Conflict of Interest Management Policy

1. Scope

This policy applies to all employees or future employees and contractors of Asuer. Conflicts of interest referred to in this document may either be recognised (actually identified / realised) or be potential or perceived (conceivable) and most often arise because of an actual or possible financial interest.

2. Purpose

The purpose of this policy is to assist individuals with identifying potential and actual conflicts of interest and for Asuer to manage them appropriately.

It provides clear guidelines and rules, and describes the procedures to be followed to ensure that conflict of interest situations do not cause Asuer to act in contravention of the Financial Advisory and Intermediary Services Act ("FAIS") and General Code of Conduct, which requires that a provider must at all times render financial services honestly, fairly, with due skill, care and diligence, and in the interests of clients and the integrity of the financial services industry.

3. Policy

Asuer is committed to avoiding and where this is not possible mitigating any conflict of interest that may arise between ourselves, as a financial services provider, and our clients when rendering a financial service. Where such a conflict of interest cannot be avoided, the situation will be explained to the affected client(s).

3.1 Allowable financial interests

The following allowable financial interests have to be disclosed internally in the company's gift register:

• Promotional items (with a value of no more than R1 000 per FAIS representative / key individual in any given year); and
• any other financial interest with a determinable monetary value not exceeding R1 000 per FAIS representative / key individual in any given year.

The following allowable financial interests have to be disclosed internally in the company's conflicts of interest register and directly and unequivocally to affected clients:

• Ownership interest;
• Directorships in other companies; and
• Rebates or fees received from product providers and which affect the fee payable by the client or which could potentially influence the advice process.

3.2 Disallowed financial interests

The following financial interests are disallowed:

• Financial interest to a representative or to the provider for giving preference to a quantity of business to the exclusion of quality to the client, preference to a specific product supplier or preference to a specific product;
• Cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship and any other incentive or valuable consideration not mentioned above, including travel and accommodation associated with allowed training;
• Any financial interest other than allowable financial interests listed above with a determinable monetary value exceeding R1 000 per FAIS representative / key individual in any given year; and
• Training restricted to a selected group of providers and FAIS Representatives on (including but not limited to) products and legalities thereof, general financial and industry information, and specialised technological systems (of a third party) necessary for rendering a financial service.

4. Procedure

4.1 Reporting and record keeping

• Both a Gifts Register for allowable financial interests and a Conflicts of Interest Register for ownership interests, directorships and disallowed financial interests have been implemented.
• The Company's Key Individual will act as the custodian of both registers.
• Each Representative has a duty to report any such financial interest provided or received to the custodian of the Gifts Register (within a week of giving / receiving such a gift), who shall report to the Managing Director as soon as the aggregate financial interest given or received by any one representative from that product provider or third party reaches R1 000 in that particular year.

4.2 Key Individual authorisation

A financial interest with a monetary value of more than R1 000.01 constitutes a material conflict. Prior to giving or accepting such a financial interest, the employee or Representative must obtain the written consent of the Managing Director of Asuer for the gift. Such an instance must be recorded in the relevant Conflict of Interest register.

4.3 Annual Key Individual and Representative disclosure

• All Key Individuals and Representatives are required to complete the Conflicts of Interest Questionnaire annually.
• The conflict of interest register is updated and reviewed by the Key Individual(s).
• If it has been established that a particular situation or activity gives rise to a conflict of interest, such a situation must be avoided.
• If such a conflict of interest is inevitable it is the responsibility of the Managing Director to ensure that the effect of the conflict is mitigated by disclosing the conflict of interest to the relevant client(s).

4.4 Further reporting

All activities that resulted in conflict of interest situations must be reported to the company's compliance officer on a bi-annual basis.

5. Record keeping

Declarations and relevant registers will be stored securely for future reference.

6. Consequences of non-adherence

Violation of this policy and procedures described herein will result in appropriate disciplinary action.

7. Training and awareness

All staff will receive training on this policy and related requirements.

8. Review

This policy shall be reviewed annually and any changes to this policy shall be communicated to all staff.

9. Annexures

• Annexure A1: Gifts Register: Gifts Received
• Annexure A2: Gifts Register: Gifts Given
• Annexure B: Conflicts of Interest Register
• Annexure C: Conflicts of Interest Questionnaire