FAIS Conflict of Interest Management Policy
Blue Strata Trading (Pty) Ltd
In terms of the Financial Advisory and Intermediary Services Act 2002 (the “Act”), a Financial Services provider is required to implement and maintain a Conflict of Interest Management Policy (the “Policy”) which complies with the requirements of Board Notice 58 of 2010. The purpose of this policy is to facilitate internal discovery, elimination/mitigation and disclosure of all real and potential conflicts of interest within the business.
Mechanism for Identification of Conflicts of Interest:
Financial Director to review business on a quarterly basis to identity conflicts.
Quarterly meetings with the external compliance officer/discussion of new and established sources of conflict.
Measures for avoidance and or mitigation of identified conflicts
Identified Conflicts and their mitigation measures are as follows:
- Investec is a 48.5% shareholder in the business as well as a Forex service provider to the business. However the conflict has been mitigated as the forex rates are market-related and constantly monitored against independent information sources and other service providers.
- Cell-captive for short-term insurance has been executed with Guardrisk, which is intermediated to clients. This conflict has been mitigated as the policy is market-related in terms of both price and terms. The relationship itself has additionally been disclosed.
Processes, Policies and Internal Controls to facilitate Compliance with the Policy:
The Financial Director is ultimately responsible for ensuring annual review of Insurance terms and pricing and daily review of Forex pricing.
Consequences of Non- compliance with the Policy:
Disciplinary action will be taken against the non-compliant individual in terms of BS’s internal processes, both formal and informal.
Basis and Type of Financial Interest that a representative will qualify for (must be compliant with s3A(1)(b) of the General Code of Conduct) :
Salaries are paid to representatives. Fees charged for services are disclosed in writing to clients.
List of Associates:
List of Third Parties Provider holds an Ownership Interest In (include nature and extent of ownership):
Names of Third Parties that hold an ownership in the Provider (include nature and extent of ownership):