INTRODUCTION

The company conducts its business honestly and ethically.  We constantly improve the quality of our services, products and operations and strive to create and maintain our reputation for honestly, fairness, respect, responsibility, integrity, trust and sound business judgement.  No illegal or unethical conduct on the part of directors, employees or affiliates is in the company’s best interest.  The company will not compromise its principles for short-term advantage.  The ethical performance of this company is the sum of the ethics of the men and women who work here; thus, we are all expected to adhere to high standards of personal integrity.

CONFLICT OF INTEREST

Officers, directors and employees of the company must never permit their personal interests to conflict, or appear to conflict, with the interests of the company, its clients or affiliates.  This may include but is not exclusive to:

  • Real or perceived financial gain resulting from recommendations to our clients at a cost to the client.
  • An outcome in service delivery or a transaction executed that may differ from the real interest of the client.
  • Any non-cash incentives that may be received by the business from affecting any pre-determined transaction and/or product.
  • Effecting a transaction and/or product that may result in a benefit to another party other than the client.

Officers, directors and employees must be particularly careful to avoid representing the company in any transaction with others with whom there is any outside business affiliation or relationship.  Officers, directors and employees shall avoid using their company contacts to advance their private business or personal interests at the expense of the company, its clients or affiliates.

REPRESENTATIVE INCENTIVES AND REMUNERATION

It is the policy of the company that no representative shall be remunerated as part of an incentive structure with its main or sole aim to increase production, by way of share options at a discount or by way of any cash on non-cash incentive, unless such incentive structure takes into account:

  • A combination of quantitative and qualitative criteria; and
  • Is not limited to a specific supplier; and
  • Is not limited to a specific product.

Any incentive as contemplated in this section must be linked to a particular incentive exercise and be approved by the CEO in writing prior to being implemented.  All incentive projects must be disclosed to clients of the company who are approached with a view to doing business with them and every incentive project must be attached to this policy, together with a description of the nature and basis of participation and any other rules as well as the duration of the incentive project.

GIFTING

No bribes, kickbacks or other similar remuneration or consideration shall be given to any person or organization in order to attract or influence business activity.  Officers, directors and employees shall avoid gifts, gratuities, fees, bonuses or excessive entertainment, in order to attract or influence business activity.

In order to further ensure the adherence to this requirement, the official policy of the business is as follows:

Any gifts or gratuities over the value of R1 000 in the aggregate from any other person, including such person’s associate as definite in Financial Services Board Notice 58 of 2010 may not be accepted by any person within the organization and neither may such gifts or incentives be given by any person in the company, to any third party.

No gifts or gratuities may be accepted or given without written consent from the CEO of the company.  In exercising his discretion, the CEO must have regard to any commission regulations or other laws which may be breached by the receipt of such gift.

MANAGEMENT OF CONFLICTS

Lesser conflicts

When any staff member of the company suspects a potential conflict of interest, that member shall be obliged to discuss the matter with his/her immediate superior.  The content of the discussion as well as any decision made must be minuted. The superior and staff member will accept joint responsibility for the decision taken unless the decision is put forward for ratification to a more senior person in the company.  In assessing whether a conflict is material or of a lesser nature, regard must be had to the impact that such a conflict will have on the company’s reputation, financial loss and internal erosion of ethical standards.

Material conflicts

Material conflicts must be discussed with the CEO before any decision is made.  Only the CEO or person authorized by him may make the final decision regarding a material conflict.

Management and Mitigation

The executive committee of the company will review all conflicts on a quarterly basis and make recommendations regarding steps or avoid a recurrence of those aspects.  The CEO will accept responsibility for the implementation of all steps necessary.  Notice of the attention paid to conflict of interest must be contained in the minutes of the meetings of the executive committee and the relevant extracts of the minutes must be made available to the company’s compliance officer on request, the purpose of which is to enable the compliance officer to report on compliance with this policy.

Where a conflict is identified and a decision made, the nature of the decision must be communicated to the third party in writing as soon as possible.  This applies regardless of whether the decision was made to cease doing business or continue with the business at hand despite the existence of the conflict.  It is important for the preservation of the corporate integrity that these disclosures are made at all times.

 Staff training and general awareness

All the company’s staff must be trained on this policy.  A copy of the policy must be provided to each staff member at inception of that staff member’s duties and updated versions must be circulated as and when they are updated.