In accordance with the Financial Advisory and Intermediary Act (FAIS), as Amended, Affinity Underwriting Managers (Pty) Ltd, as an Authorized Financial Services Provider, upholds the obligation to maintain a Conflict of Interest policy. This policy serves to safeguard the fairness of our services towards our valued clients.

At Affinity Underwriting Managers, we are dedicated to promoting principles of fairness and impartiality in all our dealings. We prioritize the best interests of our clients and stakeholders, ensuring that our services are conducted with integrity and transparency.

In line with this commitment, the Directors of Affinity Underwriting Managers (Pty) Ltd have formally adopted a Conflict of Interest Management Policy. This policy serves as a guiding framework across all facets of our operations.

To uphold the integrity of our services, this Policy undergoes regular review by our directors, ensuring its continued relevance in light of evolving circumstances or legislative changes. Our dedication to maintaining the highest standards of ethical conduct remains unwavering, and this Policy reaffirms our commitment to fair and equitable service delivery to all our clients and stakeholders.

Definitions

Associate
(a) in relation to a natural person, means:
     (i) a person who is recognised in law or the tenets of religion as the spouse, life partner or civil union partner of that person;
     (ii) a child of that person, including a stepchild, adopted child and a child born out of wedlock;
     (iii) a parent or stepparent of that person;
     (iv) a person in respect of which that person is recognised in law or appointed by a Court as the person legally responsible for managing the affairs of or meeting the                   daily care needs of the first mentioned person;
     (v) a person who is the spouse, life partner or civil union partner of a person referred to in sub-paragraphs (ii) to (iv);
     (vi) a person who is in a commercial partnership with that person;
(b) in relation to a juristic person:
     (i) which is a company, means any subsidiary or holding company of   that company, any other subsidiary of that holding company and any other company of which that           holding company is a subsidiary;
    (ii) which is a close corporation registered under the Close Corporations Act, 1984 (Act 69 of 1984), means any member thereof as defined in section 1 of that Act;
    (iii) which is not a company or a close corporation as referred to in sub-paragraphs (i) or (ii), means another juristic person which would have been a subsidiary or                        holding company of the first-mentioned juristic person:
          (aa) had such first-mentioned juristic person been a company; or
          (bb) in the case where that other juristic person, too, is not a company, had both the first-mentioned juristic person and that other juristic person been a company;
    (iv) means any person in accordance with whose directions or instructions the board of directors of or, in the case where such juristic person is not a company, the                      governing body of such juristic person is accustomed to act;
(c) in relation to any person:
     (i) means any juristic person of which the board of directors or, in the case where such juristic person is not a company, of which the governing body is accustomed to                act in accordance with the directions or instructions of the person first-mentioned in this paragraph;
     (ii) includes any trust controlled or administered by that person.             

Conflict of Interest
Any situation in which a provider or a representative has an actual or potential interest that may, in rendering a financial service to a client: (a) influence the objective performance of his, her or its obligations to that client; or (b) prevent a provider or representative from rendering an unbiased and fair financial service to that client, or from acting in the interests of that client, including, but not limited to:
    (i) a financial interest;
    (ii) an ownership interest;
    (iii) any relationship with a third party.  

Distribution channel
(a) any arrangement between a product supplier or any of its associates and one or more providers or any of its associates in terms of which arrangement any support or service is provided to the provider or providers in rendering a financial service to a client;  
(b) any arrangement between two or more providers or any of their associates, which arrangement facilitates, supports or enhances a relationship between the provider or providers and a product supplier.  
(c) any arrangement between two or more product suppliers or any of their associates, which arrangement facilitates, supports or enhances a relationship between a provider or providers and a product supplier.  

Financial Interest  
Any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, other incentive or valuable consideration, other than:
(a) an ownership interest; 
(b) training, that is not exclusively available to a selected group of providers or representatives, on:
    (i) products and legal matters relating to those products;
    (ii) general financial and industry information;
    (iii) specialised technological systems of a third party necessary for the rendering of a financial service; but excluding travel and accommodation associated with that                  training.
(c) a qualifying enterprise development contribution to a qualifying beneficiary entity by a provider that is a measured entity.   

