Page 454 - Bedford-FY22-23 Budget

c. Liquidity needs of the portfolio require that the investment be sold or redeemed.

III. Standards of Care.

1. Prudence. The standard to be used by Investment Officers shall be the “prudent person”
rule, which states, “investments shall be made with judgment and care, under prevailing
circumstances, that a person of prudence, discretion, and intelligence would exercise in the
management of the person’s own affairs, not for speculation, but for investment, considering
the probable safety of capital and the probable income to be derived.” Investment Officers
acting in accordance with written policies and procedures, and exercising due diligence,
shall be relieved of personal responsibility for an individual investment's credit risk or
market price changes, provided deviations from expectations are reported in a timely
fashion.

2. Ethics and Conflicts of Interest. Investment Officers shall refrain from personal business
activity that could conflict with the proper execution and management of the investment
program, or that could impair their ability to make impartial decisions. Investment Officers
shall disclose any material interests in financial institutions with which they conduct
business. They shall further disclose any personal financial/investment positions that could
be related to the performance of the investment portfolio. Investment Officers shall refrain
from undertaking personal investment transactions with the same individual with whom
business is conducted on behalf of BEDFORD.

An Investment Officer who has a personal business relationship, as defined by the PFIA,
with a depository bank or with any entity seeking to sell an investment to BEDFORD shall
file a statement disclosing that personal business interest. An Investment Officer who is
related within the second degree of affinity or consanguinity to an individual seeking to sell
an investment to BEDFORD shall file a statement disclosing that relationship. A statement
required under this subsection must be filed with the Texas Ethics Commission and the City
Council.

3. Delegation of Authority. Authority to manage and operate the investment program is
granted to the Director of Finance. The Director of Finance shall establish written
procedures and internal controls for the operation of the investment program consistent with
this Investment Policy. Procedures should include, but not be limited to: account
management procedures, cash flow estimation procedures, investment transaction
procedures, authorized broker/dealer selection process, and investment portfolio reporting
requirements. No person may engage in an investment transaction except as provided under
the terms of this Policy and the procedures established by the Director of Finance. The
Director of Finance shall be responsible for all transactions undertaken and shall establish a
system of controls to regulate the activities of the Authorized Investment Officers and
subordinate officials.

4. Authorized Investment Officers.Assistant City Manager

Director of Finance

3