Conflict of Interest Management Policy

POLICY STATEMENT

Assured Life Consultants (Pty) Ltd (“ALC”) is committed to conducting its business with integrity, transparency, fairness and professionalism. The company recognises that conflicts of interest may arise during the rendering of financial services and has implemented this Conflict of Interest Management Policy to identify, avoid, mitigate, monitor and disclose actual or potential conflicts of interest.

This policy applies to:

• Directors
• Key Individuals
• Representatives
• Administrators
• Contractors
• Associates
• Service Providers
• Any person acting on behalf of Assured Life Consultants

All employees and representatives are required to act honestly, fairly, with due skill, care and diligence and always in the best interests of clients.

1. PURPOSE

The purpose of this policy is to:

• Identify actual and potential conflicts of interest.
• Establish procedures to avoid conflicts where possible.
• Establish measures to mitigate unavoidable conflicts.
• Ensure appropriate disclosure to clients.
• Promote Treating Customers Fairly (TCF) outcomes.
• Comply with Section 3A of the General Code of Conduct under FAIS.
• Protect clients from inappropriate influence.
• Ensure fair and objective advice and intermediary services.

2. DEFINITIONS

3. IDENTIFICATION OF CONFLICTS OF INTEREST

A conflict of interest exists where any relationship, ownership interest, financial interest or other arrangement may:

• Influence the objective performance of duties towards a client.
• Prevent the rendering of unbiased financial services.
• Prevent acting in the client’s best interests.
• Result in unfair treatment of a client.
• Create an actual or perceived bias in favour of a product supplier, associate or related entity.

Examples include:

• Ownership interests.
• Referral arrangements.
• Commission structures.
• Gifts and hospitality.
• Relationships with product suppliers.
• Relationships with debt counselling entities.
• Personal relationships affecting business decisions.

4. INTERNAL CONTROLS

To identify and manage conflicts of interest Assured Life Consultants will:

4.1 Governance Reviews

Conduct annual reviews of:

• Product supplier agreements.
• Distribution agreements.
• Referral arrangements.
• Ownership structures.
• Associate relationships.
• Outsourced service providers.

4.2 Declarations

All Directors, Key Individuals, Representatives and Management personnel must complete:

• Annual Conflict of Interest Declarations.
• Ad-hoc declarations whenever a conflict arises.

4.3 Gift Register

A Gift Register will be maintained.

The following must be recorded:

• Gifts
• Hospitality
• Sponsorships
• Travel benefits
• Discounts
• Entertainment

Any gift exceeding R500 must be disclosed immediately.

No employee may accept gifts or benefits that may influence client outcomes.

4.4 Conflict of Interest Register

A Conflict of Interest Register will be maintained.

The following types must be recorded:

• Financial Interest
• Ownership Interest
• Immaterial Financial Interest
• Relationship Interest
• Other – description to be provided

We take pride therein that our advice is objective and free of external influence, but wish to disclose to you, our valued client, that we have received the following financial interests and wish to disclose the value and the reason for receiving the financial interests.

4.5 Monitoring

The Group Risk Manager and Compliance Function will conduct ongoing monitoring and annual reviews of:

• Conflicts Register
• Ownership disclosures
• Financial interests
• Associate relationships

5. AVOIDANCE AND MITIGATION

Where a conflict is identified, the following hierarchy applies:

Step 1 – Avoid

The conflict must be avoided where reasonably possible.

Examples:

• Removal from decision-making.
• Independent review.
• Allocation to another representative.

Step 2 – Mitigate

Where avoidance is not possible:

• Additional oversight is applied.
• Independent review is performed.
• Client disclosures are made.
• Compliance monitoring is increased.

Step 3 – Disclose

All material conflicts must be disclosed to clients before any transaction is concluded.

6. DISCLOSURE TO CLIENTS

Assured Life Consultants will disclose:

• Any ownership interest.
• Any financial interest.
• Any relationship with a product supplier.
• Any relationship that may influence recommendations.
• Any actual or potential conflict of interest.

