Conflict of Interest Policy

2 Here “interest” includes a financial interest, ownership interest or any relationship with a Third Party. 2.2 Ownership means equity, dividends, profit share, etc 2.3 Third Party means a product supplier, another provider, an associate of a product supplier or a distribution channel. 2.4 Associate means any subsidiary or holding company of this company, any other subsidiary of the holding company, any other company of which that holding company is a subsidiary or any person in accordance with whose directions or instructions the Board of directors of this company is accustomed to act. 3. STEPS The steps to be followed in the implementation of this policy are as follows; Kganya will document: 3.1 Mechanisms for the identification of conflicts of interest; 3.2 Measures for the avoidance of conflicts of interest and where avoidance is not possible, the reasons therefore and the measures for the mitigation of such conflicts of interest; 3.3 Measures for the disclosure of conflicts of interest; 3.4 The processes, procedures and internal controls to facilitate compliance with the policy; 3.5 Consequences of non-compliance with the policy by Kganya’s employees; 3.6 A list of all Kganya’s associates; 3.7 A list of all parties in which Kganya holds an ownership interest; and 3.8 A list of all third parties that hold and interest in Kganya. These steps are documented below. 4. MECHANISMS FOR THE IDENTIFICATION OF CONFLICTS OF INTEREST In terms of Section 3A(2)(b)(i)(aa) of the FAIS General Code of Conduct, a conflict of interest management policy must provide mechanisms for the identification of conflicts of interest. The mechanisms in place to identify actual or potential conflicts of interest are: 4.1 An annual review will be undertaken by the Managing Directors, on all contracts held with 3rd parties and will re-examine whether the relationship influences Kganya’s objective performance towards its clients. This review will be tabled at the two meetings of the Board of directors held every year for consideration. Additionally, the review will be submitted to Kganya’s Group Risk Manager for consideration;