Loading...
HomeMy WebLinkAbout2010 08 23 Consent 201 Amendment To General Employee's Retirement System Investment Policy Statement COMMISSION AGENDA CONSENT X INFORMATIONAL ITEM 201 PUBLIC HEARING REGULAR August 23, 2010 MGR /DEPT l Meeting Authorization REQUEST: The City Manager and Finance Department requests that the City Commission consider and approve an amendment to the City of Winter Springs General Employees' Retirement System Investment Policy Statement. SYNOPSIS: The Bogdahn Group has recommended and the Board of Trustees has unanimously voted to change the pension investment performance benchmarks and funding targets as follows; 50% Russell 3000, 15% MSCI EAFE, 20% Barclays Capital U.S. Intermediate Aggregate Bond Index, 5% Barclays Capital TIPS Index and 10% NFI -ODCE index. CONSIDERATIONS: On August 9, 2010 the City Commission approved a rebalancing of the Pension Fund investment portfolio that included a shift of $1.4 million from bonds to real estate. This shift in funds makes in necessary to update section III.a.1. of the Pension Investment Performance Objectives Policy that specifically states the percentage of each investment category's targeted funding level. Furthermore, this section describes the performance benchmark indices that each investment category is measured against. The following changes are proposed: 1) Changing the target for bond funding levels from 25% to 20 %. 2) Changing the target for real estate funding levels from 5% to 10 %. 3) Changing the investment benchmark for real estate from NCREIF to Open End Diversified Core Equity (NFI -ODCE) index. The NFI -ODCE is comprised of only open -end funds, and excludes all the closed -end and separate account real estate portfolios. The NFI -ODCE index reports on both a historical and current basis the results of 26 open -end, commingled funds pursuing a core investment strategy. Currently, the benchmark includes funds with total market value of $70.2 billion. The index includes property investments at ownership share, cash balances and leverage, allowing it to reflect the fund's actual asset ownership positions and financing strategy. The NFI -ODCE is best suited as a benchmark from Multi- employer Property Trust (MEPT) since it specifically covers core funds and the effects of their cash balances and leverage on fund performance. Since open -end funds in the NFI -ODCE have different strategies, the funds may perform well at different times in the real estate /economic cycle. Therefore, it makes sense to look at long -term comparisons of the NFI -ODCE because the performance of the varying fund strategies can be tested throughout all stages of the real estate cycle. FISCAL IMPACT: It is difficult to determine the direct impact of the underlying decision to rebalance the pension portfolio. However, it is conventional wisdom that when faced with increasing interest rates and inflation that bonds will typically under - perform other investment opportunity such as Real Estate. COMMUNICATION EFFORTS: The Board of Trustees will be notified via email that the Commission has approved the Pension Fund Policy. City Manager and Finance Director will work with The Bogdahn Group to rewrite and execute the investment policy. Once the policy has been rewritten it will be posted on the City's intra/internet web sites. RECOMMENDATION: City Manager and Finance Department recommend the Commission approve the amendment set out in this agenda item and detailed herein. ATTACHMENTS: Draft: City of Winter Springs General Employees' Retirement System Investment Policy DRAFT CITY OF WINTER SPRINGS (Plan Sponsor) GENERAL EMPLOYEES' RETIREMENT SYSTEM Investment Policy Statement PURPOSE OF INVESTMENT POLICY STATEMENT The Pension Board of Trustees, as named fiduciaries, maintains that an important determinant of future investment returns is the expression and periodic review of the Plan's investment objectives. To that end, the Board has adopted this statement of Investment Policy and directs that it apply to all assets under their control. In fulfilling their fiduciary responsibility, the Board recognizes that the retirement system is an essential 1 providing income benefits to retired participants or their beneficiaries. The Board also ci vehicle for P g P P recognizes investment policy should be made with a Plan are long-term and that II nizes that the obligations of the a g S g P Y view toward performance and return over a number of years. The general investment objective, then, is to obtain a reasonable total rate of return - defined as interest and dividend income plus realized and unrealized capital gains or losses - commensurate with the Prudent Investor Rule and any other applicable statute. ii Reasonable consistency of return and protection of assets against the inroads of inflation are paramount. However, the volatility of interest rates and securities markets make it necessary to judge results within the context of several