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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.
March 26, 2025
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Item 2
Material Changes
We have not made any material changes to this brochure, dated March 26, 2025, since our last
brochure dated October 10, 2024.
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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 ............................................................... 14
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 ................................................................................................................ 19
Item 14 Client Referrals and Other Compensation .............................................................................. 19
Item 15 Custody ................................................................................................................................... 20
Item 16
Investment Discretion ............................................................................................................. 20
Item 17 Voting Client Securities .......................................................................................................... 21
Item 18 Financial Information ............................................................................................................. 23
Additional Information – Privacy Notice ................................................................................................. 24
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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, owns slightly less than 40%
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
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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.
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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
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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
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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.
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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.
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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
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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
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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
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laws, regulatory fines, penalties, financial
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
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.
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Item 10
Other Financial Industry Activities and Affiliations
Oak Ridge has relationships and arrangements with other financial industry entities that could
create a conflict of interest or are material to Oak Ridge’s business.
North Square Investments, LLC (“NSI”)
Certain former employees of Oak Ridge joined a new investment advisory company in 2018,
NSI. NSI employees provide certain marketing services to Oak Ridge.
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
14
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
15
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.
16
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
17
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.
18
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 may pay NSI to solicit business for Oak Ridge. NSI currently provides some
marketing services for Oak Ridge, including non-exclusive sales representation for its current
SMA products and services. NSI is paid by Oak Ridge for sales of these Oak Ridge strategies,
governed by a solicitation agreement.
NSI employees provide certain marketing services to Oak Ridge. Under a services agreement,
NSI carries out activities with respect to Oak Ridge’s marketing and advertising
communications efforts. Under Rule 206(4)-1 of the Advisers Act, NSI is considered to be
providing an “endorsement” of Oak Ridge’s advisory services in providing these
communications. NSI is not a client of Oak Ridge. Due to NSI’s indirect minority ownership
interest in Oak Ridge, NSI has a financial incentive to promote Oak Ridge’s services. Any
financial incentive creates a conflict of interest. NSI’s communications should be considered in
light of this and may not be representative of others’ experience with Oak Ridge.
19
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.
20
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.
21
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.
22
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.
23
Additional Information – Privacy Notice
FACTS
WHAT DOES Oak Ridge Investments, LLC
DO WITH YOUR PERSONAL INFORMATION?
WHY?
Financial companies choose how they share your personal information. Federal law
gives consumers the right to limit some but not all sharing. 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. This information can include:
WHAT?
Investment experience and transaction history
Social Security number and income
Account balances and account transactions
When you are no longer our customer, we continue to share your information as
described in this notice.
How?
All financial companies need to share customers' personal information to run their
everyday business. In the section below, we list the reasons financial companies can
share their customers' personal information; the reasons Oak Ridge Investments,
LLC chooses to share; and whether you can limit this sharing.
Does Oak Ridge
Investments share?
Can you limit
this sharing?
Reasons we can share your personal information
Yes
No
For our 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
Yes
No
For our marketing purposes – to offer our products
and services to you
Yes
No
Joint marketing with unrelated financial companies
N/A
N/A
For our affiliates' everyday business purposes –
information about your transactions and experiences
N/A
N/A
For our affiliates' everyday business purposes –
information about your creditworthiness
No
No
For non-affiliates to market to you
or go to www.oakridgeinvest.com
Questions? Call 312-857-1040
24
Page 2
What we do
does Oak Ridge
protect my
How
Investments
personal information?
To protect your personal information from unauthorized access and
use, we use security measures that comply with federal law. These
measures include computer safeguards and secured files and
buildings.
We collect your personal information, for example, when you
Seek financial or tax advice or seek advice about your
does Oak Ridge
collect my
investments
How
Investments
personal information?
Provide account information or make deposits
Enter into an investment advisory contract
Federal law aw gives you the right to limit only:
Why can't I limit all sharing?
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.
Definitions
Companies related by common ownership or active control. They
can be financial and nonfinancial companies.
Affiliates
Oak Ridge Investments has no such affiliates.
Companies not related by common ownership or control. They can
be financial and nonfinancial companies.
Non-affiliates
Oak Ridge Investments, LLC currently only shares with
a company named North Square Investments, LLC
which is a minority owner of Oak Ridge Investments,
LLC. Otherwise, Oak Ridge does not share with non-
affiliates so they can market to you.
A formal agreement between nonaffiliated financial companies that
together market financial products or services to you.
Joint marketing
Oak Ridge Investments, LLC may jointly market with
North Square Investments, LLC.
March 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.
March 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.
March 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.
March 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.