very limited
situations ETFs as described earlier.
One or more employees may manage securities portfolios for friends and family members, including
acting as trustee for trusts established by those friends and family members. These portfolios: a) are
clients of Oak Ridge which trade alongside other client accounts; or b) are not clients or traded in
the same strategies that Oak Ridge uses for client accounts. Employees are not paid advisory fees
by the trusts or individuals for managing these accounts, except that they may receive trustee fees
for serving as trustee for the account, and these accounts are disclosed and subject to Oak Ridge’s
personal securities transactions policies and Code of Ethics.
All employee trading is reviewed by compliance and is monitored on an ongoing basis for conflicts
of interest.
Item 12
Brokerage Practices
Oak Ridge’s policy is to seek to obtain best execution, the best combination of net price and
execution while considering potentially certain other factors such as research made available for the
benefit of our clients as a result of trading, for our clients. When deciding what brokers to use, the
Firm evaluates the full range and quality of services including quality of execution, research and
related services provided, financial stability, responsiveness, clearance and settlement procedures,
and other factors.
Oak Ridge also may choose firms through which to execute client trading due to client instructions
(directed brokerage) or to compensate a brokerage firm or vendor for research and related services
directly or indirectly provided to us (soft dollars) as described below.
Directed Brokerage
The majority of our clients access Oak Ridge’s services through Sponsored Programs. The majority
of these programs require or recommend that trading be directed through a specific broker-dealer,
often affiliated with the Sponsored Program. In many cases, such as wrap fee programs, the client
pays a single fee that includes the Sponsor’s trading costs. Clients who do not participate in
Sponsored Programs may also have a relationship with a specific brokerage firm and may choose
to direct Oak Ridge to trade through that firm.
When Oak Ridge is directed to use a specific brokerage firm, that direction may affect our ability
to achieve best execution for a client. For example, the commissions negotiated between a client
and the brokerage firm may be higher than what Oak Ridge might have negotiated. The client may
be getting other services from the brokerage firm that justify a higher trade cost and Oak Ridge will
not negotiate the commission rate for those accounts since the trading location is requested by the
client. Some directed brokers charge a minimum commission or a ticket charge for each trade.
Although Oak Ridge tries to monitor those situations to avoid excessive fees for client trading, those
charges may adversely affect portfolio performance. There may be other advantages Oak Ridge sees
in trading with certain firms, including their familiarity with the market for certain stocks or access
to blocks of shares in a stock.
Oak Ridge may try to mitigate some of the costs associated with directed brokerage when doing
trades for large blocks of accounts. See “Trade Aggregation & Rotation” below. Nevertheless,
clients who direct Oak Ridge to use a specific broker may in some cases pay a higher commission
than other clients and may lose the ability to be aggregated with other clients for trade execution. If
the trading is directed by the client back to a broker who has referred the client or other clients to
Oak Ridge, we could have a conflict of interest between obtaining the best execution for the client
and receiving future referrals from the broker. However, client referrals are not a factor Oak Ridge
considers in directing brokerage transactions. A client’s direction as to where to trade the client’s
account would often be to the Sponsor of the wrap or other Program in which the client was
participating. Oak Ridge’s utilizing that broker would be because the client requested it or because
it was economical or logical, not because of potential client referrals.
When a client directs Oak Ridge to generally use a particular broker, in certain circumstances Oak
Ridge will still trade with a different brokerage firm and “step out” the trade to the directed broker
(see below). All clients, including those in wrap fee programs, will pay commissions (references to
commissions throughout include price mark-ups and mark-downs) on these trades. Oak Ridge
believes that the benefits of the trade aggregation can in certain circumstances, especially prevalent
with many (but not exclusively) smaller capitalization stocks, exceed the resultant additional costs
and are consistent with our goal of seeking best execution for these clients.
Trade Aggregation & Rotation
When a portfolio manager initiates a strategy trade (a trade in a security across all accounts in one
or more Equity Strategies), orders for multiple accounts may be aggregated and traded in one or
more blocks. Accounts where Oak Ridge has trading discretion will be “blocked” together with
some directed brokerage accounts. A single broker-dealer will execute a full block but will “step
out” a portion or portions of the resultant trade in favor of one or more different broker-dealers that
have arrangements with a client(s) or a broker or party who provides research or related services to
Oak Ridge. Block trading allows accounts to participate in larger block transactions and get the
same execution price, among other potential benefits.
