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Authority to manage the City's investment program is derived from Sections 41006 and <br /> 53600 et seq. of the Government Code and Chapter 2.16 of the Pleasanton Municipal <br /> Code. Management responsibility for the investment program is delegated by the City <br /> Council and City Manager to the Director of Finance. <br /> The Director of Finance will be responsible for all transactions undertaken and will <br /> establish a system of procedures and controls to regulate the activities of subordinate <br /> officials and employees. Such procedures will include explicit delegation of authority to <br /> persons responsible for investment transactions. No person may engage in an investment <br /> transaction except as provided under the terms of this policy and the procedures <br /> established by the Director of Finance. <br /> The City may engage the services of professional investment managers (Advisers) at the <br /> election and further approval of the City Council at the recommendation of the City <br /> Manager and Director of Finance. The Adviser shall be registered under the Investment <br /> Advisers Act of 1940. The Adviser may be granted discretion to purchase and sell <br /> investment securities in accordance with this investment policy. The Adviser shall follow <br /> this Investment Policy, written internal controls and other written instructions as provided <br /> by the City. Such delegation is subject to City review and overriding discretion which will <br /> be exercised as needed. <br /> ETHICS AND CONFLICTS OF INTEREST <br /> All participants in the investment process shall act as custodians of the public trust. <br /> Investment officials shall recognize that the investment portfolio is subject to public review <br /> and evaluation. Officers and employees involved in the investment process shall refrain <br /> from personal business activity that could conflict with proper execution of the investment <br /> program, or which could impair their ability to make impartial investment decisions. <br /> Employees and investment officials shall disclose to the City Manager any material <br /> interests in financial institutions with which they conduct business, and they shall further <br /> disclose any large personal financial/investment positions that could be related to the <br /> performance of the investment portfolio. Employees and officers shall refrain from <br /> undertaking any personal investment transactions with the same individual with whom <br /> business is conducted on behalf of the City. employees and investment officials who <br /> manage the investment of public funds must file an annual Statement of Economic <br /> Interests. <br /> AUTHORIZED FINANCIAL DEALERS AND INSTITUTIONS <br /> To the extent practicable, the Director of Finance shall endeavor to complete investment <br /> transactions using a competitive bid process whenever possible. The Director of Finance <br /> will determine which financial institutions are authorized to provide investment services <br /> to the City. It shall be the City's policy to purchase securities only from authorized <br /> institutions and firms. The Director of Finance will maintain a list of financial institutions <br />