CONFLICT OF INTEREST MANAGEMENT POLICY

Authorised Financial Services Provider – FSP No. 46313
Effective: 2025

1. Background

1.1
This Conflict of Interest Management Policy outlines how DWD Financial Planners ("the Company") identifies, manages, mitigates and discloses conflicts of interest when rendering financial services to clients. This policy applies to all employees, including directors, key individuals, representatives, contractors, admin staff and any person acting on behalf of the Company.

1.2
The purpose of this policy is to:

  • ensure that client interests always come first
  • prevent undue influence or bias in the financial advice process
  • protect the integrity, independence and objectivity of DWD Financial Planners
  • comply with the Financial Advisory and Intermediary Services Act (FAIS) and the General Code of Conduct, specifically Section 3A

1.3
All employees and representatives are required to understand and comply with this policy. Non-compliance may lead to disciplinary action, which may include suspension, dismissal or removal from office.

1.4
Copies of this policy are available upon request or through the Information/Compliance Officer of DWD Financial Planners.

2. Definitions

The following definitions apply in terms of the FAIS General Code of Conduct:

  • Conflict of Interest: Any situation where a personal or financial interest may influence the objective, fair and unbiased rendering of a financial service to a client.
  • Financial Interest: Any cash, gift, service, benefit, hospitality, sponsorship, fee, commission or other item of monetary value.
  • Ownership Interest: Any equity or proprietary interest held in another company.
  • Third Party: A product supplier, financial services provider, associate, distribution channel or any person that provides a financial interest to the Company or its representatives.
  • Representative: Any person who advises clients or provides intermediary services on behalf of the Company.

3. Responsibilities

3.1 Duty to Avoid, Mitigate and Disclose Conflicts

  • Employees must always act in the best interest of clients.
  • Conflicts must be avoided where possible.
  • Where conflicts cannot be avoided, they must be mitigated, managed, and disclosed.
  • Representatives must maintain independence and objectivity throughout the advice process.

3.2 Duty to Report Conflicts

  • Any actual or potential conflict must be reported immediately to the Compliance Officer.
  • Failure to disclose a conflict may lead to disciplinary action.

3.3 Compliance Officer Responsibilities

The Compliance Officer is responsible for:

  • maintaining the Conflict of Interest Register
  • assessing reported conflicts
  • recommending avoidance or mitigation measures
  • providing staff guidance
  • ensuring adherence to FAIS requirements

4. Identifying, Managing and Disclosing Conflicts of Interest

DWD Financial Planners follows a structured approach:

Step 1 — Identify & Report

Employees must proactively identify:

  • personal financial interests
  • relationships with product suppliers
  • situations where remuneration may influence advice
  • any association that may be perceived to bias a recommendation

All potential conflicts must be reported to the Compliance Officer.

Step 2 — Assess

The Compliance Officer will determine:

  • whether a conflict exists
  • whether it can be avoided
  • if not avoidable, what mitigation is required
  • what disclosures are necessary

All decisions are documented in the Conflict of Interest Register.

Step 3 — Avoid or Mitigate

If feasible, the conflict must be avoided entirely.

Examples of avoidance:

  • declining a gift
  • stopping an activity that creates bias
  • assigning a different representative to the client

If avoidance is not possible, mitigation steps must be implemented:

  • full disclosure to the client
  • enhanced monitoring by management
  • written confirmation of the representative’s impartiality

Step 4 — Disclose to the Client

Disclosure must include:

  • details of the conflict
  • steps taken to mitigate it
  • any financial interest received
  • any ownership interest involved
  • any relationship with a third party

Disclosure must be clear, concise and understandable.

5. Financial Interests, Gifts and Benefits

5.1 Permitted Financial Interests

Representatives may receive:

  • commission authorised under the Long-Term Insurance Act or Medical Schemes Act
  • fees agreed to with the client
  • Immaterial financial interests (not exceeding R1,000 per year from a single third party)

All benefits must be logged in the Immaterial Financial Interest Register.

5.2 Prohibited Financial Interests

Employees may not receive:

  • cash gifts
  • unapproved incentives
  • compensation tied to volume of product sales
  • benefits exceeding R1,000 per year from any product supplier

5.3 Gifts & Hospitality

Gifts may only be accepted if:

  • the value does not exceed R1,000 per third party per year
  • it is not intended to influence advice
  • it is recorded in the Conflict of Interest Register

5.4 Examples of Financial Interests

This includes:

  • vouchers
  • entertainment
  • travel
  • accommodation
  • sponsorships
  • services rendered at no cost
  • discounts not available to the public

6. Representative Remuneration Policy

Remuneration of representatives includes:

  • a fixed salary
  • performance-based bonuses linked to:

    • compliant behaviour

    • quality of advice

    • client service excellence

    • adherence to DWD Financial Planner’s policies

NO representative is remunerated based on the quantity of product sales, nor is any preference given to particular product providers.

7. Ownership Interests & Third Parties

  • DWD Financial Planners does not hold ownership interests in any product supplier.
  • No product supplier holds ownership in DWD Financial Planners.
  • All relationships with third-party providers (insurers, asset managers, investment platforms) are based purely on suitability for clients, not on incentives or commissions.

A full list of approved product providers is available on request.

8. Avoidance Measures & Mitigation Examples

Examples of when conflicts must be disclosed:

  • A representative has a personal relationship with a product supplier.
  • A representative may earn a higher fee from one product than another.
  • A representative or family member holds shares in a product provider.

Examples of mitigation:

  • Rotating client responsibilities
  • Additional oversight by senior staff
  • Documenting all recommendations thoroughly
  • Providing alternative product quotations
  • Ensuring all advice is based on a Client Needs Analysis

9. Record Keeping

DWD Financial Planners keeps:

  • a Conflict of Interest Register
  • a Gifts Register
  • a Remuneration Register
  • training records
  • disclosure documents

Records are maintained for at least 5 years in accordance with FAIS and FICA.

10. Training & Awareness

All employees receive:

  • annual Conflict of Interest training
  • training on FAIS, POPIA, FICA
  • periodic compliance updates

Employees sign annual declarations confirming understanding and adherence.

11. Policy Review

This policy:

  • is reviewed annually
  • may be updated when legislation or business structures change
  • is approved and monitored by Key Individuals and the Compliance Officer

12. Availability of the Policy

This policy is available:

  • on request from the Information/Compliance Officer
  • at the DWD Financial Planners office
  • as part of client disclosures
  • on the company website (if required)

DWD Financial Planners — Protecting Clients Through Transparency, Integrity & Compliance