Oak Ridge may also block or aggregate rebalancing or other account-specific trades when multiple
accounts are traded with a single broker at the same time, but account-specific trades will not be
stepped out.
Some firms do not allow Oak Ridge to step out transactions for clients. In those cases, we will
always use the directed brokerage firm to execute transactions for clients who have directed us to
use that firm. In addition, Oak Ridge may use its discretion to exclude brokers from step out trades
even if they may be allowed to participate. Reasons for excluding a firm from step out transactions
include lack of confidence in the ability to settle the trades properly or efficiently, the size of the
overall transaction, and the size of the program or the number of clients in a program, among others.
Clients, in particular wrap fee clients, who participate in a transaction that is stepped out, will likely
pay charges that they would not otherwise pay. Some firms also charge an additional service charge
to process transactions that were traded at other firms. Oak Ridge balances the possibility of clients
paying additional fees or commissions with the expectation that a larger block can be traded more
efficiently and with market sensitivity that might not be possible when dealing with many smaller
trades.
Oak Ridge has a trade rotation policy that determines the order in which trades are executed for
multiple broker dealers for a strategy trade. The policy is designed to seek to provide an equitable
rotation where no broker/client program consistently executes trades earlier or later than others
except that if step out blocks are used for a particular trade, and they include multiple brokers, they
will usually be traded ahead of directed brokers who do not participate. As a result, priority in the
rotation order is often given to accounts and programs where Oak Ridge has more discretion.
Accounts with limits on discretionary authority, such as an inability or unwillingness to participate
in step
outs or Oak Ridge’s lack of visibility into the trading process, may trade in a rotation
following the execution of more fully discretionary accounts.
-
In cases where a block trade is not completed in a single day, trades will generally be allocated pro
rata across accounts in the block. For blocks that include multiple Sponsored Programs or directed
brokers, the traders may fill programs (or allocate trades pro rata in one or more programs) prior to
filling orders for other programs. When determining which programs to complete, we will consider
our trade rotation, the size of the order that was completed and other factors including past rotations.
Oak Ridge will also take into account programs or accounts that pay minimum commissions or
ticket charges and therefore those accounts/programs are more likely to have a random, rather than
pro rata, allocation to minimize overall transaction costs to those accounts.
Soft Dollars
When Oak Ridge has discretion to direct trading, including through aggregating and stepping out
trades, the Firm generally will use the commission dollars generated by client transactions to pay
for research and related services and execution services. The commissions paid to a brokerage firm
- the soft dollars - are paid by only some accounts, but the services that are received in return benefit
all clients. Therefore, clients who do not pay those commissions benefit from others’ payments. The
Firm also receives a benefit because we are not required to produce or pay directly for the research
services that are provided. Oak Ridge may have an incentive to select or recommend a brokerage
firm for trades based on our interest in receiving research from that firm rather than strictly
considering only that a client is receiving most favorable execution based on other factors alone. As
mentioned below, Oak Ridge’s research department, together with its trading department, evaluate
as a group the various brokerage firms and other research providers based on the benefits they
believe the Firm receives from the trading at the brokerage firm, research availability, research
quality, responsiveness to trading requests and other factors. The input of our trading team is
important since we believe the efficacy of our trading has an impact on the performance of our
investment management and thus indirectly on the success of our Firm. Poor trading results by any
brokerage firm over time would result in reduced or eliminated future trading at that firm.
The research that Oak Ridge receives from brokerage firms for the benefit of our clients includes
invitations to industry conferences, newsletters, access to analysts, one-on-one meetings with
company management, and other related items. Oak Ridge also uses some client commissions to
pay for research services provided by third-party providers, including in-depth, industry-specific
research. However, use of commissions is limited to research services.
