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May 18, 2015
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May 18, 2015

IMB Conflict of Interest Policy

IMB Financial Services (Pty) Ltd

264 Victoria Road,Woodstock, 7925 | T: + 27 87 941 3254 | F: + 27 21 447 5502

info@imb.co | Web:www.imb.co

Reg.No 2008/001532107

An Authorised Financial Services Provider: FSP No.: 43443

 

Table of Contents

1. Policy

2. IMB Management Process for dealing with conflicts of interest (Outlined in sections 3 and 4)

3. IMB Financial Services mechanism for the identification and Monitoring of conflict of interest

4. IMB Financial Services measures – avoid of conflict of interest

5. Consequences of non-compliance

6. IMB Financial Services To do’s
1. Policy

1.1. In the process of rendering a financial services, IMB Financial Services and IMB Financial
Services representatives will avoid and where this is not possible mitigate, any conflict of interest between IMB Financial Services and a client or an IMB Financial Services
representative and a client

1.2. IMB Financial Services or IMB Financial Services representative will, in writing, at the earliest
reasonable opportunity, disclose to a client

1.2.1. any conflict of interest in respect of that client, including the measures taken, to avoid
or mitigate the conflict or

1.2.2. any ownership interest or financial interest, other than an immaterial financial interest,
that the IMB Financial Services or IMB Financial Services representative may be or
become eligible for or

1.2.3. the nature of any relationship or arrangement with a third party that gives rise to a
conflict of interest, in sufficient detail to a client to enable the client to understand the exact nature of the relationship or arrangement and the conflict of interest;

1.2.4. inform a client of the IMB Financial Services conflict of interest management policy and
how it may be accessed.

1.3. IMB Financial Services or IMB Financial Services representatives may only receive or offer
the following financial interest from or to a third party —

1.3.1. commission authorised under the Long-term Insurance Act, 1998 (Act No. 52 of 1998)
or the Short-term Insurance Act, 1998 (Act No. 53 of 1998);

1.3.2. commission authorised under the Medical Schemes Act, 1998 (Act No. 131 of 1998);

1.3.3. fees authorised under the Long-term Insurance Act, 1998 (Act No. 52 of 1998), the
Short-term Insurance Act, 1998 (Act No. 53 of 1998) or the Medical Schemes Act,
1998 (Act No. 131 of 1998), if those fees are reasonably commensurate to a service being rendered;

1.3.4. fees for the rendering of a financial service in respect of which commission or fees
referred to above is not paid, if those fees —

1.3.4.1. are specifically agreed to by a client in writing; and

1.3.4.2. may be stopped at the discretion of that client;

1.3.5. fees or remuneration for the rendering of a service to a third party, which fees or
remuneration are reasonably commensurate to the service being rendered;

1.3.6. subject to any other law, an immaterial financial interest; and

1.3.7. a financial interest, not referred to above, for which a consideration, fair value or
remuneration that is reasonably commensurate to the value of the financial interest, is paid by that provider or representative at the time of receipt thereof.

 

1.4. IMB Financial Services may not offer any financial interest to an IMB Financial Services
representative for —

1.4.1. giving preference to the quantity of business secured for IMB Financial Services to the
exclusion of the quality of the service rendered to clients; or

1.4.2. giving preference to a specific product supplier, where an IMB Financial Services
representative may recommend more than one product supplier to a client; or

1.4.3. giving preference to a specific product of a product supplier, where an IMB Financial
Services representative may recommend more than one product of that product
supplier to a client.

For the purposes of this section, where the same legal entity is a product supplier and a provider, paragraph 3 does not apply to IMB’s representatives. IMB is subject to section 4, in respect of its representatives.

 

2. IMB MANAGEMENT PROCESS FOR DEALING WITH CONFLICTS OF INTEREST (OUTLINED IN SECTIONS 3 AND 4)

STEP DESCRIPTION RESP

 

1 Compliance Officer is notified by IMB Financial Services or its representative of a possible conflict of interest (either telephonically, or in person) IMB FS /
IMB FS Rep
2 Requests IMB Financial Services or IMB Financial Services representative to put possible conflict of interest in writing, and to attach copies of the relevant documents Compliance
Officer
3 Peruse the possible conflict of interest, identify the nature and extent thereof Compliance
Officer
4 Keep IMB Financial Services (and its representative if applicable) informed of progress Compliance
Officer
5 Keep proper notes of all actions and/or steps taken with at least the following information: date, time and persons with whom spoken or dealt with and a short summary of what was discussed Compliance
Officer
6 Arrange consultation with IMB Financial Services and discuss (if necessary) Compliance
Officer
7 Inform IMB Financial Services of findings Compliance
Officer
8 IMB Financial Services or IMB Financial Services representative will, in writing, disclose to the client conflict of interest as per guidelines outlined in section 2 above (as and where applicable) IMB FS /
IMB FS Rep
9 Note the outcome and date finalized in the documentation related to the issue, and ensure that it is recorded in the company records Compliance
Officer

3. IMB FINANCIAL SERVICES MECHANISMS FOR THE IDENTIFICATION AND MONITORING OF CONFLICT OF INTEREST

Customer surveys

The Representative contract to make provision for IMB Financial Services policy on conflict of interest

Call recording of calls to and from clients

Management reports e.g. check for multiple occurrences of bank accounts (and determined frequency of these reports)

Other reports on an ad hoc basis – as and when needed – e.g. check product sales and company ratios to clients and representatives

4. IMB FINANCIAL SERVICES MEASURES – AVOIDANCE OF CONFLICT OF INTEREST

—   Frequent managerial checks to review the status

 

5. CONSEQUENCE OF NON COMPLIANCE

—   As per IMB Financial Services Disciplinary process

LIST OF IMB FINANCIAL SERVICES ASSOCIATES:
COMPANY

– Lion of Africa

– Standard Bank SA

FOR MORE INFORMATION, PLEASE CONTACT THE CEO OF IMB AT
(087) 230 9861

 

6. IMB FINANCIAL SERVICES TO DO’S

 

6.1. Adopt the policy

A conflict of interest management policy must be adopted by the board of directors of IMB Financial Services.

6.2. Ensure awareness and provide for appropriate training & educational material

IMB Financial Services must ensure that its employees, representatives and, where
appropriate, associates are aware of the contents of its conflict of interest management policy and provide for appropriate training and educational material in this regard.

6.3. Ensure awareness and provide for appropriate training & educational material

IMB Financial Services must ensure that its employees, representatives and, where
appropriate, associates are aware of the contents of its conflict of interest management policy and provide for appropriate training and educational material in this regard.

6.4. Monitoring compliance

IMB Financial Services must continuously monitor compliance with its conflict of interest management policy and annually conduct a review of the policy.

6.5. Publish in appropriate media and ensure accessibility

IMB Financial Services must publish its conflict of interest management policy in appropriate media and ensure that it is easily accessible for public inspection at all reasonable times.

IMB Financial Services may not avoid, limit or circumvent or attempt to avoid, limit or
circumvent compliance
with this section through an associate or an arrangement involving an associate.

6.6. Duties of the compliance officer

IMB Financial Services compliance officer must include a report on IMB Financial Services conflict of interest management policy in compliance reports submitted to the Registrar under the Act.

The report referred to in paragraph 6 must report on at least the implementation, monitoring and compliance with, and the accessibility of the conflict of interest management policy.