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the overall portfolio's investment return, provided adequate diversification has been <br /> implemented. <br /> DELEGATION OF AUTHORITY: In accordance with Minnesota Statutes Chapter <br /> 118A,the responsibility for conducting investment transactions resides with the treasurer. <br /> Management responsibility for the investment program is hereby delegated to the <br /> treasurer and assistant finance director (hereafter referred to as investment officers), who <br /> are authorized to make investments of public funds. No person may engage in an <br /> investment transaction except as provided under the terms of this policy. <br /> PRUDENCE: Investments shall be made with judgement and care, under circumstances <br /> then prevailing, which persons of prudence, discretion and intelligence exercise in the <br /> management of their own affairs, not for speculation, but for investment, considering the <br /> probable safety of their capital as well as the probable income to be derived. <br /> The investment officers, acting in accordance with this investment policy and exercising <br /> due diligence shall be relieved of personal responsibility for an individual security's <br /> credit risk or market price changes, provided deviations from expectations are reported in <br /> a timely fashion and that appropriate action is taken to control adverse developments. <br /> ETHICS AND CONFLICT OF INTEREST: Investment officers shall refrain from <br /> personal business activity that could conflict with the proper execution and management <br /> of the investment program, or that could impair their ability to make impartial decisions. <br /> Investment officials shall disclose any material interest in financial institutions with40 <br /> which they conduct business. Investment officers shall refrain from undertaking personal <br /> investment transactions with the same individual with whom business is conducted on <br /> behalf of the City. <br /> INTERNAL CONTROL: The investment officers are responsible for establishing and <br /> maintaining an internal control structure designed to ensure that the assets of the City are <br /> protected from loss, theft or misuse. The internal control structure shall be designed to <br /> provide reasonable assurance that these objectives are met. The concept or reasonable <br /> assurance recognizes that (1) the cost of a control should not exceed the benefits likely to <br /> be derived and (2) the valuation of cost and benefits, requires estimates and judgements <br /> by management. <br /> Accordingly, the investment officers shall establish a process for an annual independent <br /> review by an external auditor to assure compliance with policies and procedures. The <br /> internal controls shall address the following points: <br /> • Control of collusion <br /> • Separation of transaction authority from accounting and record-keeping <br /> • Custodial safekeeping <br /> • Avoidance of physical delivery securities <br /> • Written confirmation of transactions for investments and wire transfers <br /> • Documentation of transactions • <br />