Conflict of Interest Policy

A conflict of interest can be defined as a situation in which a person has a private or personal interest sufficient to appear to influence the objective exercise of his/her official duties.

In the financial services environment, a conflict of interest means a situation where a FSP or a representative has an actual or potential interest that may influence the objective exercising of obligations to the client or prevent the rendering of financial services in an unbiased and fair manner.

4AM Wealth (Pty) Ltd has implemented this policy to ensure that any financial services we render are always in the interest of our clients and to provide a framework within which to address and identify areas where conflicts may arise.

2.1 Specific Duties: In terms of the General Code of Conduct (as amended by General Notice 706, 26 June 2020), a FSP and a representative must:

• Avoid and where not possible, mitigate any conflict of interest between the FSP and a client
• In writing disclose any conflict of interest in respect of that client
• Include any measures taken to avoid or mitigate the conflict
• Disclose any ownership interest or financial interest
• Describe in sufficient detail the nature of any relationship or arrangement with a third party that gives rise to a conflict
• Inform a client of the conflict-of-interest management policy and how it may be accessed

2.2 Policy Requirement: A conflict of interest management policy must be adopted by the board of directors or senior management of the FSP. The FSP must ensure employees and representatives are aware of its contents, continuously monitor compliance, and annually review the policy. The policy must be published and easily accessible.

2.3 Purpose: This policy assists the FSP, the key individual and its employees to identify potential and actual conflicts of interest and manage them appropriately. The FSP has a duty to remain independent, objective and professional when giving advice or providing intermediary services.

2.4 Penalties for Non-Compliance: Failure to comply with this policy constitutes misconduct and could result in disciplinary action, including termination of employment and/or debarment with the FSCA.

"Associate" means, in relation to a natural person: a spouse, life partner or civil union partner; a child of that person; any other member of that person's immediate family; or a juristic person controlled or managed by such person.

"Conflict of Interest" means any situation in which a provider or representative has an actual or potential interest that may influence the objective exercise of their obligations to a client, or prevent them from rendering an unbiased and fair financial service.

"Financial Interest" means 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; c) a soft commission; or d) limited promotional items.

"Immaterial Financial Interest" means 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.

"Ownership Interest" means any equity or proprietary interest, for which fair value was paid by the owner at the time of the acquisition, other than equity or a proprietary interest held as an approved nominee on behalf of another person.

4.1 Identification of Conflicts: Conflicts of interest are identified through a register of interests maintained by the FSP. Representatives must immediately disclose any actual or potential conflict of interest to the Key Individual. Common situations that may give rise to conflicts include receipt of financial interests from third parties, ownership interests in product providers, and personal relationships with clients or product providers.

4.2 Measures to Avoid and Mitigate: Where possible, conflicts of interest will be avoided entirely. Where avoidance is not possible, the FSP will:

• Disclose the conflict of interest to the client in writing
• Implement measures to mitigate the impact of the conflict
• Record the conflict and measures taken in the Conflicts Register
• Ensure the client's interests are protected throughout

4.3 Managing Conflicts: All conflicts, whether avoided or mitigated, are recorded in the Conflicts of Interest Register and reviewed by the Key Individual on a regular basis.

Where 4AM Wealth receives commission, this is disclosed to clients as required by the FAIS Act and the General Code of Conduct. The FSP does not allow commission structures to influence the financial advice rendered. Where fees are charged in lieu of commission, these are agreed in writing with the client prior to implementation.

4AM Wealth does not accept or pay sign-on bonuses or similar recruitment incentives that could create conflicts of interest with respect to the rendering of financial services.

This policy is reviewed and updated on at least an annual basis by the Key Individual. All registers associated with this policy (conflicts of interest, financial interests, ownership interests, gifts, personal/business interests) are updated and reviewed regularly.