(A)   Prudence. The actions of the Designated Officials in the performance of their duties as managers of the City of St. Matthews' funds shall be evaluated using the "prudent person" standard. Investments shall be made with judgment and care under prevailing circumstances which persons of prudence, discretion, and intelligence exercise in the management of their own affairs, not for speculation, but for investment considering the probable safety of their capital as well as the probable income to be derived. The Designated Officials, acting in accordance with written procedures, this investment policy, and exercising due diligence shall be relieved of personal responsibility for an individual security's performance, provided that deviations from expectations are reported in a timely fashion to the governing body and appropriate action is taken to control adverse developments.
   (B)   Ethics and conflicts of interest. Officers and employees involved in the investment process shall refrain from personal activity that could conflict with the proper execution and management of the investment program, or that could impair their ability to make impartial investment decisions. Employees and investment officials shall disclose any material interests in financial institutions with which they conduct business. Disclosure shall be made to the governing body. They shall further disclose any 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.
   (C)   Delegation of authority.
      (1)   Governing body. The governing body will retain ultimate fiduciary responsibility for the portfolios. The governing body will receive monthly reports, designate Designated Officials and review the investment policy making any changes necessary by adoption.
      (2)   Designated Officials. Authority to manage the investment program is granted to the Mayor and the City Treasurer, hereinafter referred to as Designated Officials as designated by this subchapter. Responsibility for the operation of the investment program is hereby delegated to the Designated Officials who shall act in accordance with established written procedures and internal controls for the operation of the investment program consistent with this investment policy. Officers will prepare monthly investment reports and other special reports as may be deemed necessary. All participants in the investment process shall seek to act responsibly as custodians of the public trust. No officer or designee may engage in an investment transaction except as provided under the terms of this policy and supporting procedures.
      (3)   Investment adviser. The city may engage the services of one or more external investment managers to assist in the management of the entity's investment portfolio in a manner consistent with the city's objectives. Such external managers may be granted discretion to purchase and sell investment securities in accordance with this investment policy. Such managers must be registered under the Investment Adviser Act of 1940.
(Ord. 19-11, passed 9-10-19)