Sarasota County Investment Policy 2018

Sarasota County Investment Policy 14 duration asset to the market cycle duration of the portfolio is the 2 year U.S. Treasury. To measure the appropriate income or yield for the County’s investment portfolio, we will benchmark the aggregate portfolio yield against the 24 month rolling average yield of the 2 year constant maturity U.S. Treasury. D. POLICIES TO ENSURE ETHICAL AND PRUDENT ACTION 1. Establishment of Internal Controls It is the policy of the County to establish a system of internal controls, which shall be in writing. The internal controls shall address the following points: a. Control of collusion Collusion is a situation where two or more employees are working in conjunction to defraud their employer or gain something illegally. b. Separation of functions Separation of key functions provides the County the ability to prevent fraud and errors by disseminating tasks and associated privileges amongst multiple employees. c. Custodial safekeeping Securities purchased from any bank or dealer, including appropriate collateral, should be placed into a third-party bank for custodial safekeeping. d. Third-Party acknowledgement Any monies managed on behalf of Sarasota County will adhere to the current investment policy and ordinance. e. Clear delegation of authority to subordinate staff members Subordinate staff members must have a clear understanding of their authority and responsibilities, to avoid any improper actions. Clear delegation of authority also preserves the internal control structure that is built around the various staff positions and their respective responsibilities. f. Specific limitations regarding securities losses and remedial action Securities losses may be necessary to implement this Investment Policy. These losses should be restricted to specified purposes and proper documentation and required approval should be clearly defined for each staff person. g. Written confirmation of telephone transactions for investments and wire transfers Due to the potential for error and improprieties arising from telephone transactions, all telephone transactions should be supported by written communications and approved by the appropriate person. h. Documentation of transactions and strategies