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• Investments shall be made with judgment and care under the circumstances then <br /> prevailing,which persons of prudence, discretion and intelligence exercise in the <br /> management of their own affairs,not for speculation,but for investment, considering <br /> the probable safety of their capital as well as the probable income. <br /> B. Ethics and Conflicts of Interest <br /> Officers and employees involved in the investment process shall refrain from <br /> personal business activity that could conflict with the proper execution and <br /> management of the investment program, or that could impair their ability to make <br /> impartial decisions. All investment officials shall disclose any material interests in <br /> financial institutions with which they conduct business. Employees and officers shall <br /> refrain from undertaking personal investment transactions with the same individual <br /> with whom business is conducted on behalf of the City. <br /> IV. AUTHORITY AND RESPONSIBILITIES <br /> • The City of Saint Paul's Administrative Code, Chapter 2,Article 1, Section 2.02, as <br /> amended, empowers the Director of the Office of Financial Services,which includes a <br /> Treasury Section,with the investment responsibility for the City. Responsibility for the <br /> operation of the investment program is delegated to the Treasury Manager,who shall act <br /> in accordance with written procedures and internal controls for the operation of the <br /> investment program consistent with the IPS. The Treasury Manager is assisted by the <br /> Cash Manager. No person may engage in an investment transaction,except as provided <br /> under the terms of this policy. <br /> A. Director of the Office of Financial Services <br /> The duties and responsibilities of the Director of the Office of Financial Services <br /> under this IPS are to: <br /> I. Recommend to the City Council adoption and amendment of the IPS. <br /> 2. On a quarterly basis, review and approve the recommendations of the Treasury <br /> Manager regarding: <br /> • 4 <br />