years rather than over short periods of two years or less. The Board will employ professional Investment Management firms to invest the assets of the Plan. Within the parameters allowed in this document, the Investment Managers shall have full discretion,�� including security selection, sector weightings and investment style. The Board, in performing their investment duties, shall comply with the fiduciary standards set forth in Employee Retirement Income Security Act of 1974 (ERISA) at 29 U.S.C. s. 1104(a) (1) (A) — (C). In case of conflict with other provisions of law authorizing investments, the investment and fiduciary standards set forth in this section shall prevail. ICI ,III II. TARGET ALLOCATIONS ADOPTED: AUGUST 10, 2009 Page 1 In order to provide for a diversified portfolio, the Board has engaged several Investment Management firms. The manager's are responsible for the assets and allocation of their mandate only and will be provided an addendum to this policy with their specific performance objectives and investment criterea. Asset Class Target Range Benchmark Index Domestic Large Cap Value Equity 25% 20% - 30% Russell 3000V Domestic Broad Cap GrowthEquity 25% 20% - 30% Russell 1000G Foreign Equity 15% 10% - 20% MSCI -EAFE Broad Market Fixed Income 25% 20% - 30% Barclays Int. Aggregate TIPS 5% 0% - 10% Barclays TIPS Alternative - 0% - 10% Real Estate* 5% 0% - 10% NFI ODCE Property Targets and ranges above are based on market value of total Plan assets. The Trustees will monitor the aggregate asset allocation of the portfolio, and will rebalance to the target asset allocation based on market conditions. If at the end of any calendar quarter, the allocation of an asset class falls outside of its allowable range, barring extenuating circumstances such as pending cash flows or allocation levels viewed as temporary, the asset allocation will be rebalanced into the allowable range. To the extent possible, cash contributions into and withdrawals from the portfolio will be executed proportionally based on the most current market values available. The Trustees do not intend to exercise short-term changes to the target allocation. III. INVESTMENT PERFORMANCE OBJECTIVES The following performance measures will be used as objective criteria for evaluating the effectiveness of the Investment Managers. A. Total Portfolio Performance 1. The performance of the Total Portfolio will be measured for rolling three and five year periods. These periods are considered sufficient to accommodate the market cycles experienced with investments. The performance of this portfolio will be compared to the return of a portfolio comprised of 50% Russell 3000, 15% MSCI EAFE and 2520% Barclays Capital U.S. Intermediate Aggregate Bond Index, 5% Barclays Capital TIPS Index, and 510% NCREIF NFI- ODCE Index. 2. On a relative basis, it is expected that the total portfolio performance will rank in the top 40` percentile of the appropriate peer universe over three and five -year time periods. 3. On an absolute basis, it is expected that total return of the combined portfolio will equal or exceed the actuarial earnings assumption (8.0 %), and equal or exceed the Consumer Price Index plus 3% over three to five year periods. B. Equity Performance The combined equity portion of the portfolio, defined as common stocks and convertible bonds, is expected to perform at a rate at least equal to the 77% Russell 3000 Index, 23% MSCI EAFE Index. Individual components of the equity portfolio will be compared as outlined in Schedule A. All portfolios are expected to rank in the top 40 percentile of the appropriate peer universe over three and five -year time periods. C. Fixed Income Performance ADOPTED: AUGUST 10, 2009 Page 2 The overall objective of the fixed income portion of the portfolio is to add stability, consistency and safety to the total portfolio. The fixed income portion of the portfolio is expected to perform at a rate at least equal to the Barclays Capital U.S. Intermediate Aggregate Bond Index. All portfolios are expected to rank in the top 40 percentile of the appropriate peer universe over three and five -year time periods. D. Treasury Inflation Protection Securities (TIPS) The overall objective of the TIPS portfolio, if utilized, is to provide inflation protection while adding stability to the total portfolio. If TIPS are utilized the strategy is expected to approximate the structure and performance of the Barclays Capital U.S Treasury TIPS Index. E. Real Estate Performance The overall objective of the real estate portfolio of the portfolio, if utilized, is to add diversification and another stable income stream to the total fund. The real estate portion of the total fund, defined as core, open ended private real estate, is expected to perform at a rate at least equal to the NCREIF NFI -ODCE Index and rank in the top 40 percentile of the appropriate peer universe over three and five -year time periods. Please also