Employee Social Media Policy

We have established guidelines for DCM Advisors, LLC (DCM) employees regarding social media in the electronic world. Although employees may maintain individual pages on social media sites to connect with friends and family, your responsibility to DCM doesn’t end when you leave the office. For that reason, this Social Media policy applies to both company sponsored social media and personal use as it relates to DCM. DCM employees should recognize that they are personally responsible for the content they publish on social media sites. DCM employees can be disciplined for commentary, content or images that are defamatory, pornographic, proprietary, harassing, libelous or that can create a hostile work environment.

What You Should Do:

  • Disclose Your Social Media Pages: Upon employment with DCM and annually thereafter, you must provide a list of all personal and outside business social media sites in use. Following the initial attestation and between annual attestations, you must notify the CCO immediately upon the establishment of a new personal social media site and must request pre-approval for any social media site relating to an outside business.
  • Do Not Set Up any Company-related Social Media Pages: Any company-related social media page many only be established at the direction and authority of DCM.
  • Disclose Your Affiliation: If you talk about DCM related matters that are within your area of job responsibility you must disclose your affiliation with DCM. Postings that mention DCM should add value and promote the positive community image of DCM at all times.
  • State That It’s YOUR Opinion: Unless authorized to speak on behalf of DCM, you must state that the views expressed are your own.
  • Do Not Post Content that Could be Considered a Testimonial: Testimonials are expressly forbidden by the Investment Advisers Act of 1940, as amended, and the rules thereunder. Accordingly, no recommendations, endorsements or “likes” may be accepted on any social media site (whether personal or DCM-related). Likewise, you are prohibited from endorsing, recommending, “liking” or otherwise actively supporting third-party business-related social media users on behalf of DCM without pre-approval by the CCO (or designee).
  • Protect Yourself: Be careful about what personal information you share online. Be mindful that what you publish will be public for a long time.
  • Act Responsibly and Ethically: When participating in online communities, do not misrepresent yourself.
  • Your Personal Information must Comply with the DCM Code of Ethics. Any personal employee information must abide by the DCM values and employee conduct expectations, as found in the DCM Code of Ethics, whether or not you identify yourself online as a DCM employee.
  • Honor Our Differences: DCM does not tolerate discrimination (including age, sex, race, color, creed, religion, ethnicity, sexual orientation, gender identity, national origin, citizenship, disability, or marital status or any other legally recognized protected basis under federal, state, or local laws, regulations or ordinances).
  • DCM Social Media Content Is Subject to Recordkeeping: DCM-related social media content is subject to recordkeeping requirements. All changes and updates to DCM-related social media sites must be maintained for the required amount of time (minimum of five (5) years.)

What You Should Never Disclose about DCM:

  • The Numbers: You should never disclose non-public financial or operational information about DCM.
  • Personal Information: Never share personal information about our customers or employees, including past, present or future employees, clients, vendors or other persons conducting business with DCM.
  • Legal Information: Never disclose anything to do with a legal issue, legal case, or attorneys without first checking with legal.
  • Confidential Information: Do not publish, post, or release information that is considered confidential.

Basically, if you find yourself wondering if you can talk about something you learned at work – don’t.

The CCO (or a designee) will conduct periodic spot checks of employee personal social media pages to ensure compliance with this Social Media policy.

Here is what could happen if you violate the DCM Social Media Policy. You could:

• Lose your job
• Get DCM in legal trouble with customers, vendors or regulatory authorities
• Cost us the ability to get and keep customers

Please ensure you comply with DCM’s Social Media Policy. Should you have any questions, please ask the DCM General Counsel or Chief Compliance Officer.