Certain very limited execution services for Oak Ridge trades for clients may effectively be provided
to Oak Ridge due to client trading. For example, this could include software that provides direct
access to a broker’s trading desk for quicker and easier order entry and/or trade allocation which
can help execution speed and communication. Compensating firms for the value of these services
may cause clients to pay more for actual trade execution than they would otherwise, but
commissions will generally be within a competitive range for the type of transaction being
completed and Oak Ridge believes this is helpful in more effectively completing orders.
Brokerage firms that provide soft dollar services are regularly reviewed by Oak Ridge. The Chief
Investment Officer, Head Trader and members of the Investment Team evaluate, among other
things, the execution services received, the quality of the research related services provided, the
breadth of coverage relative to Oak Ridge’s holdings, and responsiveness to our calls. The third-
party vendors are also reviewed for the value of the research services procured for the benefit of
our clients relative to the commissions that are used to pay for them. Allocation targets for each
brokerage firm and third-party vendor are determined based on these inputs.
Oak Ridge also compensates brokerage firms for research through commission sharing
arrangements. In those cases, Oak Ridge does not trade directly with a research firm but will use
another firm to execute trades and that executing firm will use commissions to compensate the
research firms.
Item 13 Review of Accounts
Internal Account Reviews
Oak Ridge employees are primarily focused on performing research, portfolio management and
trading. Oak Ridge receives some operational support from SEI, a third-party provider. All
investment/trading determinations are made by Oak Ridge investment/trading personnel. Accounts
are reviewed regularly on a formal basis and periodically on an ad hoc basis. SEI reconciles accounts
with custodial records and reviews cash levels on behalf of Oak Ridge, per Oak Ridge standards.
For most accounts, reconciliation is done on a daily basis. If daily download information is not
available, the reconciliation will occur at least monthly. Oak Ridge’s investment team meets
formally at least weekly to discuss portfolio holdings and product sector weightings. Informal
meetings occur on a more frequent basis. Dispersion of account performance for accounts within
each product is examined at least quarterly. Outlier accounts are identified and the reasons for
dispersion are investigated.
Client Reporting
For clients with an investment advisory agreement directly with Oak Ridge, we send out quarterly
reports which include a market commentary and portfolio performance summary. Clients may opt
out of receiving statements and/or commentary letters from us by making a written request either
directly or through their consultant/broker. In addition, and as their primary source of reporting, all
clients receive statements usually monthly but at least quarterly from their custodians with details
on transactions. Sponsored Program clients will also be provided with additional information about
Oak Ridge’s performance and holdings from the Program Sponsor.
Item 14 Client Referrals and Other Compensation
Oak Ridge reserves the right to engage and compensate firms or individuals to provide certain
marketing services to Oak Ridge. Such activities can be considered to be providing an
“endorsement” of Oak Ridge’s advisory services. Although Oak Ridge has entered into such
arrangements in the past, no such arrangements are active at this time.
Item 15
Custody
Although Oak Ridge does not take physical possession of client funds or securities, Oak Ridge is
deemed to have custody of some client assets under the SEC’s Custody Rule only because it deducts
fees from certain client accounts, as described below. Oak Ridge provides investment management
services only and the physical safekeeping of client assets is performed by qualified custodians (i.e.,
regulated financial institutions including banks and broker dealers).
Advisory Fees
For some accounts, Oak Ridge sends an invoice for investment advisory services directly to the
qualified custodian or provides notice to the custodian to debit the account for fee payments. In
those cases, Oak Ridge is likely deemed to have custody because the client does not specifically
direct the payment of the invoices each time, although they provide authority to Oak Ridge and their
custodian to perform this task. Usually monthly, but at least quarterly, the custodian sends
statements to the client which show, among other things, the advisory fees paid to Oak Ridge. We
encourage our clients to review those statements and, if they also receive statements directly from
us, to compare the account statements that they receive.
In addition, for some of our clients we are authorized to deduct our quarterly investment
management fees directly from those clients’ accounts. For this reason alone, this is considered to
be custody of those clients’ assets since we have been given the authority and ability to remove fees
from the accounts. We have procedures to monitor that we only remove the fees owed to us from
those clients’ accounts. As stated above, if we have that ability to remove fees from your account,
you should carefully review your statements to monitor that the fee amount we remove is correct
and especially that we do not remove more than the fees due us.
