Conflict of Interest

Premier Wealth Solutions

Conflict of Interest Management Policy

Background

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.

Object Of The Policy

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.

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.

Mission Statement On Conflict of Interest

Edge Financial Group is committed to ensuring that all business is conducted in accordance with good business practice.

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:

We will identify circumstances which may give rise to actual or potential conflicts of interest entailing a material risk of damage to our clients’ interests;

We have established appropriate structures and systems to manage those conflicts; and

We will maintain systems in an effort to prevent damage to our clients’ interests through identified conflict of interest

Fair Value

Has the meaning assigned to it in the financial reporting standards adopted or issued under the Companies Act, 61 of 1973.

WHAT MAY WE GIVE AND RECEIVE

We confirm that we will only receive financial interest from the aforesaid providers in the form of:

Commission authorized under the Long-term Insurance Act, 52 of 1998;
Commission authorized under the Short-term Insurance Act, 53 of 1998;
Commission authorized under the Medical Schemes Act, 131 of 1998;
Fees under the aforesaid acts if these fees are reasonably commensurate to the service being rendered;
Fees for rendering a financial service in respect of which no commission or fees are paid as aforesaid, if those fees are specifically agreed to by you in writing and may be stopped at your discretion;
Fees or remuneration for the rendering of a service to a third party, which fees are reasonably commensurate to the service being rendered;
Subject to any other law, an immaterial financial interest;
A financial interest for which a consideration, fair value or remuneration that is reasonably commensurate to the value of the financial interest, is paid at the time of receipt thereof.

REMUNERATION POLICY

Our remuneration policy is described in the Contact Stage Disclosure letter.

PROCESSES AND INTERNAL CONTROLS

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.

MEASUREMENT FOR AVOIDANCE AND MITIGATION OF CONFLICT OF 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.

Disclosure:

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.

Declining to act:

We may decline to act for a client in cases where we believe the conflict of interest cannot be managed in any other way.

Publication:

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.

ONGOING MONITORING OF CONFLICT OF INTEREST MANAGEMENT

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.

TRAINING AND STAFF

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.

REPRESENTATIVE INCENTIVES

We confirm we will not offer any financial interest to our key individuals or representatives for-

favouring quantity of business over quality of service; or
giving preference to a specific product supplier where more than one supplier can be recommended to a client; or
giving preference to a specific product of a supplier where more than one product of that supplier can be recommended.

REGISTERS:

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:

Nature and Extent of Ownership interests
Financial Interest Received
Nature and Extent of Business Relationships
Associations

Resource Centre

Our team of specialists want you to be informed before making any decisions, below are just some links to get you started before contacting our team.