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Conflict Of Interest

FSP Name: Global Risk Management
FSP Number: 45186
Date: 15/03/2021

A conflict of interest is any situation in which a provider or a representative has an actual or potential interest that may, in rendering a financial service to a client (a) influence the objective performance of his, her, or its obligation to the client or (b) prevent a provider or representative from rendering an unbiased and fair financial service to that client, or from (i) a financial interest; (ii) an ownership interest; (iii) any relationship with a third party.

1. PURPOSE AND SCOPE

The purpose of this Conflict of Interest Policy is to outline a suitable approach and response to the identification and management of conflicts of interest. This policy is intended to comply with the procedures prescribed in Financial Services Board Notice 58 of 2010 which amends the General Code of Conduct for Financial Services Providers and Representatives published in Board Notice 80 of 2003, as amended by Board Notice 43 of 2008.

All applicable FSP's are financial services providers, and regulated by the Financial Advisory and Intermediary Services Act, 37 of 2002 (FAIS Act). The purpose of this policy is to comply with the procedures described in Board Notice 58 of 2010.

conflict of interest is any situation in which a provider or a representative has an actual or 2. DEFINITIONS

"Associate"

a) in relation to a natural person, means –

 

 

 

b) in relation to a juristic person –

 

c) in relation to any person –

i) means any juristic person of which the board of directors or members, or in the case where such juristic person is not a company or close corporation, of which the governing body is accustomed to act in accordance with the directions or instructions of the person first-mentioned in this paragraph;

ii) includes any trust controlled or administered by that person.

"Client"

A specific person or group of persons, excluding the general public, who is or may become subject to a financial service rendered intentionally by the FSP's

"Conflict of interest" means any situation in which a provider or a representative has an actual or potential interest that may, in rendering a financial service to a client –

 

"Distribution Channel"

 

"Financial Interest"

A financial interest includes cash, a cash equivalent, voucher, gift, services, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, other incentive, or valuable consideration other than:

 

"FSP"

Financial Services Provider authorised in terms of the Financial Advisory and Intermediary Services Act, 37 of 2002.

"Immaterial Financial Interest"

Any financial interest with a determinable monetary value, the aggregate of which does not exceed R1000 in any calendar year from the same third party in that calendar year, received by:

 

"Ownership Interest"

 

"Product Supplier"

Any person or juristic person who issues a financial product by virtue of an authority, approval or right granted to such person or juristic person under any law.

"Product Provider”

An authorised FSP registered as such with the FSB.

"Responsible Person"

A key individual, representative or employee of a Product Supplier or FSP.

"Third Party"

 

 

 

3. Objectives

GRM is an authorised financial services provider. Like any financial services provider, GRM is potentially exposed to conflicts of interest in relation to various activities. However, the protection of our clients' interests is our primary concern and so our policy sets out how:

 

4. Conflict of Interest

GRM strives towards ensuring it is able to appropriately and effectively identify and manage potential conflicts. It may manage potential conflicts through avoidance, establishing confidentiality barriers and by providing appropriate disclosure of the conflict to affected clients.

In determining whether there is or may be a conflict of interest to which the policy applies, it needs to be determined whether there is a material risk of damage to the client, taking into account whether GRM or a GRM representative, associate or employee:

 

5. Management

Specific monetary measures GRM focuses on include:

 

The measures GRM has adopted to manage identified conflicts are further summarized below. We consider them appropriate to our efforts to take reasonable care that, in relation to each identified potential conflict of interest, we act impartially to avoid a material risk of harming clients' interests:

 

 

 

6. Particular Management Measures

Identification of conflict of interest:

 

Avoidance of conflict of interest:

 

7. Consequences of Non-compliance with the Policy

In the event of non-compliance with the abovementioned terms of the Policy, in addition to any civil or criminal consequences, employees and representatives will be subject to appropriate disciplinary action