Service as Trustee/Executor
In certain instances, an Oak Ridge employee may serve as the trustee of a trust or executor of an
estate for whom we provide advisory services. In order to avoid being deemed to have custody, we
limit these situations to those where the employee had a pre-existing relationship (long-time friend
or family member) with the decedent, trust grantor or beneficiary. All new relationships of this type
are reviewed by Compliance.
Item 16
Investment Discretion
We accept discretionary authority to manage separately managed accounts which is generally
granted in the investment advisory agreement and allows Oak Ridge to determine the identity and
amount of the securities to be bought or sold in accordance with each client’s investment objectives.
For some Sponsored Programs, discretionary authority is granted to the Sponsor who then delegates
that authority to Oak Ridge for certain accounts.
As part of our account evaluation and acceptance process, we review any proposed account
restrictions desired by the client for the account. Each client has the ability to request in writing that
we adhere to certain restrictions and Oak Ridge will review those to determine if they can be
implemented effectively. Client-imposed restrictions may affect the ability to manage according to
the stated investment strategy, achieve the stated investment goals and may cause deviation from
other accounts managed in the same strategy. If the Firm determines that based on the nature or the
extent of the requested restrictions we cannot effectively implement those restrictions or that the
client would not receive sufficient value due to the restrictions, we decline to manage the account.
We will also work with clients on restrictions if the client desires their account be managed in a
socially responsible way, as the client may want to define that. Oak Ridge will also provide input
on managing an account, if requested, in accordance with environmental, social and governance
standards (“ESG”) as the client may want to define or design that.
For a portion of our advisory business we provide investment advisory services to certain UMAs
managed by broker-dealers or other investment advisers that use in part stock selection information
provided by Oak Ridge via a model. We provide the information on our stock selections to the UMA
firms as necessary, but usually we are not responsible for deciding whether to implement trades or
all of the trades for these accounts and as such these are not considered managed on a discretionary
basis. The decision on whether and to what extent to use the information provided by Oak Ridge is
left, in varying degrees, to the brokerage/advisory firms. Certain UMA firms will evaluate all of a
client’s accounts in their program, including that account or portion of an account using our model
information, in determining whether to implement changes suggested by us. We are not the Sponsor
of any UMA accounts and the terms of those accounts, including the fees charged to clients by the
Sponsors of those accounts, are not determined by us. You should consult with your advisors about
any UMA program terms that apply to your account.
Item 17
Voting Client Securities
Oak Ridge will accept responsibility to vote proxies for securities which are held in client accounts
which we manage when our clients direct us to do so. Our authority to vote proxies is established
in our investment advisory agreement or the agreement completed with a Program Sponsor. Oak
Ridge will vote alike for all shares of a company held by client accounts. We will not accept
direction from clients on specific votes except in extraordinary circumstances.
We have adopted policies and procedures designed to help us vote in what we believe are our clients’
best interests with a focus on maximizing the economic benefit of owning the shares. Our basic
policies and procedures for administering proxy voting are summarized below and a copy of our
proxy voting policies and procedures is available by contacting us.
We currently use the input of an outside voting advisory service which provides information on
proxy ballot issues. While that service provides us with analysis and advice, we make our own
voting decisions based upon our voting policies and procedures.
We consider the quality of a company’s management to be an important factor in our decision to
invest and stay invested in a company. Therefore, we typically vote with company management for
routine proposals that do not change the company’s structure, bylaws, or operations in a way we
believe is detrimental to shareholders. For Board membership, we will usually vote for individuals
nominated in an uncontested election unless we are concerned about issues that would impede the
Board member's ability to perform effectively, such as unusual conflicts of interest or membership
on too many boards.
We typically vote against proposals we believe restrict shareholders' ability to realize the full
potential financial value of their stock investment. These include poison pills, supermajority voting
requirements, and classified boards. For non-routine matters we evaluate the issues on a case-by-
case basis using the same economic focus described above.
A conflict of interest may arise where Oak Ridge has discretion to vote proxies for a company that
in an uncommon situation has a material business relationship with us or our employees. For matters
that are covered by our policies, we will generally vote according to those policies.
