Diamond Hill Investment Group, Inc.
        Compensation Recoupment and Restitution Policy

                  Adopted February 13, 2013

       This Compensation Recoupment and Restitution Policy (this "Policy")
of Diamond Hill Investment Group, Inc., an Ohio corporation (the "Company"),
and its affiliates (collectively, "Diamond Hill") provides for the recoupment
or restitution by the Company, under certain circumstances, of annual cash
bonuses, stock-based awards, performance-based compensation, and any other
forms of cash or equity compensation other than salary ("Awards").  This
Policy applies to (i) all of Diamond Hill's current employees and (ii)
all former employees who were employed by Diamond Hill during any
"Adjustment Period" (as defined below), except to the extent that an Award
agreement, Award statement or terms and conditions relating to any Award
expressly provides that this Policy does not apply.

       Compensation Recoupment and Restitution.  If (i) the Company's
previously issued financial statements are restated as a result of error,
omission, fraud or non-compliance with financial reporting requirements or
(ii) there has been an erroneous calculation of the Company's incentive
compensation pool from which Awards are made for any period (either (i) or
(ii) is referred to as an "Adjustment Event"), the Compensation Committee
of the Company's Board of Directors will review the facts and circumstances
underlying the Adjustment Event.  The Compensation Committee will make a
recommendation to the Company's Board of Directors as to whether the Company
should recover all or a portion of an Award (or multiple Awards) from, or
otherwise adjust an Award to, one or more employees (or former employees)
with respect to an "Adjustment Period" in which the Company's financial
results are affected by an Adjustment Event.  An "Adjustment Period" is the
three-year period ending on the date that the Company (i) is required to
prepare an accounting restatement or (ii) identified the erroneous
calculation of the incentive compensation pool, as applicable.

       If (i) any Award(s) was paid, granted or vested based upon the
achievement of financial results that are subsequently restated or based
on the improper calculation of the incentive compensation pool, or (ii) a
lower payment, Award value or vesting amount would have occurred based upon
the restated financial results or the proper calculation of incentive
compensation pool, the Company may seek to recoup, and any such employee
(or former employee) will forfeit or repay, all or any portion of such excess
compensation as the Board of Directors deems appropriate.  Recoupment under
this Policy may include, but is not limited to, reimbursement by the employee
of the amount of cash bonuses received, cancellation or forfeiture of
outstanding stock-based compensation or Awards, the payment to the Company
of stock sale proceeds and the surrender of shares of the Company, and the
manner of recoupment will be determined by the Board of Directors in its
discretion.  To the extent not inconsistent with applicable law regarding
extensions of credit by the Company under the Sarbanes-Oxley Act of 2002 or
any other applicable law, the Board of Directors may determine the period of
time and method for repayment of the designated amount.

       If (i) any Award(s) would have been paid, granted or vested or (ii) a
higher payment, Award value or vesting amount would have occurred based on
the restated financial results or the proper calculation of the incentive
compensation pool, the Compensation Committee of the Company's Board of
Directors will review the facts and circumstances underlying the restatement
or improper calculation of the incentive compensation pool.  The Compensation
Committee will make a recommendation to the Company's Board of Directors as
to whether the Company should make appropriate restitution to affected
employees who are then currently employed by the Company.  The Board of
Directors will determine, in its sole discretion, the amount, form and timing
of any such restitution, which will be no more than the difference between
the amount of compensation that was paid or awarded and the amount that would
have been paid or granted based on the actual, restated financial statements
or properly calculated incentive compensation pool.  The Company will not be
obligated to pay to any employee any additional compensation under this
Policy.

       Additional Recoupment for Fraud or Misconduct.  If the Compensation
Committee determines that an employee (i) engaged in an act of fraud or
misconduct that contributed to the need for a financial restatement, or
(ii) violated any law or regulation applicable to the Company or any policy
or procedure of the Company and such violation has adversely impacted the
Company's business or reputation, the Compensation Committee will report such
determination to the Company's Board of Directors.  In such an instance, the
Board of Directors may, in its discretion and in addition to any other
recoupment under this Policy, recover, and the employee will forfeit or repay,
all of the employee's Awards for the relevant period, plus a reasonable rate
of interest.

       Taxes.  Should any repayment obligation under this Policy trigger
income tax penalties to the employee, the employee will be solely liable for
the payment of any such taxes.

       Interpretations of and Changes to the Policy.  This Policy is intended
to be interpreted in a manner consistent with any applicable rules or
regulations adopted by the Securities and Exchange Commission or The NASDAQ
Stock Market and any other applicable law and will be interpreted by the
Board of Directors, whose interpretation of this Policy will be final.  The
Company reserves the right to adopt changes, amendments or interpretations
of this Policy and any such changes, amendments or interpretations will
immediately be applicable to all Awards covered by this Policy from its
initial date of adoption.  This Policy will not apply to the extent that
such application would violate any applicable state law that is not preempted
by federal law.

       Not Exclusive Remedy.  The recoupment of Awards pursuant to this
Policy will not in any way limit or affect the Company's right to pursue
disciplinary action or dismissal, take legal action or pursue any other
available remedies.  This policy does not replace and is in addition to any
rights of the Company to recoup Awards from its employees under applicable
laws and regulations, including but not limited to the Sarbanes-Oxley Act of
2002 and the Dodd-Frank Wall Street Reform and Consumer Protection Act.

       Incorporation of Policy.  Each recipient of an Award from the Company
will execute an acknowledgement providing that any Awards granted to such
recipient on or after the effective date of this Policy are subject to this
Policy.  Additionally, the Company, in its discretion, may incorporate the
requirements of this Policy into any applicable award statement, award
agreement or terms and conditions of any Awards made by the Company following
the adoption of this Policy.