Our COI policy is deemed to apply to all employees, which includes
i) Directors
ii) Managers
iii) Permanent Staff
whether they be employed in the financial services sector or not.

FSB Definition of COI is
“any situation in which a provider or representative has an actual or potential interest that may,

In rendering a financial service to a client:
a) influence the objective performance of his, her or its obligations to that client; or
b) prevent a provider or representative from rendering an unbiased and fair financial services
to that client, or from acting in the interests of that client, including, but not limited to:
i) a financial interest
ii) an ownership interest
iii) any relationship with a third party

The following areas have been considered our areas of potential Conflict of Interests:
i) with insurers with whom thee is a business/ownership relationship
ii) With other FSPs with whom there is a business/ownership relationship
iii) with distribution channels with whom there is a business/ownership relationship
iv) with any other persons with whom there is a business/ownership relationship
v) with any service providers with whom there is a business/ownership relationship

Any of the above could be deemed Associate companies or 3 rd party companies with who we may
have an ownership interest in them or by them. These companies, if applicable, are listed in
separate annexure to this policy.
vi) our employment contracts and remuneration polices
vii) with any other relevant relationship that may exist within the company

We considered the following when determining potential COIs
We have documented within this Policy the various relationships and arrangements that we
currently have in place, whether or not these create a conflict of potential conflict.

This document details where we currently stand and requires regular maintenance as new or
potential COIs arise. Any potential COI will be documented and specific steps taken to mitigate,
avoid or manage our Co’s position.
The situations that we scrutinized included.
1. What Associate company relationships do we, or our staff, have?
i.e. in simple terms companies with whom there is a relationship based on common
shareholding, management control or family (in its widest context) members are involved
and subsidiary management control or family (in the widest context) members are involved
and subsidiary or holding company status.
2. What Third party relationships did we, or our staff, have? Including any of their
i Product suppliers (insurers)
ii Other FSPs
Associates
Including any other associates
Iii Distribution channels
Iv Any other person who in terms of an agreement or arrangement with any other these
provides a financial interest is due to us or one of our representatives, for example;
Attorneys
Stationary
IT
Accounting

3 We considered any ownership interest within these relationships?
4 Was there any financial interest paid from or to the entities within these relationships? And
would this create a conflict of interest?
5 Was there any immaterial financial interest paid from or to the entities within these
relationships? If so are we monitoring the frequency and extent?
6 What are our staff remuneration policies?
The process allowed us to assess all of our relationships, including those of our staff and including
financial aspects, and to document these fully. No conflict was identified in terms of our staff
arrangements but at shareholder level our repair agreements need comment. In all circumstances
we looked to
i Avoid – Take-away the situation that creates the conflict
ii Mitigate i.e. implement measures to reduce its potential impact