If the policies do not clearly inform our vote, we may:
• choose to vote the proxy in accordance with the voting recommendation of a
nonaffiliated third party, such as our outside advisory service,
• accept direction from the client(s) or a fiduciary of the client(s), or
• abstain from voting.
The method we select will depend upon the facts and circumstances of each situation and the
requirements of applicable law.
We will not vote proxies in certain situations where we determine that the cost of voting a particular
proxy exceeds any anticipated benefit to the client or in the event where the exercise of voting rights
could restrict the ability of the portfolio manager to freely trade the security. Oak Ridge will not
vote proxies for holdings in client accounts which were not purchased based on the firm’s
discretionary authority.
Information on how we voted proxies for client accounts is available upon request.
Class Actions
From time to time, Oak Ridge may receive notice of class action suits involving securities held or
previously held in client accounts. The Firm does not take any action or provide any legal advice
related to these matters. Upon client request, we may be able to assist in providing transaction or
holding information necessary for another party to respond to these notices.
Item 18
Financial Information
Oak Ridge believes it does not have any financial commitments, policies or impairments that require
disclosure in response to this item.
FACTS
WHAT DOES OAK RIDGE INVESTMENTS, LLC (“OAK RIDGE”)
DO WITH YOUR PERSONAL INFORMATION?
WHY?
Financial companies choose how they share your personal information. Applicable U.S.
federal law gives consumers the right to limit some but not all sharing. U.S. federal law
also requires us to tell you how we collect, share, and protect your personal
information. Please read this notice carefully to understand what we do.
The types of personal information we collect and share depend on the product or
service you have with us. The information can include:
Social Security Number
Income
WHAT?
Account balances
Account transactions
Transaction history
Investment experience
HOW?
All financial companies need to share customers' personal information to run the
everyday business. In the section below, we list the reasons financial companies can
share their customers’ personal information; the reasons Oak Ridge Investments, LLC
(“Oak Ridge”) chooses to share; and whether you can limit this sharing.
Does Oak Ridge
share?
Can you limit this
sharing?
Yes
No
Reasons we can share your personal
information
For everyday business purposes:
such as to process your transactions, maintain your
account(s), respond to court orders and legal
investigations, or report to credit bureaus
For marketing purposes:
to offer our products and services to you
Yes
No
For joint marketing with other financial companies
Yes
No
For affiliates' everyday business purposes:
information about transaction(s) and experiences
No
We don’t share
For affiliates' everyday business purposes:
information about your creditworthiness
No
We don’t share
For our affiliates to market to you:
No
We don’t share
For non-affiliates to market to you:
No
We don’t share
Call 312-857-1040 or go to www.oakridgeinvest.com
To limit our
sharing
Please note: If you are a new customer, we can begin sharing your information 30 days
from the date we sent this notice. When you are no longer our customer, we continue to
share your information as described in this notice.
However, you can contact us any time to limit our sharing.
Call 312-857-1040 or go to www.oakridgeinvest.com
QUESTIONS?
WHO WE ARE
Who is providing this notice?
OAK RIDGE INVESTMENTS, LLC
WHAT WE DO
How does Oak Ridge protect my
personal information?
To protect your personal information from unauthorized access and
use, we use security measures that comply with U.S. federal law.
These measures include computer safeguards and secured files and
buildings.
We collect your personal information, for example, when you
How does Oak Ridge collect my
personal information?
Seek financial or tax advice
Seek advice about your investments
Provide account information
Deposit money
Enter into an advisory contract
Why can't I limit all sharing?
We also collect your personal information from others, such as credit
bureaus, affiliates, or other companies.
U.S. federal law gives you the right to limit only:
sharing for affiliates everyday business purposes - information
about your creditworthiness
affiliates from using your information to market to you
sharing for non-affiliates to market to you
State laws and individual companies may give you additional rights to
limit sharing. In order to provide you with the services for which you
have engaged Oak Ridge, the company relies on a number of third
parties which provide support services, including professional, legal,
accounting and technical support.
Your choices will apply to everyone on your account – unless you tell
us otherwise.
What happens when I limit sharing
for an account I hold jointly with
someone else?
