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62 <br /> INVESTMENT POLICY <br /> IV. Ethics and Conflicts of Interest <br /> Officers and employees involved in the investment process shall refrain from personal <br /> business activity that could conflict with the proper execution and management of the <br /> investment program, or that could impair their ability to make impartial decisions. <br /> Employees and investment officials shall disclose any material interests in financial <br /> institutions with which they conduct business. They shall further disclose any personal <br /> financial/investment positions that could be related to the performance of the investment <br /> portfolio. Employees and officers shall refrain from undertaking personal investment <br /> transactions with the same individual with whom business is conducted on behalf of the <br /> City. <br /> V. Delegation of Authority <br /> Authority to manage the investment program is granted to the Finance Director who <br /> shall be designated as the investment officer. The Finance Director shall develop and <br /> • maintain administrative procedures for the operation of the investment program. The <br /> procedures glWY nclude a bidding process for commercialripaper, monitoring <br /> diversification and risk as well as a system of controls to regulate the activities of <br /> subordinate officials. The Finance Director is authorized, as allowed under Minnesota <br /> Statute, to make transactions with designed depositories and designate broker-dealers <br /> for City funds. In the Finance Directors absence, the City Manager shall be authorized <br /> to complete transactions as the investment official. <br /> VI. Authorized Financial Dealers and Institutions <br /> The Finance Director will maintain a list of financial institutions to provide investment <br /> services to the City. All broker-dealers who desire to become qualified bidders for <br /> investment:transactions must supply the Finance Director with.audited financial_ <br /> statements, proof of National Association of Securities Dealers certification, proof of <br /> Minnesota registrations and completion of broker notification and certification form as <br /> required by the Minnesota Statue #1 18A prior to any investment transactions with the <br /> City. <br /> 3 <br />