Conflict of Interest Policy

1 1. INTRODUCTION The Kganya Benefits Fund Trust and Kganya Group of companies (Kganya Investment Holdings (Pty) Ltd, Kganya Insurance Administrators (Pty) Ltd (RF), Kganya Alternative Distribution (Pty) Ltd (RF), Kganya Financial Services (Pty) Ltd, Kganya International, Kganya Projects NPC, Kganya Brands (Pty) Ltd and Kganya Technology Solutions (Pty) Ltd – herein after referred to as Kganya) have decided that for purposes of transparency, accountability and good governance, it is essential to adopt a Conflict of Interest Management Policy that would apply to Kganya as a whole. It is vitally important that potential conflicts of interest are identified as soon as possible, as conflicts of interest affecting clients could undermine the integrity and professionalism of Kganya. Identifying conflicts at an early stage will encourage confidence in Kganya’s ethical standards. Potential conflicts of interest are inherent in any business. Kganya’s aim is to identify and manage potential or actual conflicts of interest before any client becomes aware that there is a potential or actual conflict of interest, and to ensure that our clients are not unduly prejudiced. Kganya’s Managing Directors are responsible for oversight of the activities of the respective Kganya Companies and are responsible for implementing appropriate processes and procedures for the effective risk management of conflicts of interest and other risks arising within their divisions. It is the responsibility of theManagingDirectors to implement this conflict of interest management policy, procedures and controls to manage conflicts effectively 2. LEGISLATIVE BACKGROUND In terms of Section 3A(2)(a) of the General Code of Conduct every provider, other than a representative must adopt, maintain and implement a conflict of interest management policy that complies with the provisions of the Financial Advisory and Intermediary Services Act ( FAIS ). Accordingly, Kganya InsuranceAdministrators (Pty) Ltd (RF) as a registered Financial Services Provider, must avoid and where this is not possible, mitigate any conflict of interest between itself and its clients. Additionally, it must ensure adequate arrangements are in place for the management of conflicts of interest that may arise partially or wholly in the provision of any financial services to its clients. Kganya in all its operations will adhere to the same standards of Conflicts of Interest Management as set out in the FAIS Act. The relevant definitions are as follows: 2.1 Conflict of Interest means any situation in which Kganya has an actual or potential interest that may (in rendering a financial service to a client): 2.1.1 influence the objective performance of its obligations to that client; or 2.1.2 prevent it from rendering an unbiased and fair financial service to that client.