DEFINITIONS
Affiliates
Companies related by common ownership or control. They can be financial or
nonfinancial companies.
Oak Ridge has no such affiliates.
Non-Affiliates
Companies not related by common ownership or control. They can be financial or
nonfinancial companies
Oak Ridge has no such affiliates.
Joint Marketing
A formal agreement between non-affiliated companies that together market financial
products or services to you
Oak Ridge does not have joint marketing partners.
OTHER INFORMATION
This notice replaces all previous notices of our consumer privacy policy, and may be amended from time to
time. Oak Ridge will inform you of updates or changes as required by law.
December 2025
David M. Klaskin
Chief Executive Officer, Chief Investment Officer
Oak Ridge Investments, LLC
10 South LaSalle St., Suite 2130
Chicago, Illinois 60603
312-857-1040
This brochure supplement provides information about David M. Klaskin that supplements the Oak
Ridge Investments, LLC brochure. You should have received a copy of that brochure. Please contact
the Oak Ridge Compliance Department using the above contact information if you did not receive
Oak Ridge’s brochure or if you have any questions about the contents of this supplement.
information about Mr. Klaskin
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Business Experience: Mr. Klaskin founded the Firm in 1989 and has served as Chief Executive
Officer, Chief Investment Officer and Board member of Oak Ridge. He also served as Chairman
from March 2005 through September 2013. He is the senior portfolio manager for the Firm’s
Small/Mid Cap Growth, Large Cap Growth and Dividend Growth strategies.
Year of birth: 1960
Education: Indiana University, B.S.
Item 3 – Disciplinary Information
Oak Ridge is required to disclose all material facts regarding certain legal or disciplinary events
that are material to an evaluation of Mr. Klaskin. There are no legal or disciplinary events to
disclose.
Item 4 – Other Business Activities
Oak Ridge is required to disclose Mr. Klaskin’s other investment-related business activities and other
outside business that is substantial. There are no other business activities to disclose.
Item 5 – Additional Compensation
Mr. Klaskin does not receive any compensation based on sales, client referrals or new accounts.
Nevertheless, as an owner of Oak Ridge, Mr. Klaskin receives an economic benefit based on the
overall profitability of the Firm which is indirectly related to sales.
Item 6 – Supervision
As Chief Investment Officer, Mr. Klaskin has supervisory responsibility for the Firm’s investment
process.
December 2025
Robert G. McVicker
Executive Vice President and Senior Portfolio Manager
Oak Ridge Investments, LLC
10 South LaSalle St., Suite 2130
Chicago, Illinois 60603
312-857-1040
This brochure supplement provides information about Robert G. McVicker that supplements the
Oak Ridge Investments, LLC brochure. You should have received a copy of that brochure. Please
contact the Oak Ridge Compliance Department using the above contact information if you did not
receive Oak Ridge’s brochure or if you have any questions about the contents of this supplement.
information about Mr. McVicker
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Business Experience: Mr. McVicker has been employed by Oak Ridge since its founding in 1989.
He is the senior portfolio manager for the All Cap Growth strategy and is a portfolio manager of
the Small/Mid Cap Growth and Large Cap Growth strategies.
Year of birth: 1965
Education: Ohio State University, B.S.
Item 3 – Disciplinary Information
Oak Ridge is required to disclose all material facts regarding certain legal or disciplinary events
that are material to an evaluation of Mr. McVicker. There are no legal or disciplinary events to
disclose.
Item 4 – Other Business Activities
Oak Ridge is required to disclose Mr. McVicker’s other investment-related business activities and
other outside business that is substantial. There are no other business activities to disclose.
Item 5 – Additional Compensation
Mr. McVicker does not receive any compensation based on sales, client referrals or new accounts.
Nevertheless, as an owner of Oak Ridge, Mr. McVicker receives an economic benefit based on the
overall profitability of the Firm which is indirectly related to sales.
Item 6 – Supervision
Mr. McVicker’s investment advice is supervised by David M. Klaskin, Chief Investment Officer of
Oak Ridge. Mr. Klaskin can be reached at 312-857-1040.
