§ 3.12.180. Control Procedures.

A.

Review of Investment Objectives. The Advisor shall review annually and report to the District the appropriateness of this Policy Statement for achieving the Plan's stated objectives. It is not expected that this Policy Statement will change frequently. In particular, short-term changes in the financial markets should not require an adjustment in this Policy Statement.

B.

Review of Investment Performance. The Advisor shall report on a quarterly basis to District staff to review the investment performance of the Plan. The Advisor shall also make an annual in-person presentation to the District's Finance Committee to review the performance and strategy of the Plan. In addition, the Advisor will be responsible for keeping the District advised of any material change in investment strategy, Managers, and other pertinent information potentially affecting performance of the Plan.

The Advisor shall compare the investment results on a quarterly basis to appropriate peer universe benchmarks, as well as market indices in both equity and fixed income markets. Examples of benchmarks and indexes that will be used include the Russell 3000 for U.S. equities, S&P 500 Index for large cap equities, Russell 2000 Index for small cap equities, MSCI All Country World Index (ACWI) ex US Index for broad based non-U.S. equity strategies; MSCI Europe, Australasia and Far East (EAFE) for developed international equities, Barclays Capital Aggregate Bond Index for fixed income securities, and the U.S. 91 Day T-bill for cash equivalents. The Russell 3000 will be used to benchmark the U.S. equities portfolio; the MSCI ACWI ex-U.S. Index will be used to benchmark the non-U.S. equities portfolio; the Barclays Capital Aggregate Index will be used to benchmark the fixed income portfolio. The categories "Other" will be benchmarked against appropriate indices depending on the specific characteristics of the strategies and funds used.

C.

Investment Reporting. The Chief Financial Officer shall submit a quarterly report of investments to the District's Board within forty-five (45) days following the end of the period covered by the report. The Chief Financial Officer shall maintain complete and timely records of all transactions.

D.

Voting of Proxies. The District recognizes that proxies are a significant and valuable tool in corporate governance. The voting rights of individual stocks held in separate accounts or collective, common or pooled funds will be exercised by the investment managers in accordance with their own proxy voting policies. The voting rights of funds will be exercised by the Advisor.

( Res. No. 2015-8-4, § 1(Policy No. 8.6), 8-25-2015 ; Res. No. 2018-9-2 , § 1, 9-25-2018)