VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #B003

5. Exchange Traded Funds and Equity Index Products 6. Foreign Ordinary shares and Emerging Market Equities d. Real Estate Investment Trusts (both U.S. and International) e. Liquid alternative investments through mutual funds or Exchange Traded Funds Allowable Assets for Short to Mid-Term Reserves  Definition of Short/Mid Term Reserves that are expected to be needed within the next two years a. Cash Equivalents 1. Treasury Bill 2. Money Market Funds 3. Commercial Paper 4. Certificates of Deposit 5. Pooled investment vehicles such as mutual funds or Exchange Traded Funds (ETFs) with short term maturity profiles (average duration less than 1 year) b. Fixed Income Securities 1. Treasury Bill 2. Money Market Funds 3. Commercial Paper 4. Certificates of Deposit 5. Notes and Bonds of U.S. governmental agencies or the Treasury 6. Investment Grade Corporate and Municipal Bonds 7. Investment Grade International Bonds 8. Bonds rated below BBB-/Baa3 (non-investment grade) - May not exceed more than 10% of the fixed income portfolio 9. Agency issued Mortgage Back Securities 10. Pooled Investment vehicles such as mutual funds or Exchange Traded Funds (ETFs) that focus on fixed income instruments

9.2

9.3 Prohibited Assets for “Long Term Reserves” and “Short Term Reserves”

Prohibited reserves include, but are not limited to the following: a. Direct Investments in Commodities and Futures Contracts 1. Private Placements 2. Options 3. Derivatives

9.4 Prohibited Transactions for “Long Term Reserves” and “Short Term Reserves” Prohibited transactions include, but are not limited to the following: a. Short Selling b. Margin Transactions c. Annuities and Insurance Products 9.5 Stock Exchanges for “Long Term Reserves ” and “Short Term Reserves” To ensure marketability and liquidity, investment manager(s) will execute equity transactions through the following exchanges: New York Stock Exchange; American Stock Exchange; and NASDAQ over the counter market.

VCOM Investment Policy

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