see attached addendums for performance objectives. F. Alternatives The overall objective of the alternative portion of the portfolio, if utilized, is to reduce the overall volatility of the portfolio and improve potential absolute returns. This portion of the fund is expected to provide an absolute rate of return and will be benchmarked as outlined in the manager addendum. IV. INVESTMENT GUIDELINES A. Authorized Investments Pursuant to the investment powers of the Board of Trustees set forth in the plan and trust documents; and subject to governing Florida Statutes and the governing local ordinances of the City of Winter Springs, the Board of Trustees sets forth the following investment guidelines and limitations on investments: I. Equities: a. Traded on a national exchange. b. Not more than 5% of the Plan's assets, at the time of purchase, shall be invested in the common stock, capital stock or convertible stock of any one issuing company, nor shall the aggregate investment in any one issuing company exceed 5% of the outstanding capital stock of the company. 2. Fixed Income: a. All fixed income investments shall have a minimum rating of investment grade or higher as determined by at least one major credit rating service. b. The value of bonds issued by any single corporation shall not exceed 3% of the total fund. 3. Money Market: ADOPTED: AUGUST 10, 2009 Page 3 a. The money market fund or STIF provided by the Plan's custodian. b. Government paper backed by full faith & credit of the United States Government. 4. Real Estate: a. Shall be limited to commingled funds. Investments must be independently appraised annually. Commingled fund debt holdings shall be considered independently of Fixed Income, and may include both rated and non rated debt. 5. Alternatives a. Investments not described under any other asset class, may be utilized to reduce the overall volatility of the portfolio and improve potential absolute returns. All alternative investments shall be independently custodied and provide for transparency of investment. 6. Foreign Securities: Limited to fully and easily negotiable equity securities, or commingled funds with investments in such securities.. 7. Commingled Funds /Mutual Funds & Exchange Traded Funds: Investments made by the Board may include commingled funds. For purposes of this policy such funds may include mutual funds, commingled funds, and exchange - traded funds. a. Such funds may be governed by separate policy which may include investments not expressly permitted in this Investment Policy Statement. In the event of investment by the Plan into a fund the Board will adopt the prospectus or governing policy of that fund as the stated addendum to this Investment Policy Statement. b. The asset classification of the fund will be based upon its investment objective. B. Trading Parameters When feasible and appropriate, all securities shall be competitively bid. Except as otherwise required by law, the most economically advantageous bid shall be selected. Commissions paid for purchase of securities must meet the prevailing best - execution rates. The responsibility of monitoring best price and execution of trades placed by each manager on behalf of the Plan will be governed by the Portfolio Management Agreement between the Plan and the Investment Managers. C. Limitations 1. Investments in corporate common stock and convertible bonds shall not exceed seventy-five percent (75 %) of the Fund assets at market. 2. Foreign securities shall not exceed twenty percent (20 %) of the value at cost of the Fund. 3. Alternative investments shall not exceed 15% of the value at market of the Fund D. Absolute Restrictions There will be no investment activity in the following: 1. Any investment prohibited by State or Federal Law. ADOPTED: AUGUST 10, 2009 Page 4 2. Any investment not specifically allowed as part of this policy. 3. Illiquid investments, as described in Chapter 215.47, Florida Statutes. V. COMMUNICATIONS A. On a monthly basis, the custodian shall supply an accounting statement that will include a summary and the market value of all assets. On a quarterly disbursements and the cost i t of all receipts and d�sb q Y P basis, the Investment Managers shall provide a written report affirming compliance with the security restrictions of Section IV above and a summary of common stock diversification and attendant schedules. B. In addition, the Investment Managers shall deliver each quarter a report detailing the Plan's performance, adherence to the investment policy, forecast of the market and economy, portfolio analysis and current assets of the Plan. Written reports shall be delivered to the Board within 30 days of the end of the quarter. A copy of the written report shall be submitted to the person e designated by the City, and shall be available for public inspection. The Investment Managers g will 'J provide immediate written and telephone notice to the Board of any significant