SPAULDING HIGH SCHOOL UNION DISTRICT #61 CODE: DFA

POLICY MANUAL

1^st Reading: 9/7/00, 1/19/09

2^nd Reading/Final: 2/2/09

3^rd Reading/Adoption: 11/6/00

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Scholarship Fund Investment Policy

1.0 STATEMENT OF PURPOSE

The purpose of this policy is to establish guidelines and procedures for the management and oversight of the investment of the Spaulding High School Scholarship Fund (“SHS Fund”). The SHS Fund shall be comprised of all monies donated or bequeathed to Spaulding High School for the express purpose of funding scholarship awards and shall be jointly aggregated for management purposes, unless prohibited by specific donor request.

2.0 INVESTMENT COMMITTEE

The implementation of this policy will be the charge of the Investment Committee (“Committee”).

2.1 The Investment Committee will consist of two representatives of the Spaulding High School Union District Finance Committee, the Chair of the Spaulding High School Union District Board of Directors (“Board”), the Barre Supervisory Union Superintendent, and the Barre Supervisory Union Business Manager.

2.2 The Investment Committee will have general charge and direction of the investment of all money, gifts, mortgages, securities, and the income and dividends therefrom.

2.3 The Investment Committee will be responsible for recommending to the Board the retention of a professional investment manager(s) (“Manager”).

2.4 The Committee is responsible for monitoring the Manager’s performance in accordance with the investment objectives and guidelines set forth in this Policy. Additionally, the Committee will conduct a comprehensive review of the Manager’s overall performance at least every five years.

The Committee will report at least annually to the Board on the status of the SHS Fund, investment performance and such other matters as are material to the management and oversight of the Fund.

The Committee will recommend to the Board for approval the amount of monies to be disbursed from the SHS Fund for annual scholarship awards. The recommendation will be made prior to March 1 and will be base on the valuation of the portfolio on December 31 of the preceding year. The Committee will be prohibited from participating in the selection of scholarship award recipients.

2.5 The Investment Committee will review the Investment Policy annually, submit recommendations for changes to the Board, and apprise the Manager of any approved changes.

3.0 INVESTMENT MANAGER

The Manger will be appointed by the Board and will be a registered Investment Manager under the laws of the State of Vermont.

3.1 The Manager will operate on a fully discretionary basis; the purchases and sales of securities may be executed without prior approval subject to the provisions of this policy and in accordance with the objectives and guidelines as stated herein.

3.2 The performance of the Manager will be evaluated over the longer term (three to five years, and with regard to applicable market cycles), to avoid focusing on short-term results.

4.0 INVESTMENT OBJECTIVES

4.1 The investment objective will be to obtain a reasonable income return while preserving the principal of the fund, and facilitating the growth of principal over time.

4.2 The objectives will establish a rate-of-return benchmark, specifically, income plus appreciation in the value of the fund to exceed 4% per annum plus the rate of inflation.

4.3 The management of the portfolio will be guided by the desired goal to permit a stable multi-year award cycle.

5.0 INVESTMENT GUIDELINES

5.1 All investments will be in accordance with and conform to all requirements of the applicable laws of the State of Vermont.

5.2 The investment objectives are expected to be accomplished without undue risk exposure and within the framework of ordinary business care and prudence.

5.3 The fund portfolio will include appropriate diversification of assets generally including a mix of equities, bonds, and approved cash equivalents.

5.4 The Manager will refrain from investing more that 5% of the fund’s assets in any individual security or more that 5% in the outstanding investment in any corporation.

5.5 The Manager will be restricted from investing in letter stock, options, commodities, derivatives, warrants, or engaging in short sales, margin transactions, or other specialized transactions without the express written consent of the Committee.

5.6 While assets will be co-mingled for the purpose of investment management, the Manager will maintain a valuation of individual donations and bequests so as to preserve the integrity of each, and facilitate the disbursement of individual scholarship awards.

6.0 COMMUNICATIONS

6.1 The Manager will provide written monthly portfolio valuations to the Committee.

6.2 On a quarterly basis, the Manager will provide written reports in sufficient detail to inform the Committee of the portfolio’s status and any changes in investment strategy.

6.3 At the direction of the Committee, meeting will be held with the Manager to discuss performance results, investment compliance, economic outlook, investment strategy, organizational changes and other pertinent matters. While it is intended that meetings be held on a quarterly basis, the Committee will have full discretion to schedule meetings as deemed necessary.

6.4 Should the Manager determine that the Investment Objectives cannot be met, or the guidelines constrict reasonable performance, the Manager will notify the Committee in a timely manner, in writing, setting forth those areas believed to limit attainment of the objectives.

7.0 SUMMARY

This Policy is to provide meaningful guidance in the management and oversight of the SHS Fund and is not intended to be overly restrictive given changing economic, business, and investment market conditions.

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