This policy applies to all employees or future employees and contractors of DIRE WOLF FINANCIAL SERVICES (PTY) LTD (“DIRE WOLF”). Conflicts of interest referred to this document may either be recognised (identified / realised) or be potential or perceived (conceivable) and most often arise because of an actual or possible financial interest.
This purpose of this policy is to assist individuals with identifying potential and actual conflicts of interest and for DIRE WOLF to manage it appropriately. It provides clear guidelines and rules, and describes the procedures to be followed to ensure that conflict of interest situations do not cause DIRE WOLF to act in contravention of the Financial Advisory and Intermediary Services Act (“FAIS”) and General Code of Conduct which requires that a provider must at all times render financial services honestly, fairly, with due skill, care and diligence, and in the interests of clients and the integrity of the financial services industry.
DIRE WOLF is committed to avoiding and where this is not possible mitigating any conflict of interest that may arise between ourselves, as a financial services provider, and our clients when rendering a financial service. Where such a conflict of interest cannot be avoided the situation will be explained to the affected client(s).
3.1.1. The following allowable financial interests have to be disclosed internally in the company’s gift register:
3.1.2. The following allowable financial interests have to be disclosed internally in the company’s conflicts of interest register and directly and unequivocally to affected clients:
The following financial interests are disallowed:
4.1.1. Reporting and record keeping
4.1.2. Key Individual authorisation
4.1.3. Annual Key Individual and Representative disclosure
4.1.4. Further reporting of conflicts of interest