Confict of Interest

1. DEFINITIONS

The Financial Services Provider (“FSP”) trades as a Company incorporated with limited liability in terms of the Companies Act, with registration number 2022/235484/07 and as an authorised Financial Services Provider (Application in progress)

For the purposes of this Policy, the following words and expressions will have the following meanings:

“associate” in relation to the FSP, means any entity referred to in subparagraphs (i) to (vii) below who is also a product supplier, another provider, an associate of a product supplier or a provider, a distribution channel or any person who in terms of an agreement or arrangement with any product supplier, another provider, an associate of a product supplier or a provider, a distribution channel above provides a financial interest to the FSP or its representatives such an associate being:

                (i)            any subsidiary company of the FSP,

                (ii)           any holding company of the FSP,

                (iii)         any other subsidiary of any holding company of the FSP

                (iv)          any other company of which that holding company Is a subsidiary;

                (v)           any person in accordance with whose directions or instructions the board of

directors of the FSP is accustomed to act;

(vi)          any juristic person of which the board of directors or, in the case where such

juristic person is not a company, of which the governing body is accustomed to act in accordance with the directions or instructions of the FSP;

                (vii)        any trust controlled or administered by the FSP.

“conflict of Interest” means any situation in which the FSP or any Representative has an

actual or potential interest that may, in rendering a financial service to a Client,

1. a) influence the objective performance of his, her or its obligations to that client; or
2. b) prevent the FSP or any representative from rendering an unbiased and fair

financial service 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;

“distribution channel” means

1. any arrangement between a product supplier or any of its associates and one or

more FSPs or any of its associates in terms of which arrangement any support or service is provided to the FSP or FSPs in rendering a financial service to a client;

1. b) any arrangement between two or more FSPs or any of their associates, which arrangement facilitates, supports or enhances a relationship between the FSP or FSPs and a product supplier;
2. c) any arrangement between two or more product suppliers or any of their associates, which arrangement facilitates, supports or enhances a relationship between a FSP or FSPs and a product supplier;

“financial interest” means any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, other incentive or valuable consideration, other than

1. a) an ownership interest;
2. b) training, that is not exclusively available to a selected group of FSPs or representatives, on

                                (i)            products and legal matters relating to those products;

                                (ii)           general financial and industry information;

(iii)         specialised technological systems of a third party necessary for the rendering of a financial service; but excluding travel and accommodation associated with that training;

1. c) a qualifying enterprise development contribution, to a qualifying beneficiary entity, by an FSP that is a measured entity

“Immaterial financial Interest” means any financial Interest with a determinable monetary value, the aggregate of which does not exceed R 1 000 in any calendar year from the same third party in that calendar year received by

1. a) a FSP who is a sole proprietor; or
2. b) a representative for that representative’s direct benefit;
3. c) a FSP, who for its benefit or that of some or all of its representatives, aggregates the immaterial financial interest paid to its representatives;

“ownership interest” means;

1. any equity or proprietary interest, for which fair value was paid by the owner at the time of acquisition, other than equity or an proprietary interest held as an approved nominee on behalf of another person; and
2. includes any dividend, profit share or similar benefit derived from that equity or ownership interest

“third party” means

1. a) a product supplier;
2. b) another FSP;
3. c) an associate of a product supplier or a FSP;
4. d) a distribution channel;
5. e) any person who in terms of an agreement or arrangement with a person referred to in paragraphs (a) to (d) above provides a financial interest to a FSP or its representatives.

All Rights Reserved. Certified Financial Service Provider. Koinz (PTY)Ltd - FSP No. 53477 - Registration: 2022/235484/07