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-5 - <br />Internal Controls <br />The Director of Finance shall develop and maintain procedures for the operation of <br />the City's investment program in accordance with this Investment Policy. These procedures <br />shall be designed to prevent loss of the City's funds due to fraud, error, misrepresentation, <br />unanticipated market changes or imprudent actions. <br />Records and Reporting <br />The Director of Finance shall maintain a current inventory of all investments including: <br />• Description of each security <br />• Cost <br />• Par value <br />• Dates (beginning, settlement and maturity) <br />• Rates <br />• Seller <br />The Director of Finance shall also prepare and distribute to Council, semi-annually, a list of all <br />investments and a report on investment activity and returns. These reports will also be available <br />upon request. <br />Education <br />The Director of Finance shall participate in any beginning and/or continuing <br />education training programs sponsored by the State Treasurer or the State Auditor in which the <br />Director of Finance is required to participate pursuant to Sections 117.44 and 135.22 of the <br />Revised Code. Through participation in those programs, the Director of Finance is to develop <br />and maintain an enhanced background and working knowledge in investment, cash management, <br />and ethics. <br />Ethics and Conflict of Interest <br />The City officials 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. Those City <br />officials and employees, and investment consultants to the City, shall: (i) disclose to the City's <br />Director of Law any material financial interests in financial institutions that conduct business <br />within the City and any large personal financial or investment positions that could be related to, <br />or affected by, the performance of the City's portfolio, and (ii) subordinate their personal <br />investment transactions to those of the City, particularly with regard to the timing of purchases <br />and sales. <br />The above supplements the applicable provisions of Ohio ethics laws. <br />Non Binding Arbitration <br />The Director of Finance may enter into a written investment or deposit agreement <br />that includes a provision under which the parties agree to submit to nenbinding arbitration <br />net_ to settle any controversy that may arise out of that agreement so long as <br />such provision meets the requirements of the Revised Code and is specifically approved by the <br />Council. <br />