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CONFLICT OF INTEREST MANAGEMENT POLICY



FAIS GENERAL CODE OF CONDUCT



1 CONFLICT OF INTEREST

Conflict of interest means any situation in which a financial services provider or its representative has an actual or potential interest that may, in rendering financial services to a client:
  • influence the objective exercise of their obligations to a client, and
  • prevent a provider or representative from rendering an unbiased and fair financial service or from acting in the interests of a client including but not limited to:
  • any ownership interest; and
  • any relationship with a third party.

2. MANAGEMENT OF CONFLICTS OF INTEREST

2.1 Remuneration of representatives

All representatives who are authorised to render financial services on behalf of the Society are remunerated on a commission basis. The Society does not provide any cash incentives to representatives with regard to the submission of any new business. Representatives are not allowed to accept any form of financial reward or payment from clients.

2.2 Limitations on remuneration of brokers

Brokers as independent financial services providers receive commission for submitting new business. The payment of commission to brokers is regulated by the Long-term Insurance Act 52 of 1998.
The Society will not provide any incentive payment, other than commission, to brokers or their representatives for submitting new business or giving preference to a specific product.

2.3 Receiving or offering immaterial financial interests

Immaterial financial interest means any financial interest with a determinable monetary value, the aggregate of which does not exceed R1 000 in any calendar year received by a provider, its associate or representative from the same third party or an associate of that third party in that calendar year.
For purposes of managing potential conflict of interest the Society will ensure that any financial interest offered to brokers and representatives will not exceed R1 000 in any calendar year.

Training by a product supplier on products, general industry information and technical systems that are not exclusively available to a selected group of providers or representatives except for travel and accommodation associated with that training will not constitute material financial interest.
The Society will not offer any financial interest to its representatives, key individuals and/or independent brokers for:
- favouring quantity of business over quality of service;
- favouring a specific product supplier where required to recommend more than one supplier to a client; and
- giving preference to a specific product over other products.

Should a conflict of interest arise which cannot be avoided, the Society will disclose to the client, product supplier or broker the nature and extent of such conflict and any possible steps that may be taken to mitigate the conflict.

3. PROCESSES AND MEASURES TO FACILITATE COMPLIANCE

All employees and representatives are required to read this policy and fully understand the provisions of this document and the application thereof.
Comprehensive training on the conflict of interest policy will be provided by the Compliance department as part of general FAIS training.
The Compliance department will include monitoring of the conflict of interest policy as part of their general monitoring duties and will report thereon in the annual compliance report.
Non-compliance will be subject to disciplinary procedures in terms of the Society’s employment conditions and can ultimately result in debarment or dismissal of the representative.
This policy shall be reviewed as and when changes to legislation occur.


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