Conflict of Interest

Introduction:

As a financial services provider 40410 INSURE (Pty) Ltd (FSP 43212) needs to take all necessary steps to guard against any practices and/or services that could create a conflict between their interests and the interests of an existing or potential customer.

A conflict of interest is any situation where 40410 INSURE or their employees, including contact centre staff members, have an interest that might influence the objective performance of their obligations to a customer or where it prevents them providing an unbiased and fair financial service.

This could include receiving a wide range of financial and non-financial benefits, ownership interests based on the relationship or service provided for a third party.

Where it is not possible to avoid any act, action or benefit that might create a potential conflict of interest, steps must be taken to minimise the impact and it must be appropriately disclosed to the customer at the earliest reasonable opportunity.

This Policy details how any such conflicts of interests will be managed including:

  • the controls in place to identify potential or actual conflicts,
  • the controls for avoiding or where necessary the disclosure of conflicts of interest,
  • processes and procedures for making sure this Policy is followed, and
  • the consequences of not complying with the Policy.

The Policy also contains details of the types of financial interests an 40410 INSURE representative receives and the basis on which it is received.

The Policy also contains a list of all associates of 40410 INSURE and third parties in which 40410 INSURE holds an ownership interest or that hold an ownership interest in 40410 INSURE.

How we identify possible conflicts of interest

  • 40410 INSURE has developed the following processes to identify conflicts of interest:
  • An analysis of all customer -acing areas within 40410 INSURE has taken place;
  • The types of financial interests received/offered have been identified and analysed;
  • Structures have been put in place around the receipt/offering of financial interests;
  • All remuneration models for the employees are reviewed by the 40410 INSURE leadership team.
  • Remuneration for contact centre staff members is assessed against allowable fee structures;
  • Appropriate training has been developed to enable employees to identify any potential or actual conflict of interest situations.
  • Quarterly and annual reviews of these processes are included in 40410 INSURE’s Risk and Compliance monitoring schedule to ensure that any conflicts of interest that arise are identified.

Avoiding and/or disclosing conflicts:

40410 INSURE’s provides specific training and educational material on how conflicts of interest may arise and how it can be avoided to all new employees. Training has also been provided to all existing employees.

Where a conflict of interest cannot be avoided, 40410 INSURE’s consultants are required to disclosure the conflict to customers at the earliest reasonable opportunity, together with the steps taken to manage the situation.

Every existing and potential customer has the right to ask 40410 INSURE employees for these disclosure details. A (potential) customer’s rights (or potential rights) and the protection offered under the Financial Advisory and Intermediary Services (FAIS)

Act and related General Code of Conduct may not be waived.

All financial interests offered to/received from third parties are monitored as part of 40410 INSURE’s overall Risk and Compliance Monitoring Programme.

Who is responsible for compliance?

40410 INSURE has adopted a governance process that requires the leadership team to ensure compliance with this Policy.

Managing Executive:

The ME is accountable for the implementation and compliance with this Policy within 40410 INSURE.

Compliance Officer:

The Compliance Officer is accountable for updating this Policy based on changing business practices and a changing regulatory environment.

They are also accountable for the monitoring of compliance with this Policy as a part of 40410 INSURE’s Risk & Compliance Management Framework and for reporting any issues to management.

Key Individuals:

40410 INSURE’s appointed Key Individuals are accountable for ensuring compliance by the representatives listed on the representative register under their control as required by the FAIS Act.

Internal Audit:

Internal Audit is accountable for assurance to the board of directors on the adequacy and effectiveness of 40410 INSURE’s internal and compliance controls relating to conflicts of interest.

Risk & Compliance Management Framework:

40410 INSURE has included conflict of interest monitoring in its Risk and Compliance Management Framework. The framework is reviewed annually.

Questions and complaints:

Existing and potential customers can also direct questions and complaints concerning the application of this Policy to compliance@40410insure.com

Consequences of non-compliance:

Any employee who fail to follow this policy will be dealt with in terms of 40410 INSURE’s internal disciplinary procedures. In addition, contact centre staff members are also subject to the procedures applicable to representatives under the FAIS Act.

Financial interests:

40410 INSURE’s policy is not to receive anything other than permitted distribution, support and administration fees.

Contact Centre Staff Members

40410 INSURE’s contact centre staff members are salaried employees who may also qualify for certain additional incentives and other benefits. These other benefits include certain non-cash prizes if specific business targets are met.

Before these incentives and other benefits are paid, 40410 INSURE’s policy is to take the following quantity and quality measures into account:

  • The volume of business generated by the staff member, measured by quantity and premium value.
  • Persistence of the business written, measured by short- and long-term lapse rates.
  • The quality of the service to the customer, measured by the Key Performance
  • Indicators in the staff member’s Performance Agreement.
  • The volume of business generated by the consultant, measured by quantity and premium value.
  • Persistence of the business written, measured by short- and long-term lapse rates.
  • The quality of the service to the customer, measured by the Key Performance Indicators in the consultant’s Performance Agreement

List of associates and third parties in which 40410 INSURE holds an ownership interest:

  • There are no third parties that 40410 INSURE holds ownership in.
  • There are no third parties that hold ownership within 40410 INSURE.