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CONFLICT OF INTEREST POLICY

Introduction

This policy sets out your responsibilities for identifying and managing actual and potential conflicts of interest when acting on behalf of Talksure.

Objective

The objective of this policy is to ensure that Talksure and its employees are protected in the event of conflicts or perceived conflicts of interest arising. The document is intended to clearly define such conflict and detail and communicate the process for declaring and managing potential conflicts. The “Conflict of interest for Financial Services” policy, which is attached as Annexure A to this policy deals with conflicts of interest which may arise in respect of Talksure as a financial services provider and in instances where its employees may be conflicted in the provision of financial advice and intermediary services to Talksure’s customers.

Scope

This document applies to all employees including the executive and non-executive directors of Talksure and outlines the procedure to be followed by employees and directors in disclosing conflicts of interests and in how conflicts of interest are reviewed and dealt with.

Definitions

Conflict of Interest:

Responsibilities

All employees must perform their functions for the benefit and interest of Talksure as a whole.

No employee may enter into any transaction, which may undermine his/her, independence and objectivity in conducting business transactions.

All employees must conduct business in a transparent and ethical manner.

Consequences of Non-compliance

Failure to disclose or report a conflict of interest or potential conflict of interest constitutes a breach of fiduciary duties owed to Talksure and the Talksure Code of Conduct and will result in disciplinary action, which may lead to dismissal.

Reporting a Conflict of Interest or Potential Conflict of Interest

Reviewing the Declarations

Record-keeping

Rights and Responsibilities

Training

The Ethics Officer will be responsible for the training of all staff in respect of conflicts of interests, including examples or possible conflicts of interest that may emerge with clients or with Talksure business interests.

Confidentiality

All parties are obliged to protect the confidentiality of information pertaining to the declaration, unless they are compelled to release such by operation of law. In all other instances, the prior permission of the employee will be requested if the information is required to be disclosed to other persons.

CONFLICT OF INTEREST POLICY FOR FINANCIAL SERVICES

Introduction

This document serves as an annexure to Talksure Trading’s internal Conflict of Interest Policy (COI) and outlines Talksure’s responsibility as a financial services provider.

The General Code of Conduct for Authorised Financial Services Providers and Representatives (“General Code”) in terms of section 15 of the Financial Advisory and Intermediary Services Act 37 of 2002 (“FAIS”) requires the Company to implement a Conflicts of Interest Policy, to make it available to Clients and to ensure controls are in place to avoid and/or manage all Conflicts of Interest when dealing with Clients.

This annexure provides clarity as to what constitutes a Conflict of Interest for FAIS and the process to follow when a Conflict of Interest has been identified. Conflicts of Interest should be avoided as far as possible, if this is not possible then Talksure Trading must implement mitigation controls to manage such risks and properly disclose such risks to Clients to ultimately ensure the fair treatment of Clients at all times

Definitions

A Conflict of Interest as defined in section 4 of the policy is extended to include any situation in which a provider or a representative has an actual or potential interest that may, in the rendering a financial service to a client, either:

Reporting a Conflict of Interest or Potential Conflict of Interest

The Ethics Officer has an obligation to:

COI identification will include contracts, proposed contracts and similar transactions or arrangements and gifts, hospitality and inducements. These must be recorded appropriately on a register.

Roles and Responsibilities

The following key areas are important to ensure that Conflicts of Interests are properly addressed in the business of the Company:

Board: The Chief Executive and Company Secretary is ultimately responsible to ensure compliance with FAIS as one of the key pieces of legislation applicable to its business. Conflicts of interest will become a standing agenda item for Board and Management meetings. Procedures will be drafted and adopted to form part of the compliance documentation so as to ensure that Conflicts of Interests are properly addressed within the business.

Key Individual: The Key Individual is responsible for the internal oversight function to implement appropriate processes and procedures for the effective risk management of conflicts of interest and other risks arising within the Company. The Key Individual is responsible for the implementation of the conflicts management policies, procedures and controls to enable the Company to manage conflicts effectively, as highlighted by the Ethics Officer. The Key Individual is also responsible for identifying, recording and managing conflicts of interest within the business. He/she must keep adequate records of the management process, from the identification through to the effective resolution of the conflict.

Compliance: FSCA appointed compliance officer, as compliance officer of the Company is available to assist in the handling of any identified conflict relating to the business of the Company. This may involve assessing and evaluating the conflict within the Company and deciding upon the appropriate response to the conflict. FSCA appointed compliance officer will ensure conflict-monitoring procedures are in place to ensure that any noncompliance with the Company’s conflicts management arrangements are identified and appropriately acted on appropriately.

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