FAIS Conflict of Interest Management Policy

For

Blue Strata Trading (Pty) Ltd


Introduction:

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.

  1. 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.

  2. Measures for avoidance and or mitigation of identified conflicts

    Identified Conflicts and their mitigation measures are as follows:

    1. 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.
    2. 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.

  3. 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.

  4. 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.

  5. 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.

  6. List of Associates:

    1. Guardrisk
    2. Investec

  7. List of Third Parties Provider holds an Ownership Interest In (include nature and extent of ownership):

    N/a

  8. Names of Third Parties that hold an ownership in the Provider (include nature and extent of ownership):

    1. Investec