Disclosure will be:

• Clear
• Accurate
• Timely
• Understandable

Disclosure may be made:

• During sales calls.
• Within policy documentation.
• In writing.
• Via electronic communication.

7. SPECIFIC DISCLOSURE REGARDING OMART

Assured Life Consultants acts as an intermediary and administrator for products underwritten by Old Mutual Alternative Risk Transfer Limited (“OMART”).

Assured Life Consultants is a subsidiary of Financial Wealth Holdings (Pty) Ltd.

Financial Wealth Holdings holds preference shares in OMART and may receive dividend distributions arising from such ownership interests.

Although this relationship creates a potential conflict of interest, product recommendations, advice and intermediary services are based solely on:

• Client needs analysis.
• Product suitability.
• Affordability requirements.
• Regulatory requirements.
• Treating Customers Fairly principles.

Representatives may not favour any product supplier due to ownership interests, incentives or financial benefits.

This relationship is disclosed to clients during the sales process and in applicable policy documentation.

8. FINANCIAL INTERESTS

Representatives may only receive financial interests permitted by legislation including:

• Statutory commission.
• Approved incentives.
• Salaries.
• Performance bonuses.
• Training support.
• Immaterial financial interests.

No incentive structure may:

• Promote unfair treatment of clients.
• Reward volume only.
• Encourage inappropriate product replacement.
• Encourage preference for a specific insurer where alternatives exist.

Performance incentives must consider:

• Compliance results.
• Quality assurance outcomes.
• Complaint ratios.
• Persistency.
• TCF outcomes.
• Client service standards.

9. COMPLIANCE MEASURES

The Group Risk Manager will ensure:

• Annual policy review.
• Annual ownership verification.
• Annual associate review.
• Maintenance of the COI Register.
• Maintenance of the Gift Register.
• Monitoring of disclosures.
• Staff training.

10. NON-COMPLIANCE

Failure to comply with this policy may result in:

• Corrective action.
• Disciplinary proceedings.
• Removal of authority.
• Debarment proceedings.
• Regulatory reporting.
• Termination of employment or contract.

11. CHANGE MANAGEMENT AND VERSION CONTROL

 Purpose

To ensure that all amendments to this policy are appropriately reviewed, approved, communicated and implemented.

Change Process

Any changes to this policy may be initiated by:

• Directors
• Group Directors
• Group Risk Manager
• Compliance Function
• Internal Audit
• Regulatory changes

All proposed amendments must:

1. Be documented.
2. Include the reason for the change.
3. Identify affected processes.
4. Be reviewed by the Group Risk Manager.
5. Be approved by the Director and Group Directors prior to implementation.

Communication of Changes

Approved changes will be:

• Recorded in the Version Control Register.
• Communicated to affected staff.
• Included in training where required.
• Uploaded to the document repository.

12. POLICY ADOPTION

This policy is adopted and approved by the governing body of Assured Life Consultants (Pty) Ltd.

ANNEXURE A – ASSOCIATES

 ANNEXURE B – GIFT REGISTER

ANNEXURE C – CONFLICT OF INTEREST REGISTER

ANNEXURE D – VERSION CONTROL REGISTER

ANNEXURE E – OWNERSHIP INTERESTS HELD BY ASSURED LIFE CONSULTANTS

Assured Life Consultants does not hold a direct controlling ownership interest in any third party.

The holding company, Financial Wealth Holdings (Pty) Ltd, holds preference shares in Old Mutual Alternative Risk Transfer Limited (OMART) and may receive dividend distributions arising from such ownership.

ANNEXURE F– OWNERSHIP INTERESTS HELD IN ASSURED LIFE CONSULTANTS

 Beneficial Ownership Structure

ANNEXURE G – FINANCIAL INTERESTS AND REMUNERATION

All remuneration structures must support fair client outcomes and comply with FAIS, TCF and applicable legislation.