Conflict of Interest Policy
In terms of Board Notice no. 58 of 2010, published on 19 April 2010 every Provider (other than a Representative) must adopt,
maintain and implement a conflict of interest management policy that complies with the provisions of FAIS.
- “Conflict of interest” is defined as being any situation in which a Provider or a Representative has an actual or potential
interest which may when rendering a financial service to a client;
- a) influence the objective performance of obligations to a client; or
- b) prevent the Provider or Representative from rendering unbiased financial service to a client or from acting in the
interest of a client.
- It should be noted that such interest may be direct or indirect and include;
- 1) a financial interest
- 2) an ownership interest
- 3) any relationship with a third party
In order to ensure that Lion of Africa Fund Managers (LOAFM), its shareholders, Key Individuals, employees or agents observe
the utmost good faith and exercise proper care and diligence when investing, holding, keeping in safe custody, controlling or
administrating all funds of clients such persons may not alienate, invest, pledge, hypothecate or otherwise encumber or make
use of client funds or trust property or in any way furnish any guarantees designed to gain directly or indirectly any improper
advantage for himself/herself or for any other person to the prejudice of the client.
Any breach of the above requirement will lead to the instant dismissal of the staff member concerned. The independent Compliance
Officer must be immediately advised of any such breach for the purpose of advising the Registrar to amend the appropriate register.
All Directors, Members, Key Individuals or Representative of LOAFM who take part in any decision to invest the funds of a client
in any company or other undertaking in which he/she has a direct or indirect interest, must declare that interest in writing to
the Board of Directors of LOAFM indicating the nature and extent of such interest, before any such decision is made.
The declarations made in this regard must be reflected in the minutes of the meeting of the Directors of LOAFM . The Chief Investment
Officer has an obligation to review all such declarations and amendments thereto, at an interval of not more than 1 month.
In order to assist in the identification of any potential conflict of interest as defined, all Key Individuals and Representatives of
LOAFM are required to conduct all personal trading through a stock broker nominated by LOAFM. All Key Individuals and Representative
must agree that the nominated stock broker be permitted to provide LOAFM with detailed trading schedules of each Key Individual
and/or Representative.
All Key Individuals and/or Representatives who have any interest in any financial product in which the client is trading are prohibited
from trading therein until such time that all orders pertaining to the client have been completed. Where a decision has to be made by
a client with respect to his investments (i.e. a non discretionary client or an advice only client) the client must be fully advised of
the interest that the Key Individual and/or Representative holds in the financial product concerned. Such disclosure to the client should
be in writing and preferably counter signed by the client and thereafter minuted by the Directors of LOAFM.
Representatives of LOAFM may qualify for a proportion of the upfront fee payable to LOAFM by the clients. This fee is payable by the
client irrespective of the product supplier utilized in affecting the clients investments and therefore cannot be motivated by any preference
for any specific product supplier.
The Directors of LOAFM are Fred Robertson, Brain Molefe and Nisaar Pangarker. The Key Individuals of LOAFM are Nisaar Pangarker, Sidney Mckinnon
and Brian Molefe. Commlife Holdings (Pty) Ltd is hereby named as an associate in keeping with the definition included in the General Code of
Conduct as published. It should be noted that LOAFM does not hold any interest in the ownership of any third party. It should be noted however
that ultimate beneficial owner of Commlife Holdings(Pty) Ltd is the Robatsi Family Trust.
A copy of this Conflict of Interest Management Policy is available for inspection at the offices of LOAFM at1st Floor building D, The Boulevard
Office Park, Searle Street Woodstock, Cape Town during normal business hours.
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