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constraints and liquidity needs. Return on investment is of secondary importance <br />compared to the safety and liquidity objectives described above. <br />5. Transparency — The City shall operate its portfolio in a transparent manner, <br />making its periodic reports both available for public inspection and designed in a manner <br />which communicates clearly and fully information about the portfolio, including market <br />pricing, adjusted book value, yields, and CUSIPs of various securities. <br />III. Performance Measurement <br />The City's investment portfolio shall be designated with the objective of exceeding <br />specific benchmarks after investment related expenses (as defined in Exhibit 1, herein), <br />over trailing three and five-year time periods. The indices are similar in composition to <br />the portfolio and therefore comprise a minimum standard for the portfolio's rate of return. <br />The portfolio will be monitored relative to a peer universe. The peer universes that will <br />be utilized will be provided by the investment consultant. Over a three and five-year time <br />period, the investment managers, and total fund, should be in the top 40% of their peer <br />group. The investment managers shall seek to achieve returns and peer rankings above <br />these thresholds, consistent with risk limitations identified herein and prudent investment <br />principles and practices. <br />IV. Standards of Care <br />1. Prudence - The standard of prudence to be used by investment officials shall be <br />the Prudent Person Rule and shall be applied in the context of managing an overall <br />portfolio. City personnel, 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 to <br />the City Manager in a timely fashion and the liquidity and the sale of securities are <br />carried out in accordance with the terms of this policy. The City Manager has the <br />discretion to report any material events to the City Commission. The Prudent Person Rule <br />states that: <br />"Investments should be made with judgment and care, under 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 the <br />probable safety of their capital as well as the probable income to be derived from the <br />investment." <br />2. Ethics and Conflicts of Interest — The Finance Director and other authorized <br />personnel shall refrain from personal business activity that could conflict with the proper <br />execution and management of the investment program, or that could impair their ability <br />to make impartial decisions. These investment officials shall disclose to the City Manager <br />annually, in a written statement, any material interests in financial institutions with which <br />they conduct business with the City. Employees and officers shall subordinate their <br />personal investment transactions to those of the jurisdiction, particularly with regard to <br />the timing of purchases and sales. They shall refrain from undertaking personal <br />