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<br />e <br /> <br />. <br /> <br />IV. RESPONSIBILITY AND CONTROL <br /> <br />DELEGATION Management responsibility for the investment program is <br />hereby delegated to the Director of Finance, who shall establish written <br />procedures for the operation of the investment program, consistent with this <br />investment policy. Such procedures shall include explicit delegation of <br />authority to persons responsible for investment transactions. <br /> <br />SUBORDINATES All persons involved in investment activities will be referred <br />to as "Investment Officials". No person shall engage in an investment <br />transaction except as provided under the terms of this policy and the <br />procedures established by the Director of Finance. The Director of Finance <br />shall be responsible for all transactions undertaken, and shall establish a <br />system of controls to regulate the activities of Subordinate Investment Officials. <br /> <br />QUARTERLY REPORTS The Director of Finance shall submit quarterly an <br />investment report that summarizes recent market conditions, economic <br />developments and anticipated investment conditions. The report shall <br />summarize the investment strategies employed in the most recent quarter, <br />describe the portfolio in terms of investment securities, maturities, risk <br />characteristics and other features. The report shall explain the quarter's total <br />investment return and compare the return to budgetary expectations. The <br />report shall include an appendix that discloses all transactions during the <br />quarter. <br /> <br />ANNUAL REPORTS Within 90 days of the end of the fiscal year, the Director <br />of Finance shall present a comprehensive annual report on the investment <br />program and investment activity. The annual report shall include twelve-month <br />and quarterly comparison of returns, and shall suggest improvements that <br />might be made in the investment program. <br /> <br />PRUDENCE Investments shall be made with the exercise of due care, which <br />persons of prudence, discretion and intelligence exercise in the management <br />of their own affairs, not for speculation but for investment considering the <br />probable safety of their own capital as well as the probable income to be <br />derived. <br /> <br />CONFLICTS OF INTEREST Officers and employees involved in the investment <br />process shall refrain from personal business activity that could conflict with <br />proper execution of the investment program, or which could impair their ability <br />to make impartial investment decisions. <br /> <br />2 <br />