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Conflicts of Interest

 

Conflict of Interests Policy

 

TF Global Markets (South Africa) (Pty) Ltd strives towards ensuring it is able to identify and manage potential conflicts appropriately and effectively. 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, TFGlobal Markets (South Africa) (Pty) Ltd considers whether there is a material risk of damage to the client, considering whether TF Global Markets (South Africa) (Pty) Ltd or a TF GlobalMarkets(South Africa)(Pty) Ltd representative,associate, or employee–

  • Is likely to make a financial gain, or avoid a financial loss, at the expense of the client. 

  • as an Interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which Is distinct from the client's interest in that outcome;

  • Has a financial or other incentive to favour the interest of another client, group of clients or any other third party over the interests of the client.

  • Rceives or will receive from a person other than the client, an inducement in relation to a service provided to the client in the form of monies, goods or services, other than the legislated commission or reasonable fee for that service.

Our policy defines possible conflicts of interest as, inter alia:

  • Conflicts of interest between TF Global Markets (South Africa) (Pty) Ltd and the client; 

  • Conflicts of interest between our clients if we are acting for different clients and the different interest’s conflict materially; 

  • Conflicts of interest where associates, product suppliers, distribution channels or any other third party is involved in the rendering of a financial service to a client;

  • Holding confidential information on clients which, if we would disclose or use, would affect the advice or services provided to clients.

Management

Specific monetary measures we focus on:

  • We may only receive commissions authorized in terms of applicable legislation; or

  • Fees authorized in terms of applicable legislation, or fees or remuneration for services rendered to a third party, if those fees are reasonably commensurate to the service being rendered; or

  • Fees for the rendering of a service in respect of which commission or fees above is not paid, if those fees are specifically agreed to by a client in writing and may be stopped at discretion of the client; or

  • A limited immaterial financial interest as defined; or

  • A financial interest for a consideration or fair value that is reasonably commensurate to the value of the financial interest that is paid by the provider or representative at time of receipt thereof.

We will not offer any financial interest to any representative for –

  • Giving preference to the quantity of business secured for the provider to the exclusion of quality service;

  • Giving preference to a specific product supplier where more than one supplier can be recommended to a client;

  • Giving preference to a specific product of a supplier where more than one product of that supplier can be recommended

The measures TF Global Markets (South Africa) (Pty) Ltd have 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.
 

Procedures:

We have adopted appropriate procedures throughout our business to manage potential conflict of interest. Our representatives, associates and employees receive guidance and training in these procedures, and they are subject to monitoring and review processes. There are specific measures and consequences in place for non-compliance with our conflict of interest policy.
 

Confidentiality barriers:

Our representatives, associates and employees respect the confidentiality of client information and disclose or use it with circumspect. No such information may be disclosed to a third party without the written consent of a client.
 

Monitoring:

The key individual or compliance officer in charge of supervision and monitoring of this policy will regularly provide feedback on all related matters. The policy will be reviewed annually.
 

Disclosure:

Where there is no other way of managing a conflict, or where the measures in place do not sufficiently protect clients’ interests, the conflict must be disclosed to allow clients to make an informed decision on whether to continue using our service in the situation concerned. In all cases, where appropriate and where determinable, the monetary value of non-cash inducements

 

Particular Management Measures

  • Identification of conflict of interest:

    • Create awareness and knowledge of applicable stipulations of the General Code of Conduct and relevant legislation relating to conflict of interest, through training and educational material;

  • Avoidance of conflict of interest:

    • Ensure understanding and adoption of conflict of interest policy and management measures by all employees, representatives and associates;

    • Do regular inspections on all commissions, remuneration, fees and financial interests proposed or received in order to avoid non-compliance.

    • Keep a register of conflict of interest.

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