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1180-6: ETHICS AND CONFLICTS OF INTEREST:
Those 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. The overall program shall be designed and managed with a degree of professionalism worthy of the public trust. Employees and investment officials shall disclose to the chief administrative officer any material financial interests in financial institutions that conduct business within the city, and they shall further disclose any large personal financial/investment positions that could be related to the performance of the city's portfolio or any other conflicts of interest. Employees and officers shall subordinate their personal investment transactions to those of the city, particularly with regard to the time of purchases and sales. (Eff. 4-4-2016)