Immaterial financial interest  
Any financial interest with a determinable monetary value, the aggregate of which does not exceed R1 000 in any calendar year from the same third party in that calendar year received by: 
(a) a provider who is a sole proprietor; or 
(b) a representative for that representative’s direct benefit; 
(c) a provider, who for its benefit or that of some or all of its representatives, aggregates the immaterial financial interest paid to its representatives.

Identification, Avoidance, Management and dissclosure of Conflict of Interest

In terms of the FAIS General Code of Conduct (as amended) Affinity Underwriting Managers (Pty) Ltd  may not receive a financial interest other than that prescribed in the legislation under which it is authorised and regulated or any fee not commensurate with the service being offered as prescribed in the legislation  

Nor may we, in the provision of Advice or Intermediary Services, benefit from associations as described in the Act  

In the event that a material financial interest is received, this must immediately be reported to the Key Individual and Compliance Officer and must be disclosed to all affected clients in the manner prescribed by Board Notice 58 of 2010  

Receipt of any such financial interest will be a material contravention of the FAIS act as well as the employment conditions of Affinity Underwriting Managers (Pty) Ltd and will be considered to be a material contravention of the FAIS Act.  

The Management and Representatives must avoid, and where this is not possible mitigate, any conflict of interest between Affinity Underwriting Managers (Pty) Ltd and a client or the representative and a client as follows;      

In writing, at the earliest reasonable opportunity —
    (i) disclose to a client any conflict of interest in respect of that client, including — 
        (aa) the measures taken, in accordance with the conflict of interest management policy to avoid or mitigate the conflict; 
        (bb) any ownership interest or financial interest, other than an immaterial financial interest, that the provider or representative may be or become eligible for; 
        (cc) the nature of any relationship or arrangement with a third party that gives rise to a conflict of interest, in sufficient detail to a client to enable the client to                                 understand the exact nature of the relationship or arrangement and the conflict of interest; and
     (ii) inform a client of the conflict of interest management policy of Affinity Underwriting Managers (Pty) Ltd and how it may be accessed.    

Any Immaterial Financial Interest (i.e. less than R1,000 per calendar year received from one Provider) is required to be listed immediately in the Conflict of Interest Register which is held by the Key Individual, Geoffrey Temlett

Associations with Financial Product and Services Suppliers

The financial product and services suppliers as well as the distribution channels that are used to enable appropriate financial products and efficient delivery of the services we provide are registered as Financial Services Providers (FSP’s).

All the relationships, distribution channels and associations in respect of Financial Products  adhere to the remuneration regulations contained in the legislation under which Affinity Underwriting Managers (Pty) Ltd is registered.  

Affinity Underwriting Managers (Pty) Ltd has no association, as defined, in any of the Financial Products or Services Providers that we have agreements with.  

The Directors of Affinity Underwriting Managers (Pty) Ltd have directorships in Financial Services Providers which are not a part of its distribution channels and do not receive remuneration other than remuneration in accordance with ownership interests

Remuneration

In accordance with the Act, Affinity Underwriting Managers (Pty) Ltd will not remunerate any of its representatives for;
    (i) giving preference to the quantity of business secured for the provider to the exclusion of the quality of the service rendered to clients; or  
    (ii) giving preference to a specific product supplier, where a representative may recommend more than one product supplier to a client; or  
    (iii) giving preference to a specific product of a product supplier, where a representative may recommend more than one product of that product supplier to a client.

Implementation and Monitoring of Compliance 

Agreements with financial product suppliers and services providers are held in our offices and monitored by our external Compliance Officer to ensure that the remuneration for costs of service are compliant with the legislation under which we are licenced.  

Persons employed or acting on behalf of Affinity Underwriting Managers (Pty) Ltd are provided with a copy of the Conflict of Interest Policy and complete an annual declaration of honesty, integrity and disclosure of potential conflicts of interest  

Acceptance of any immaterial benefit, as defined, must be authorised by a manager written up in the Gift Register which is monitored by our external Compliance Officer on a monthly basis  

Acceptance directly or indirectly of any material benefit, as defined, is forbidden in terms of the employment or contract agreements and any offer of such must be reported to the Key Individual and Compliance Officer.

Contravention of this Policy

A contravention of this policy by any employee will result in disciplinary action and reported to the Authority as prescribed in the relevant legislation

Accessibility

A copy of the Conflict of Interest Policy is accesable on request at our offices during business hours and a copy is linked to our website www.affinityum.co.za