Cooke & Bieler, L.P. claims compliance with the Global Investment Performance Standards (GIPS®) and has prepared and presented this report in compliance with the GIPS standards. Cooke & Bieler has been independently verified for the periods January 1, 1993 through December 31, 2013.  
Verification assesses whether (1) the firm has complied with all the composite construction requirements of the GIPS standards on a firm-wide basis and (2) the firm’s policies and procedures are designed to calculate and present performance in compliance with the GIPS standards. Verification does not ensure the accuracy of any specific composite presentation. The All Cap Value Equity Composite has been examined for the periods from May 1, 2001 through December 31, 2013. The verification and examination reports are available upon request.

The Firm is defined as Cooke & Bieler, L.P., an independent investment management firm, and is registered as an investment adviser under the Investment Advisers Act of 1940.  Registration does not imply a certain level of skill or training.

The Cooke & Bieler All Cap Value Equity Composite (Composite) currently includes all fully discretionary, fee paying and non-fee paying all cap value equity portfolios managed for more than one month. During 2012, the minimum market value for inclusion in the composite was $1 million.  Prior to 2012, the minimum market value for inclusion was $2,500. For investment purposes, all cap investing is generally defined as investing in securities of companies whose market capitalization is within the range of the Russell 3000® Index at time of purchase. The Composite was created in May 2001. All Cap portfolio holdings are chosen from securities held in the firm’s large, mid and small cap portfolios.  The investment team regularly reviews these portfolios to determine which securities are to be held in the All Cap portfolio. Typically, those stocks that have higher portfolio weights in the large, mid and small cap portfolios represent a substantial portion of the All Cap portfolio. As part of the inclusion process, the investment team also considers the impact a security has on the portfolio’s sector and market cap diversification profile. Portfolios are more concentrated, typically holding approximately 40-50 securities. 

Rates of return are expressed in U.S. dollars. Portfolios are valued monthly on a trade date basis. Portfolio returns reflect the reinvestment of dividend and interest income and are calculated using the Modified Dietz method. Composite returns are calculated monthly by weighting portfolio returns according to the size of each portfolio at the beginning of the month.  

Performance returns are presented both gross and net of fees. Gross of fee returns do not reflect the deduction of investment advisory fees.  Individual client returns will be reduced by investment advisory fees and other expenses that it may incur in the management of its investment advisory account.
The investment advisory fees are described in Part 2A of Form ADV. The standard fee agreement currently in effect is 0.75 of 1% per annum on the first $10 million of principal, 0.65 of 1% per annum on the next $10 million of principal, 0.55 of 1% per annum on the balance, however fees are negotiable. Net returns are net of model investment advisory fees in effect for the respective time period and are derived using the maximum fixed fee rate.   As an example, the “cost” of the investment advisory fee of a $10 million portfolio is .75% on an annualized basis.  In a ten-year period, the effect of the investment advisory fee will reduce a 5% annual return by as much as 11.8% on a cumulative basis. On an exception basis, the actual fee charged may depend on the asset size, client location and type of portfolio.  

The dispersion is measured using an asset weighted standard deviation of portfolio returns represented within the Composite for the full year.  For those annual periods with less than five portfolios included for the entire period, dispersion is not presented as it is not considered meaningful. A list of composite descriptions is available upon request. Policies for valuing portfolios, calculating performance, and preparing compliant presentations are also available upon request.

For comparison purposes, the composite is measured against the Russell 3000® Value Index. The index returns are provided to represent the investment environment existing during the time periods  shown and are not covered by the report of independent verifiers. Each index is fully invested and includes the reinvestment of income. The returns for each index do not include any transaction costs, management fees, or other costs. Russell Investment Group is the source and owner of the trademarks, service marks and copyrights related to the Russell Indexes. Russell® is a trademark of Russell Investment Group. 

The three-year annualized ex-post standard deviation measures the variability of the composite (using gross returns) and the benchmark for the preceding 36-month period. The three-year annualized ex-post standard deviation is not required to be presented for periods prior to 2011 or when 36 monthly composite returns are not available. Past performance is not indicative of future results.