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Investment Limitations: <br />The following investment transactions are prohibited: <br />• Direct investments in precious metals (precious metals mutual funds and exchange -traded <br />funds are permissible). <br />• Venture Capital <br />• Short sales* <br />• Purchases of Letter Stock, Private Placements, or direct payments <br />• Leveraged Transactions* <br />• Commodities Transactions Puts, calls, straddles, or other option strategies* <br />• Purchases of real estate, with the exception of REITs <br />• Derivatives, with exception of ETFs* <br />*Permissible in diversified mutual funds and exchange -traded funds <br />Duties and Responsibilities <br />Responsibilities of Plan Sponsor <br />The Plan Administrator for the City of San Leandro is responsible for: <br />■ Confirming the accuracy of this Investment Guidelines Document, in writing. <br />■ Advising Trustee and Investment Manager of any change in the plan/account's financial <br />situation, funding status, or cash flows, which could possibly necessitate a change to the <br />account's overall risk tolerance, time horizon or liquidity requirements; and thus would <br />dictate a change to the overall investment objective and goals for the account. <br />• Monitoring and supervising all service vendors and investment options, including <br />investment managers. <br />■ Avoiding prohibited transactions and conflicts of interest. <br />Responsibilities of Trustee <br />The plan Trustee is responsible for: <br />■ Valuing the holdings. <br />■ Collecting all income and dividends owed to the Plan. <br />■ Settling all transactions (buy -sell orders). <br />Responsibilities of Investment Manager <br />The Investment Manager is responsible for: <br />■ Assisting the Plan Administrator with the development and maintenance of this <br />Investment Policy Guideline document annually. <br />■ Meeting with the Plan Administrator annually to review portfolio structure, holdings, and <br />performance. <br />■ Designing, recommending and implementing an appropriate asset allocation consistent <br />with the investment objectives, time horizon, risk profile, guidelines and constraints <br />outlined in this statement. <br />■ Researching and monitoring investment advisers and investment vehicles. <br />■ Purchasing, selling, and reinvesting in securities held in the account. <br />■ Monitoring the performance of all selected assets. <br />■ Voting proxies, if applicable. <br />■ Recommending changes to any of the above. <br />City of San Leandro Employee Benefit Fund Pension Plan <br />Investment Guidelines Document — HighMark Capital Management, Inc. <br />(v. 05/06/2021 - RY) <br />6 <br />