market related or non - market related event, specifically including, but not limited to, any deviation from the standards set forth in Section IV above. C. The Investment Managers will disclose any securities that do not comply with section IV in each quarterly report. D. If the Plan owns investments at the end of a calendar quarter that complied with section IV at the time of Purchase, which do not satisfy the applicable investment standard, then such investment shall be disposed of at the earliest economically feasible opportunity in accordance with the prudent man standard of care and no additional investment may be made. However an action plan outlining the disposition strategy shall be provided to the Board immediately. and and report on a quarterly basis the rate of return a E. The Investment Consutlant shall evaluate P q Y relative performance of the Plan. F. The Board will meet quarterly to review the monitoring service's performance report. The Board will meet with the investment manager and appropriate outside consultants to discuss performance results, economic outlook, investment strategy and tactics and other pertinent matters affecting the Plan on a periodic basis. G. At least annually, the Board shall provide the Investment Managers with projected disbursement needs of the Plan so that the investment portfolio can be structured in such a manner as to provide sufficient liquidity to pay obligations as they come due. To this end the Investment Managers maturities with known cash needs and should, to the extent possible, attempt to match investment a P � P anticipated cash -flow requirements. VI. COMPLIANCE A. It is the direction of the Board that the plan assets are held by a third party custodian, and that all securities purchased by, and all collateral obtained by the plan shall be properly designated as Plan P Y Y P P P Y � assets. No withdrawal of assets, in whole or in part, shall be made from safekeeping except by an authorized member of the Board or their designee. Securities transactions between a broker - dealer and the custodian involving purchase or sale of securities by transfer of money or securities must be made on a "delivery vs. payment" basis to insure that the custodian will have the security or money in 11 1 ADOPTED: AUGUST 10, 2009 Page 5 hand at conclusion of the transaction. Provided that all approved vendors transacting repurchase agreements perform as stated in any Master Repurchase Agreement. B. At the direction of the Board operations of the Plan shall be reviewed by independent certified public accountants as part of any financial audit periodically required. Compliance with the Board's internal controls shall be verified. These controls have been designed to prevent losses of assets that might arise from fraud, error, or misrepresentation by third parties or imprudent actions by the Board or employees of the plan sponsor, to the extent possible. C. Each member of the Board shall participate in a continuing education program relating to investments and the Board's responsibilities to the Plan. It is highly suggested that this education process begin during each Trustee's first term. II D. With each actuarial valuation, the Board shall determine the total expected annual rate of return for the current year, for each of the next several years and for the long term thereafter. This determination shall be filed promptly with the Department of Management Services, the plan's sponsor and the consulting actuary. E. The proxy votes must be exercised for the exclusive benefit of the participants of the Plan. Each Investment Manager shall provide the Board with a copy of their proxy voting policy votin olic Y forapproval. On a regular basis, at least annually, manager aaershllr shall report record of their proxy vote. Y� g p p y ote. F. Investments for which there is no generally recognized market or consistent accepted pricing mechanism shall be valued at 50% cost. Assets without a fair market value shall be excluded from determination of annual fundin g cost. VII. CRITERIA FOR INVESTMENT MANAGER REVIEW The Board wishes to adopt standards by which judgments of the ongoing performance of a portfolio manager may ay be made. If, at any time, any three of the following is breached, the portfolio manager will be warned of the Board's serious concern for the Fund's continued safety and performance. If any five of these are violated the consultant will recommend a manager search ch for that mandate. I i a g a • Four (4) consecutive quarters of relative under - performance verses the benchmark. • Three (3) year trailing return below the top 40 percentile within the appropriate peer group and under performance verses the benchmark. • Five (5) year trailing return below the top 40 percentile and under performance verses the Ij benchmark. • Three (3) year downside volatility greater than the index (greater than 100), as measured by down market capture ratio. • Five (5) year downside volatility greater than the index (greater than 100), as measured by down market capture ratio. • Style consistency or purity drift from the mandate. • Management turnover in portfolio team or senior management. g na ement. P II g • Investment process change, including varying the index or benchmark. • Failure to adhere to the IPS or other compliance issues. • h Investigation of the firm by the Securities and Exchange Commission (SEC). ( ) • Significant asset gn flows into or out of the company. it ADOPTED: AUGUST 10, 2009 Page 6 • Merger or sale of firm. • Fee increases outside of the competitive range. • Servicing issues — key personnel stop servicing the account without proper notification. • Failure to attain a 60% vote of confidence by the Board. Nothing in this section shall limit or diminish the Board's right to terminate the manager at any time for any reason. VIII. APPLICABLE CITY ORDINANCES If, at any time, this document is found to be in conflict with the City Ordinances, the Ordinances shall prevail. IX. REVIEW AND AMENDMENTS It is the Board's intention to review this document at least annually subsequent to the actuarial report and to amend this statement to reflect any changes in philosophy, objectives, or guidelines. In this regard, the Investment Manager's interest in consistency in these matters is recognized and will be taken into account when changes are being considered. If, at any time, the Investment Manager feels that the specific objectives defined herein cannot be met, or the guidelines constrict performance, the Board should be 1 notified in writing. By initialing and continuing acceptance of this Investment Policy Statement, the Investment Managers concur with the provisions of this document. City of Winter Springs General Employees' Retirement System 1 { Chairperson, Board of Trustees Date ADOPTED: AUGUST 10, 2009 Page 7 CITY OF WINTER SPRINGS (Plan Sponsor) GENERAL EMPLOYEES' RETIREMENT SYSTEM Investment Policy Statement PURPOSE OF INVESTMENT POLICY STATEMENT The Pension Board of Trustees, as named fiduciaries, maintains that an important determinant of future investment returns is the expression and periodic review of the Plan's investment objectives. To that end, the Board has adopted this statement of Investment Policy and directs that it apply to all assets under their control. In fulfilling their fiduciary responsibility, the Board recognizes that the retirement system is an essential vehicle for providing income benefits to retired participants or their beneficiaries. The Board also recognizes that the obligations of the Plan are long -term and that investment policy should be made with a view toward performance and return over a number of years. The general investment objective, then, is to obtain a reasonable total rate of return - defined as interest and dividend income plus realized and unrealized capital gains or losses - commensurate with the Prudent Investor Rule and any other applicable statute. Reasonable consistency of return and protection of assets against the inroads of inflation are paramount. However, the volatility of interest rates and securities markets make it necessary to judge results within the context of several years rather than over short periods of two years or less. The Board will employ professional Investment Management firms to invest the assets of the Plan. Within the parameters allowed in this document, the Investment Managers shall have full discretion, including security selection, sector weightings and investment style. The Board, in performing their investment duties, shall comply with the fiduciary standards set forth in Employee Retirement Income Security Act of 1974 (ERISA) at 29 U.S.C. s. 1104(a) (1) (A) — (C). In case of conflict with other provisions of law authorizing investments, the investment and fiduciary standards set forth in this section shall prevail. ADOPTED: AUGUST 10, 2010 Page 1 II. TARGET ALLOCATIONS In order to provide for a diversified portfolio, the Board has engaged several Investment Management firms. The manager's are responsible for the assets and allocation of their mandate only and will be provided an addendum to this policy with their specific performance objectives and investment criterea. Asset Class Target Range Benchmark Index Domestic Large Cap Value Equity 25% 20% - 30% Russell 3000V Domestic Broad Cap GrowthEquity 25% 20% - 30% Russell 1000G Foreign Equity 15% 10% - 20% MSCI -EAFE Broad Market Fixed Income 20% 20% - 30% Barclays Int. Aggregate TIPS 5% 0% - 10% Barclays TIPS Alternative - 0% - 10% Real Estate* 10% 0% - 10% NFI -ODCE Property Targets and ranges above are based on market value of total Plan assets. The Trustees will monitor the aggregate asset allocation of the portfolio, and will rebalance to the target asset allocation based on market conditions. If at the end of any calendar quarter, the allocation of an asset class falls outside of its allowable range, barring extenuating circumstances such as pending cash flows or allocation levels viewed as temporary, the asset allocation will be rebalanced into the allowable range. To the extent possible, cash contributions into and withdrawals from the portfolio will be executed proportionally based on the most current market values available. The Trustees do not intend to exercise short-term changes to the target allocation. 