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securities are carried out in accordance with the temns of this policy. <br /> <br />Investments shall be made with judgement and care, under circumstances <br />then prevailing, which persons of prudence, discretion and intelligence <br />exercise in the management of their own affairs, not for speculation, but <br />for investment, considering the probable safety of their capital as well as <br />the probable income to be derived. <br /> <br />Ethics and Conflicts of Interest <br />Officers and employees involved in the investment process shall refrain <br />fi'om personal business activity that could conflict with the proper <br />execution and management of the investment program, or that could <br />impair their ability to make impartial decisions. Employees and <br />investment officials shall disclose any material interests in financial <br />institutions with which they conduct business. They shall further disclose <br />any personal financial/investment positions that could be related to the <br />performance of the investment portfolio. <br /> <br />Delegation of Authority <br />Responsibility for the operation of the investment program is hereby <br />delegated to the investment officer, who shall act in accordance with the <br />established written procedures and internal controls for the operation of <br />the investment program consistent with this investment policy. Procedures <br />should include references to: safekeeping, delivery vs. payment, <br />investment accounting, repurchase agreements, wire transfer agreements, <br />and collateral/depository agreements. No person may engage in an <br />investment transaction except as provided under the terms of this policy <br />and the procedures established by the investment officer. The investment <br />officer shall be responsible for all transactions undertaken and shall <br />establish a system of controls to regulate the activities of subordinate <br />officials. <br /> <br />IV. Investment Transactions <br /> <br />Authorized Financial Dealers and Institutions <br />A list will be maintained of financial institutions authorized to provide <br />investment transactions. <br /> <br />Internal Controls <br />The investment officer is responsible for establishing and maintaining an <br />internal control structure that will be reviewed annually with the City of <br />University City/General Fund's independent auditor. The internal control <br />structure shall be designed to ensure that the assets of the City of <br />University City/General Fund are protected from loss, theft or misuse and <br />to provide reasonable assurance that these objective are met. The concept <br /> <br /> <br />