2010-320D - Laserfiche WebLink

Home Browse Search

material financial/investment position or finding which may be contrary to this policy or otherwise related to the performance of the Master Trust Fund ' s portfolio . Any adverse findings of the U. S . Department of Labor or the Securities and Exchange Commission regarding a Manager or its financial activities shall be brought to the immediate attention of the Master Trustees by the Administrator once the Administrator is notified . Before engaging in any investment transactions with the Master Trust Fund, a Manager shall have submitted to the Administrator a signed certification from a duly authorized representative attesting that the individuals responsible for the Master Trust Fund' s account have reviewed and shall comply with this investment policy and that they agree to undertake reasonable efforts to preclude imprudent transactions involving the assets of the Master Trust Fund . V. INTERNAL CONTROLS The Master Trustees require that the Administrator and any other designees establish a system of internal controls which shall be in writing . These controls shall be reviewed by independent certified public accountants as part of any required periodic financial statement audit . The internal controls should be designed to prevent losses of the Master Trust Fund which might arise from fraud, error, misrepresentation by third parties, or imprudent actions by the Master Trustees, Administrator or other designees . VI. BROKERAGE AND BID REQUIREMENT Managers shall use their best efforts to ensure that portfolio transactions are placed on a best execution basis . The Master Trustees intend to utilize recapture commissions when it does not interfere with best execution, solely at the discretion of the investment managers . Managers are required to , on a quarterly basis, report all brokerage transactions and reasons for using brokers to the Master Trustees . The Managers shall competitively bid securities in question when feasible and appropriate . Except as otherwise required by law, the most economically advantageous bid must be selected . VII. PROXY VOTING Responsibility for the voting of proxies shall be with the Master Trustees . The Master Trustees may exercise the right to assign this responsibility to the investment managers . Since proxy votes may be considered an asset of the Master Trust Fund, the assignment of voting proxies shall be exercised solely in the interest of the participants and beneficiaries of the Master Trust Fund, and for the exclusive purpose of providing benefits to participants and beneficiaries . Documentation related to the handling and voting of proxies will be reported to the Master Trustees on a quarterly basis . The Master Trustees may (but are not required to) solicit Participating Employees ' instructions as to the voting of a Master Trust Fund investment for their benefit . In so doing, the Master Trustees may solicit instructions from only those Participating Employees whose Plan accounts held the applicable investment on the record date fixed by the investment issuer. To the extent that the Administrator receives proper instructions from these Participating Employees, the Master Trustees shall vote the Master Trust Fund' s rights in accordance with the instructions . Page 4 of 19 Revised June 1 , 2007