111. INVESTMENT PERFORMANCE OBJECTIVES The following performance measures will be used as objective criteria for evaluating the effectiveness of the Investment Managers. A. Total Portfolio Performance 1. The performance of the Total Portfolio will be measured for rolling three and five year periods. These periods are considered sufficient to accommodate the market cycles experienced with investments. The performance of this portfolio will be compared to the return of a portfolio comprised of 50% Russell 3000, 15% MSCI EAFE and 20% Barclays Capital U.S. Intermediate Aggregate Bond Index, 5% Barclays Capital TIPS Index, and 10% NFI -ODCE Index. 2. On a relative basis, it is expected that the total portfolio performance will rank in the top 40 percentile of the appropriate peer universe over three and five -year time periods. 3. On an absolute basis, it is expected that total return of the combined portfolio will equal or exceed the actuarial earnings assumption (8.0 %), and equal or exceed the Consumer Price Index plus 3% over three to five year periods. B. Equity Performance The combined equity portion of the portfolio, defined as common stocks and convertible bonds, is expected to perform at a rate at least equal to the 77% Russell 3000 Index, 23% MSCI EAFE Index. Individual components of the equity portfolio will be compared as outlined in Schedule A. All portfolios are expected to rank in the top 40 percentile of the appropriate peer universe over three and five -year time periods. C. Fixed Income Performance ADOPTED: AUGUST 10, 2010 Page 2 The overall objective of the fixed income portion of the portfolio is to add stability, consistency and safety to the total portfolio. The fixed income portion of the portfolio is expected to perform at a rate at least equal to the Barclays Capital U.S. Intermediate Aggregate Bond Index. All portfolios are expected to rank in the top 40`'' percentile of the appropriate peer universe over three and five -year time periods. D. Treasury Inflation Protection Securities (TIPS) The overall objective of the TIPS portfolio, if utilized, is to provide inflation protection while adding stability to the total portfolio. If TIPS are utilized the strategy is expected to approximate the structure and performance of the Barclays Capital U.S Treasury TIPS Index. E. Real Estate Performance The overall objective of the real estate portfolio of the portfolio, if utilized, is to add diversification and another stable income stream to the total fund. The real estate portion of the total fund, defined as core, open ended private real estate, is expected to perform at a rate at least equal to the NFI- ODCE Index and rank in the top 40` percentile of the appropriate peer universe over three and five - year time periods. Please also see attached addendums for performance objectives. F. Alternatives The overall objective of the alternative portion of the portfolio, if utilized, is to reduce the overall volatility of the portfolio and improve potential absolute returns. This portion of the fund is expected to provide an absolute rate of return and will be benchmarked as outlined in the manager addendum. IV. INVESTMENT GUIDELINES A. Authorized Investments Pursuant to the investment powers of the Board of Trustees set forth in the plan and trust documents; and subject to governing Florida Statutes and the governing local ordinances of the City of Winter Springs, the Board of Trustees sets forth the following investment guidelines and limitations on investments: 1. Equities: a. Traded on a national exchange. b. Not more than 5% of the Plan's assets, at the time of purchase, shall be invested in the common stock, capital stock or convertible stock of any one issuing company, nor shall the aggregate investment in any one issuing company exceed 5% of the outstanding capital stock of the company. 2. Fixed Income: a. All fixed income investments shall have a minimum rating of investment grade or higher as determined by at least one major credit rating service. b. The value of bonds issued by any single corporation shall not exceed 3% of the total fund. 3. Money Market: ADOPTED: AUGUST 10, 2010 Page 3 a. The money market fund or STIF provided by the Plan's custodian. b. Government paper backed by full faith & credit of the United States Government. 