Jorge Rodrigo, CFA, is a portfolio manager for Ephesus Securities. Rodrigo maintains records that support his decisions to buy or sell a security. He also maintains records on reviews undertaken which do not lead to a change in his investment positions. Rodrigo maintains all records only in hard copy, for a period of five years. With regard to record retention, Ephesus has no relevant policy and there is no applicable law.

Are Rodrigo's actions consistent with the Standard relating to record retention?