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.