December 2025
Kenneth S. Kailin, CFA
Executive Vice President, Senior Portfolio Manager
Oak Ridge Investments, LLC
10 South LaSalle St., Suite 2130
Chicago, Illinois 60603
312-857-1040
This brochure supplement provides information about Kenneth S. Kailin that supplements the Oak
Ridge Investments, LLC brochure. You should have received a copy of that brochure. Please contact
the Oak Ridge Compliance Department using the above contact information if you did not receive
Oak Ridge’s brochure or if you have any questions about the contents of this supplement.
Item 2 – Educational Background and Business Experience
Business Experience: Mr. Kailin has been employed by Oak Ridge since 2002. Prior to that, he
was a partner and portfolio manager at Skyline Asset Management. He is the senior portfolio
manager for the Mid Cap Growth strategy. Mr. Kailin served as the Chief Compliance Officer of
Oak Ridge Investments, LLC from March 2019 to March 2021.
Year of birth: 1958
Education: Indiana University, B.S.
University of Chicago, MBA
Professional Designations: The Chartered Financial Analyst (CFA) charter is a graduate-level
investment credential established in 1962 and awarded by the CFA Institute. To earn the CFA
charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years
of qualified professional investment experience; 3) join CFA Institute as a member; and 4) commit
to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards
of Professional Conduct.
Item 3 – Disciplinary Information
Oak Ridge is required to disclose all material facts regarding certain legal or disciplinary events
that are material to an evaluation of Mr. Kailin. There are no legal or disciplinary events to disclose.
Item 4 – Other Business Activities
Oak Ridge is required to disclose Mr. Kailin’s other investment-related business activities and other
outside business that is substantial. There are no other business activities to disclose.
Item 5 – Additional Compensation
Mr. Kailin does not receive any compensation based on sales, client referrals or new accounts.
Nevertheless, as an owner of Oak Ridge, Mr. Kailin receives an economic benefit based on the
overall profitability of the Firm which is indirectly related to sales.
Item 6 – Supervision
Mr. Kailin’s investment advice is supervised by David M. Klaskin, Chief Investment Officer of Oak
Ridge. Mr. Klaskin can be reached at 312-857-1040.
December 2025
Brian L. King, CFA
Vice President, Research Analyst and
Portfolio Manager
Oak Ridge Investments, LLC
10 South LaSalle St., Suite 2130
Chicago, Illinois 60603
312-857-1040
This brochure supplement provides information about Brian L. King that supplements the Oak
Ridge Investments, LLC brochure. You should have received a copy of that brochure. Please contact
the Oak Ridge Compliance Department using the above contact information if you did not receive
Oak Ridge’s brochure or if you have any questions about the contents of this supplement.
Item 2 – Educational Background and Business Experience
Business Experience: Mr. King has been employed by Oak Ridge since 2006 and is a member of
the investment team. Prior to that, he worked for three years at Timeless Investment Management
and served as a Lieutenant in the U.S. Navy. He is a portfolio manager of the Mid Cap Growth
portfolio and the Dividend Growth portfolio.
Year of birth: 1972
Education: United States Naval Academy, BS University of Michigan, MBA
Professional Designations: The Chartered Financial Analyst (CFA) charter is a graduate-level
investment credential established in 1962 and awarded by the CFA Institute. To earn the CFA
charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years
of qualified professional investment experience; 3) join CFA Institute as a member; and 4) commit
to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards
of Professional Conduct.
Item 3 – Disciplinary Information
Oak Ridge is required to disclose all material facts regarding certain legal or disciplinary events
that are material to an evaluation of Mr. King. There are no legal or disciplinary events to disclose.
Item 4 – Other Business Activities
Oak Ridge is required to disclose Mr. King’s other investment-related business activities and other
outside business that is substantial. There are no other business activities to disclose.
Item 5 – Additional Compensation
Mr. King does not receive any compensation based on sales, client referrals or new accounts.
Nevertheless, as an owner of Oak Ridge, Mr. King receives an economic benefit based on the overall
profitability of the Firm which is indirectly related to sales.
Item 6 – Supervision
Mr. King’s investment advice is supervised by David M. Klaskin, Chief Investment Officer of Oak
Ridge. Mr. Klaskin can be reached at 312-857-1040.