CONFLICT OF INTEREST POLICY CC&A Insurance Brokers (Pty) Ltd (Hereinafter referred to as “The FSP”) “A conflict of interest is a situation in which financial or other personal considerations have the potential to compromise or bias professional judgment and objectivity.” Introduction In terms of the Financial Advisory and Intermediary Services Act, Act No 37 of 2002 and its subordinate legislation, The FSP is required to maintain and operate effective organizational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage a conflict of interest. The General Code of Conduct contains various provisions which are indicative of the relevance of a conflict of interest and fair treatment of clients. Section 3(1)(b) stipulates that – “When a provider renders a financial service the provider must disclose to the client the existence of any personal interest in the relevant service, or of any circumstance which gives rise to an actual or potential conflict of interest in relation to such service, and take all reasonable steps to ensure fair treatment of the client.” Section 3(1)(c) stipulates that – “non-cash incentives offered and/or other indirect consideration payable by another provider, a product supplier or any other person to the provider could be viewed as a potential conflict of interest.” Section 7(1)(c)(vi) stipulates that – “…. a provider must …. in particular, at the earliest reasonable opportunity, provide, where applicable, full and appropriate information of the following: the nature, extent and frequency of any incentive, remuneration, consideration ….. which will or may become payable to the provider, directly or indirectly, by any product supplier or any person other than the client, or for which the provider may become eligible, as a result of rendering of the financial service ….” Section 7(1)(d) stipulates that – “the service must be rendered in accordance with the contractual relationship …… and with due regard to the interests of the client which must be accorded appropriate priority over any interests of the provider.” Section 7(1)(f) stipulates that – “the provider must not deal in any financial product, for own benefit, account or interest where the dealing is based upon advanced knowledge…. which would be expected to affect the prices of such product.” Other – The General Code of Conduct also prescribes that we should disclose to a client the fact that we hold 10% or more shares in a product supplier and whether we received more than 30% of our remuneration from one product supplier over a 12 months period. The FSP has put in place a policy to safeguard its clients’ interests and ensure fair treatment of clients. The key information is summarized below. Detailed information may be obtained upon request from the key individual who is responsible to monitor and manage a conflict of interest on behalf of The FSP. Our objectives The FSP is an authorized financial services provider. Any financial services provider, such as The FSP, is potentially exposed to a conflict of interest in relation to various activities. However, the protection of our client’s interests is our primary concern as stated in our policy:
Conflict of interest The FSP strives towards ensuring it is able to appropriately and effectively identify and manage potential conflict. It will manage potential conflict through avoidance, establishing confidentiality barriers or by providing appropriate disclosure of the conflict to affected clients. In determining whether there is or may be a conflict of interest to which the policy applies, The FSP considers whether there is a material risk of damage to the client, taking into account whether The FSP or an employee thereof –
Our policy defines a possible conflict of interest as:
Management The measures that The FSP have adopted to manage identified conflict is summarized below. We consider them appropriate in our efforts to ensure that reasonable care is taken, in relation to each identified potential conflict of interest, and to act impartially to avoid a material risk of harming clients’ interests.
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