4. Real Estate: a. Shall be limited to commingled funds. Investments must be independently appraised annually. Commingled fund debt holdings shall be considered independently of Fixed Income, and may include both rated and non rated debt. 5. Alternatives a. Investments not described under any other asset class, may be utilized to reduce the overall volatility of the portfolio and improve potential absolute returns. All alternative investments shall be independently custodied and provide for transparency of investment. 6. Foreign Securities: Limited to fully and easily negotiable securities, or commingled funds with investments in such securities.. 7. Commingled Funds /Mutual Funds & Exchange Traded Funds: Investments made by the Board may include commingled funds. For purposes of this policy such funds may include mutual funds, commingled funds, and exchange- traded funds. a. Such funds may be governed by separate policy which may include investments not expressly permitted in this Investment Policy Statement. In the event of investment by the Plan into a fund the Board will adopt the prospectus or governing policy of that fund as the stated addendum to this Investment Policy Statement. b. The asset classification of the fund will be based upon its investment objective. B. Trading Parameters When feasible and appropriate, all securities shall be competitively bid. Except as otherwise required by law, the most economically advantageous bid shall be selected. Commissions paid for purchase of securities must meet the prevailing best - execution rates. The responsibility of monitoring best price and execution of trades placed by each manager on behalf of the Plan will be governed by the Portfolio Management Agreement between the Plan and the Investment Managers. C. Limitations 1. Investments in corporate common stock and convertible bonds shall not exceed seventy -five percent (75 %) of the Fund assets at market. 2. Foreign securities shall not exceed twenty percent (20 %) of the value at cost of the Fund. 3. Alternative investments shall not exceed 15% of the value at market of the Fund D. Absolute Restrictions There will be no investment activity in the following: 1. Any investment prohibited by State or Federal Law. ADOPTED: AUGUST 10, 2010 Page 4 2. Any investment not specifically allowed as part of this policy. 3. Illiquid investments, as described in Chapter 215.47, Florida Statutes. V. COMMUNICATIONS A. On a monthly basis, the custodian shall supply an accounting statement that will include a summary of all receipts and disbursements and the cost and the market value of all assets. On a quarterly basis, the Investment Managers shall provide a written report affirming compliance with the security restrictions of Section IV above and a summary of common stock diversification and attendant schedules. B. In addition, the Investment Managers shall deliver each quarter a report detailing the Plan's performance, adherence to the investment policy, forecast of the market and economy, portfolio analysis and current assets of the Plan. Written reports shall be delivered to the Board within 30 days of the end of the quarter. A copy of the written report shall be submitted to the person designated by the City, and shall be available for public inspection. The Investment Managers will provide immediate written and telephone notice to the Board of any significant market related or non - market related event, specifically including, but not limited to, any deviation from the standards set forth in Section IV above. C. The Investment Managers will disclose any securities that do not comply with section IV in each quarterly report. D. If the Plan owns investments at the end of a calendar quarter that complied with section IV at the time of purchase, which do not satisfy the applicable investment standard, then such investment shall be disposed of at the earliest economically feasible opportunity in accordance with the prudent man standard of care and no additional investment may be made. However an action plan outlining the disposition strategy shall be provided to the Board immediately. E. The Investment Consutlant shall evaluate and report on a quarterly basis the rate of return and relative performance of the Plan. F. The Board will meet quarterly to review the monitoring service's performance report. The Board will meet with the investment manager and appropriate outside consultants to discuss performance results, economic outlook, investment strategy and tactics and other pertinent matters affecting the Plan on a periodic basis. G. At least annually, the Board shall provide the Investment Managers with projected disbursement needs of the Plan so that the investment portfolio can be structured in such a manner as to provide sufficient liquidity to pay obligations as they come due. To this end the Investment Managers should, to the extent possible, attempt to match investment maturities with known cash needs and anticipated cash -flow requirements. VI. COMPLIANCE A. It is the direction of the Board that the plan assets are held by a third party custodian, and that all securities purchased by, and all