ITEM 15 ATTACHMENT 1 - Laserfiche WebLink

Advisers Act of 1940. The Adviser may be granted discretion to purchase and sell investment securities in accordance with this investment policy. The Adviser shall follow this Investment Policy, written internal controls and other written instructions as provided by the City. Such delegation is subject to City review and overriding discretion which will be exercised as needed. ETHICSAND CONFLICTS OF INTEREST All participants in the investment process shall act as custodians of the public trust. Investment officials shall recognize that the investment portfolio is subject to public review and evaluation. Officers and employees involved in the investment process shall refrain from personal business activity that could conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions. Employees and investment officials shall disclose to the City Manager any material interests in financial institutions with which they conduct business, and they shall further disclose any large personal financial/ investment positions that could be related to the performance of the investment portfolio. Employees and officers shall refrain from undertaking any personal investment transactions with the same individual with whom business is conducted on behalf of the City. employees and investment officials who manage the investment of public funds must file an annual Statement of Economic Interests. AUTHORIZED FINANCIAL DEALERS AND INSTITUTIONS To the extent practicable, the Director of Finance shall endeavor to complete investment transactions using a competitive bid process whenever possible. The Director of Finance will determine which financial institutions are authorized to provide investment services to the City. It shall be the City's policy to purchase securities only from authorized institutions and firms. The Director of Finance will maintain a list of financial institutions authorized to provide investment services. In addition, a list will also be maintained of approved security broker/dealers selected by credit worthiness, these may include "primary" dealers or regional dealers that qualify under Security & Exchange Commission Rule 15C3-1 (uniform net capital rule). All broker investment transactions require the approval of authorized City staff. No public deposit shall be made except in a qualified public depository as established by state laws, and deposits will be insured by the Federal Deposit Insurance Corporation, or, to the extent the amount exceeds the insured maximum, will be collateralized in accordance with State law. In accordance with Section 53601.5, institutions eligible to transact investment business with the City include: • Institutions licensed by the state as a broker-dealer • Institutions that are members of a federally regulated securities exchange • Primary government dealers as designated by the Federal Reserve Bank and non - primary government dealers • Special Revenue Funds • Nationally or state -chartered banks • The Federal Reserve Bank • Direct issuers of securities eligible for purchase All financial institutions and broker/dealers who desire to become qualified bidders for investment transactions must supply the Director of Finance with the following: audited financial statements, completed broker/dealer questionnaire, and certification of having reviewed California Government Code, Section 53600 et seq. and read the City's investment policy. 244