Section 3A(2)(a) of the General Code of Conduct stipulates that every provider, other than a representative, must adopt, maintain and implement a conflict of interest management policy that complies with the provisions of the Act. The policy is to provide for mechanisms in place at Edge Financial Group to identify, mitigate and manage the conflicts of interest to which Edge Financial Group is a party. This Conflict of Interest Management Policy is designed as prescribed in Board Notice 58 of 2010 which amends the General Code of Conduct for Financial Services Providers and Representatives published in Board Notice 80 of 2003, as amended by Board Notice 43 of 2008.
This Conflict of Interest Management Policy does not change our existing conflict of management procedures but intends to document them in simple form as required by the Financial Services Board.
In terms of the Financial Advisory and Intermediary Services Act, 2002, Edge Financial Group is required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflict of interest. Edge Financial Group has put in place a policy to safeguard its clients’ interests and ensure fair treatment of clients.
All providers, key individuals, representatives, associates and administrative personnel will commit to such policy and the
processes will be monitored on an ongoing basis.
Edge Financial Group keeps and maintains a register in which all actual or potential conflicts are recorded.
Edge Financial Group is committed to ensuring that all business is conducted in accordance with good business practice. To this end Edge Financial Group conducts business in an ethical and equitable manner and in a way that safeguards the interests of all stakeholders to minimise and manage all real and potential conflicts of interests. Like any financial services provider, Edge Financial Group is potentially exposed to conflicts of interest in relation to various activities. However, the protection of our clients’ interests is our primary concern and so our policy sets out how:
A conflict of interest may occur when in rendering a financial service to you we do not act objectively or do not render an unbiased or fair service to you or do not act in your interests, including but not limited to:
Any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, valuable consideration, other incentive or valuable consideration (exceeding R1000 per annum)other than –
Has the meaning assigned to it in the financial reporting standards adopted or issued under the Companies Act, 61 of 1973.
We confirm that we will only receive financial interest from the aforesaid providers in the form of:
Our remuneration policy is described in the Contact Stage Disclosure letter.
Identification of Conflict of Interest
To adequately manage conflicts of interest we must identify all relevant conflicts timeously. In determining whether there is or may be a conflict of interest to which the policy applies, Edge Financial Group considers whether there is a material risk of damage to the client, taking into account whether Edge Financial Group or its representative, associate or employee:
is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
has a financial or other incentive to favour the interest of another client, group of clients or any other third party over the interests of the client;
receives or will receive from a person other than the client, an inducement in relation to a service provided to the client in the form of monies, goods or services, other than the legislated commission or reasonable fee for that service.
Our policy defines possible conflicts of interest as, inter alia:
conflicts of interest between Edge Financial Group and the client;
conflicts of interest between our clients if we are acting for different clients and the different interests conflict materially;
conflicts of interest where associates, product suppliers, distribution channels or any other third party is involved in the rendering of a financial service to a client;
holding confidential information on clients which, if we would disclose or use, would affect the advice or services provided to clients. we may only receive commissions authorised in terms of applicable legislation.
Edge Financial Group maintains an Index of potential conflict risks, taking into consideration all business areas and income streams. The index is updated with all new conflicts identified, and to ensure completeness is reviewed on an annual basis.
All employees, including internal compliance officers and management, are responsible for identifying specific instances of conflict and are required to notify the Key Individual of any conflicts they become aware of. The Key Individual will assess the implications of the conflict and how the conflict should be managed and act impartially to avoid a material risk of harming clients’ interests.
Create awareness and knowledge of applicable stipulations of the General Code of Conduct and relevant legislation relating to conflict of interest, through training and educational material.
Ensure understanding and adoption of conflict of interest policy and management measures by all employees, representatives and associates.
Regular inspections on all commissions, remuneration, fees and financial interests proposed or received in order to avoid non-compliance.
Keep a register of conflict of interest.
Once a conflict of interest has been identified it needs to be appropriately and adequately managed.
The Key Individual will assess each conflict, including whether the conflict is actual or perceived, what the value of the conflict or exposure is and the potential reputational risk. Compliance and management then agree on the controls that need to be put in place to manage the conflict.
Where there is no other way of managing a conflict, or where the measures in place do not sufficiently protect clients’ interests, the conflict must be disclosed to allow clients to make an informed decision on whether to continue using our service in the situation concerned. In all cases, where appropriate and where determinable, the monetary value of non-cash inducements will be disclosed to clients.
We will publish our conflict of interest management policy in appropriate media and ensure that it is easily accessible for public inspection at all reasonable times.
We may decline to act for a client in cases where we believe the conflict of interest cannot be managed in any other way.
This policy will be reviewed annually, and must be included in your annual FSB compliance report, containing details “…on a least the implementation, monitoring and compliance with, and the accessibility of the conflict of interest management policy.”
The key individual or staff member in charge of supervision and monitoring of this policy will regularly monitor and assess all related matters.
All employees and representatives are required to read Board Notice 58 of 2010 as well as this policy and to sign a statement to the effect that they have done so and fully understand the provisions of both documents and the application thereof.
Comprehensive training on the Conflict of Interest policy will be provided to all employees and representatives as part of general FAIS training or specifically.
Training will be incorporated as part of all new appointees’ induction and refresher training provided on an annual basis.
The Key Individual will conduct ad hoc checks on business transactions to ensure the policy has been complied with.
The Compliance Officer will include monitoring of the Conflict of Interest policy as part of his general monitoring duties and will report thereon in the annual compliance report.
Non-compliance will be subject to disciplinary procedures in terms of FAIS and employment conditions and can ultimately result in debarment or dismissal as applicable.
Avoidance, limitation or circumvention of this policy via an associate will be deemed non-compliance.
This policy shall be reviewed annually and updated if applicable.
We confirm we will not offer any financial interest to our key individuals or representatives for-
With regard to existing third party relationships, being the product suppliers listed in our Contact Stage Disclosure letter, we confirm that we do not have an ownership interest or are subject to exclusive training nor are there any other circumstances which could lead to a potential conflict of interest. Should any conflicts arise with regard to any of these prior to entering into any business transaction with you we undertake to disclose these in the registers below.
Edge Financial Group has implemented the registers below:
At Edge, we do not underestimate the power of vision. We believe that one of our greatest achievements lies in the Quality of our Service. Our motto is "Keeping the end in mind", this does not only apply to our investment principles and future planning principles, but also to our principles regarding service, and what we can uniquely offer our clients.