collateral obtained by the plan shall be properly designated as Plan assets. No withdrawal of assets, in whole or in part, shall be made from safekeeping except by an authorized member of the Board or their designee. Securities transactions between a broker - dealer and the custodian involving purchase or sale of securities by transfer of money or securities must be made on a "delivery vs. payment" basis to insure that the custodian will have the security or money in ADOPTED: AUGUST 10, 2010 Page 5 hand at conclusion of the transaction. Provided that all approved vendors transacting repurchase agreements perform as stated in any Master Repurchase Agreement. B. At the direction of the Board operations of the Plan shall be reviewed by independent certified public accountants as part of any financial audit periodically required. Compliance with the Board's internal controls shall be verified. These controls have been designed to prevent losses of assets that might arise from fraud, error, or misrepresentation by third parties or imprudent actions by the Board or employees of the plan sponsor, to the extent possible. C. Each member of the Board shall participate in a continuing education program relating to investments and the Board's responsibilities to the Plan. It is highly suggested that this education process begin during each Trustee's first term. D. With each actuarial valuation, the Board shall determine the total expected annual rate of return for the current year, for each of the next several years and for the long term thereafter. This determination shall be filed promptly with the Department of Management Services, the plan's sponsor and the consulting actuary. E. The proxy votes must be exercised for the exclusive benefit of the participants of the Plan. Each Investment Manager shall provide the Board with a copy of their proxy voting policy for approval. On a regular basis, at least annually, each manager shall report a record of their proxy vote. F. Investments for which there is no generally recognized market or consistent accepted pricing mechanism shall be valued at 50% cost. Assets without a fair market value shall be excluded from determination of annual funding cost. VII. CRITERIA FOR INVESTMENT MANAGER REVIEW The Board wishes to adopt standards by which judgments of the ongoing performance of a portfolio manager may be made. If, at any time, any three of the following is breached, the portfolio manager will be warned of the Board's serious concern for the Fund's continued safety and performance. If any five of these are violated the consultant will recommend a manager search for that mandate. • Four (4) consecutive quarters of relative under - performance verses the benchmark. • Three (3) year trailing return below the top 40 percentile within the appropriate peer group and under performance verses the benchmark. • Five (5) year trailing return below the top 40 percentile and under performance verses the benchmark. • Three (3) year downside volatility greater than the index (greater than 100), as measured by down market capture ratio. • Five (5) year downside volatility greater than the index (greater than 100), as measured by down market capture ratio. • Style consistency or purity drift from the mandate. • Management turnover in portfolio team or senior management. • Investment process change, including varying the index or benchmark. • Failure to adhere to the IPS or other compliance issues. • Investigation of the firm by the Securities and Exchange Commission (SEC). • Significant asset flows into or out of the company. ADOPTED: AUGUST 10, 2010 Page 6 • Merger or sale of firm. • Fee increases outside of the competitive range. • Servicing issues — key personnel stop servicing the account without proper notification. • Failure to attain a 60% vote of confidence by the Board. Nothing in this section shall limit or diminish the Board's right to terminate the manager at any time for any reason. VIII. APPLICABLE CITY ORDINANCES If, at any time, this document is found to be in conflict with the City Ordinances, the Ordinances shall prevail. IX. REVIEW AND AMENDMENTS It is the Board's intention to review this document at least annually subsequent to the actuarial report and to amend this statement to reflect any changes in philosophy, objectives, or guidelines. In this regard, the Investment Manager's interest in consistency in these matters is recognized and will be taken into account when changes are being considered. If, at any time, the Investment Manager feels that the specific objectives defined herein cannot be met, or the guidelines constrict performance, the Board should be notified in writing. By initialing and continuing acceptance of this Investment Policy Statement, the Investment Managers concur with the provisions of this document. City of Winter Springs General Employees' Retirement System Chair rson, Board of Trustees Date ADOPTED: AUGUST 10, 2010 Page 7