Conflict of Interest Management
Conflict of Interest
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.
- Promotional items (with a value of no more than R1,000.00 per FAIS representative / key individual in any given year); and
- any other financial interest with a determinable monetary value not exceeding R1,000.00 per FAIS representative / key individual in any given year
- ownership interest;
- directorships in other companies; and
- rebates or fees received from product providers and which affects the fee payable by the client or which could potentially influence the advice process.
- Financial interest to a representative or to the provider for giving preference to a quantity of business to the exclusion of quality to the client, preference to a specific product supplier or preference to a specific product;
- cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship and any other incentive or valuable consideration not mentioned above, including travel and accommodation associated with allowed training;
- any financial interest other than allowable financial interests listed above with a determinable monetary value exceeding R1,000.00 per FAIS representative / key individual in any given year; and
- training restricted to a selected group of providers and FAIS Representatives on including but not limited to: products and legalities thereof; general financial and industry information; specialised technological systems (of a third party) necessary for rendering a financial service.
- Both a Gifts Register for allowable financial interests (Annexure A) and a Conflicts of Interest Register for Ownership interests, Directorships and Disallowed financial interests (Annexure B) have been implemented.
- The Company’s (TBC) will act as the custodian of both the Conflicts of Interest register and the Gifts register.
- Each Representative has a duty to report any such an immaterial financial interest provided or received to the custodian of the Gifts Register (within a week of giving / receiving such a gift) who shall report to the Managing Director of the Company as soon as the aggregate financial interest given or received by any one representative from that product provider or third party reaches R1,000.00 in that particular year.
- A financial interest with a monetary value of more than R1,000.01 constitutes a material conflict, and will prior to giving, or accepting such a financial interest, the employee or Representative must obtained the written consent of the Managing Director of DIRE WOLF for the gift. Such an instance must be recorded in the relevant Conflict of Interest register.
- All the Key Individuals and Representatives will be required to also complete the ’Conflicts of Interest Questionnaire’ as provided for in Annexure C of this policy.
- The conflict of interest register will be updated and reviewed by the Key Individual(s).
- If it has been established that a particular situation or activity gives rise to a conflict of interest, such a situation must be avoided.
- If such a conflict of interest is inevitable it is the responsibility of the Managing Director to ensure that the effect if the conflict is mitigated by disclosing the conflict of interest to the relevant client(s).
- Record keeping
Declarations and relevant registers will be stored securely for future reference.
- Consequences of non-adherence
Violation of this policy and procedures described herein will result in appropriate disciplinary action.
- Training and awareness
All staff will receive training on the Conflict of Interest policy and requirements.
This policy shall be reviewed annually and any changes to this policy shall be communicated to all staff.
Dire Wolf Financial Services (Pty) Ltd, Reg Nr: (2021/398161/07), Authorised financial services provider: FSP 51573
Directors: A Mulder, HL Pretorius, KL Frank, RR Grobler, W Swanepoel