FSP Name: Talksure Trading
FSP Number: 42788
Key Individual: Leonard Chetty
Section 3A (2)(a) of 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 the FSP to identify, mitigate and manage the conflicts of interest to which the FSP 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 Conduct Authority.
In terms of the Financial Advisory and Intermediary Services Act, 2002, the FSP is required maintaining and operating effective organizational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflict of interest. The FSP 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.
Our remuneration policy is described in the Contact Stage Disclosure letter.
Processes and internal controls
Identification of Conflict of interest
To adequately manage conflicts of interest we must identify all relevant conflicts timely. In determining whether there is or may be a conflict of interest to which the policy applies, the FSP considers whether there is a material risk of damage to the client, taking into account whether the FSP or its representative, associate or employee:
Our policy defines possible conflicts of interest as, inter alia:
The FSP 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.
The FSP keeps and maintains a register in which all actual or potential conflicts are recorded.
Mission statement on Conflict of Interest
The FSP is committed to ensuring that all business conducted in accordance with good business practice. To this end, the FSP conducts business in an ethical and equitable manner and in a way that safeguards the interests of all stakeholders to minimize and manage all real and potential conflicts of interests. Like any financial services provider, the FSP is potentially exposed to conflict 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:
Understanding the definitions
Conflict of interest:
AA 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 far service to you or do not act in your interests, including but not limited to:
A Financial Interest:
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:
An Ownership interest:
Has the meaning assigned to it in the financial reporting standards adopted or issued under the Companies Act, 61 of 1973.
What can we receive and/or give
We confirm that we will only receive financial interest from the aforesaid providers in the form of:
All employees, including management, are responsible for identifying specific instances of conflict and are required to notify the key individual of any conflict of interest they become aware of. The key individual will assess the implication 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
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 services in the situation concerned. In all cases, where appropriate and where determinable, the monetary value of non-cash inducements will be disclosed to the client/s.
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.
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
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 the FAIS Act and employment conditions and such 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 individual/s or representative/s for:
(i) Favoring quantity of business over equity of service; or
(ii) Giving preference to a specific product supplier where more than one supplier can be recommended to a client; or
(iii) Giving preference to a specific product of a supplier where more than one product of that supplier can be recommended.
With regards 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 conflict/s arise with regards to any of these prior to entering into any business transaction with you, we undertake to disclose these in the registers below.
The FSP has implemented the following registers:
MEDICAL INSURANCE DISCLAIMER: This is not a medical scheme and the cover is not the same as that of a medical scheme. This policy is not a substitute for medical scheme membership. The benefits are subject to waiting periods and applicable limits. These are outlined in the policy wording which you are required to read and understand. T&Cs apply. The increase would be based on risk and inflation rates. This is not your policy wording and for the full disclaimer please go to www.elixi.co.za/disclaimer-notice
GAP COVER DISCLAIMER: This is not a medical scheme and will not be a substitute for medical scheme membership. It fills the GAP between what is covered by your Medical Aid, and the actual amount charged by your medical practitioner for in-hospital procedures. This is not your policy wording and for the full disclaimer please go to www.elixi.co.za/disclaimer-notice
Please note that the premiums presented on this website are based on the current rates and is subject to an increase which should take place in December 2018. The increase would be based on risk and inflation rates.
Constantia Insurance Company Ltd – an authorised FSP 31111. Talksure Trading (Pty) Ltd – an authorised FSP 42788. Ambledown Financial Services (Pty) Ltd – an authorised FSP 10287.