Firm Description
Dodge & Cox provides investment management services to institutions, individuals, mutual funds and other pooled
investment vehicles on a fully discretionary basis, subject to the investment objectives and investment guidelines of
each client. In addition, Dodge & Cox also provides non-discretionary investment management services to clients in
certain circumstances. Established in 1930, Dodge & Cox is an independent organization with ownership limited to
active employees of the firm. No one person is considered a principal owner of the firm.
Advisory Services
Investment management is our only business. Dodge & Cox provides equity, fixed income, and balanced account
management services to our clients. In addition to separately managed accounts, Dodge & Cox manages Dodge &
Cox Funds, an SEC-registered investment company consisting of the following seven series: Dodge & Cox Stock
Fund, Dodge & Cox Global Stock Fund, Dodge & Cox International Stock Fund, Dodge & Cox Emerging Markets
Stock Fund, Dodge & Cox Balanced Fund, Dodge & Cox Income Fund, and Dodge & Cox Global Bond Fund.
Dodge & Cox also serves as investment manager to Dodge & Cox Worldwide Funds plc, an investment company
authorized and regulated by the Central Bank of Ireland pursuant to the European Communities (Undertakings for
Collective Investment in Transferable Securities) Regulations, 2011, as amended. Dodge & Cox Worldwide Funds
plc is an umbrella company offering four sub-funds (the “Dodge & Cox Worldwide Funds”).
Our investment philosophy is built on traditional principles—we conduct our own research, employ a rigorous
price discipline, and maintain a long-term investment horizon. Dodge & Cox follows a disciplined approach to
investing in which investment ideas are considered by investment committees. Investment committee decisions are
generally applied to all eligible fund and separate account clients after taking cash flows, investment guidelines and
restrictions, and other account-specific circumstances into consideration. This process involves establishing target
allocations that are applied across relevant client portfolios.
Please note that Dodge & Cox does not provide financial planning services. Accordingly, Dodge & Cox will
provide investment management services only with respect to the securities, cash, and other investments held in a
client’s account and, in making recommendations with respect to the account, Dodge & Cox will not consider any
other securities, cash, or other investments owned by the client when managing a client’s account except in limited
circumstances where specifically instructed by a client and based on information provided by the client.
Notwithstanding the foregoing, Dodge & Cox has no obligation to monitor investments or changes in accounts not
under Dodge & Cox’s management. In addition, Dodge & Cox does not provide tax, accounting, or legal services or
advice.
Activities Dodge & Cox Does Not Engage In
Dodge & Cox seeks to avoid or limit business practices that create conflicts of interest. For example, Dodge & Cox
does not manage or offer hedge funds, trade with affiliated broker-dealers, use solicitors, pay to participate in wrap
fee programs, or compensate employees on the basis of sales.
Securities Lending
We do not enter into securities lending arrangements with or on behalf of separately managed account clients. To
the extent that a client chooses to enter into a securities lending agreement with a securities lending agent (which
may be its custodian), the client should be aware that Dodge & Cox is not a party to the agreement and that securities
lending presents certain risks, including, but not limited to, delayed settlement, failed delivery, and the inability to
vote proxies or respond to corporate actions in a timely manner, which may hinder Dodge & Cox’s ability to manage
a client’s portfolio effectively. We are not responsible for any losses or expenses caused directly or indirectly by a
client’s securities lending arrangements.
Legal Proceedings
We do not file claims or make decisions on a client’s behalf in legal proceedings (including bankruptcies and class
actions) relating to securities held or formerly held in a separately managed account, or notify clients of any such
proceedings.
Clients should instruct their custodians to forward applicable class action notifications to them. Clients
can then elect to opt-in or opt-out of participating in the class action. Dodge & Cox will forward to the client, its
custodian, or a designated recipient any applicable class action notification and proof-of-claim forms that we receive
only if instructed to do so by the client. In the event a client instructs Dodge & Cox to forward such materials to the
client’s custodian, the client should (i) ensure that the custodian is capable of filing, and has the proper authorization
to file, proofs of claim on the client’s behalf and (ii) determine whether and how to file a request for exclusion from a
particular class action settlement. Dodge & Cox does not give legal advice, including advice concerning participation
in class actions.
Custodians and Broker-Dealers
We do not provide custody services and do not act as a broker-dealer in placing trades for a client’s portfolio. Clients
should obtain statements from their custodians on at least a quarterly basis showing all transactions in the client’s
custodial account during the period and listing assets held in each account as of the end of the period. We are not
responsible for the acts or omissions of any custodian, broker-dealer, securities lending agent, or other third party.
Client Investment Guidelines and Restrictions
We manage portfolios subject to client-imposed investment guidelines and restrictions. Our investment
management services can be tailored to a client’s needs, provided they are clearly stated and not unduly
burdensome or restrictive. See Investment Discretion on
p. 39 for more information. Dodge & Cox Funds and other
commingled vehicles we manage are not subject to an individual investor’s investment restrictions, but are managed
in accordance with their prospectus and governing documents.
ERISA Restrictions
Clients are responsible for informing Dodge & Cox whether the assets in their account are subject to the Employee
Retirement Income Security Act of 1974 (“ERISA”) or any state or local laws that are similar to ERISA. To the extent
a client account is subject to ERISA, the client must inform us of any employer securities the client is not permitted
to own under ERISA. In addition, in order to rely on the class exemption for qualified professional asset managers,
the client must provide us with a list of any relevant “party in interest” as defined in Section 3(14) of ERISA and every
party with the authority to appoint or terminate Dodge & Cox as investment adviser or to negotiate the terms of an
investment management agreement with Dodge & Cox with respect to the account. If an ERISA client has identified
a broker-dealer or other financial counterparty as a “party in interest,” Dodge & Cox will be restricted from
transacting with that broker-dealer or counterparty in its management of the client’s account absent an exemption
under ERISA. An account with a broker-dealer restriction will not be aggregated for execution purposes with orders
for the same securities for other accounts managed by Dodge & Cox if the transaction is effected by the restricted
broker-dealer. In addition, the account may be restricted from participating in new issues or tender offers depending
on whether a broker-dealer or financial industry affiliate plays a role in the transaction and how it is compensated. In
the event that a purchase or sale order is placed for multiple client accounts, orders for accounts giving Dodge &
Cox full brokerage discretion will generally be placed ahead of an account with a broker-dealer restriction. As a
result, it is possible that an account with restricted broker-dealers or counterparties will be subject to higher
commissions, less favorable net prices, and/or less favorable execution than would be the case if there were no
broker-dealer or counterparty restrictions on the account. State laws similar to ERISA impose equivalent conditions
on non-ERISA accounts in certain circumstances. See also Dodge & Cox Brokerage Practices on p. 29 of this
Brochure.
Assets Under Management
As of December 31, 2023, we managed $361,661,401,285.30 on a discretionary basis and $1,331,159,702.08 on a
non-discretionary basis.