Conflict of Interest Policy

3 4.2 Declarations are to be signed by all Key Individuals confirming the presence or absence of any actual or potential conflict of interest, on an annual basis; 4.3 The following lists are attached and will be updated annually: 4.3.1 Kganya’s Associates; 4.3.2 All parties in which Kganya holds an ownership interest; 4.3.3 All third parties that hold an ownership interest in Kganya; 4.3.4 A Master register of interests 4.3.5 All gifts in excess of R1 000.00 received from 3rd parties. 4.4 All Kganya employees will disclose in writing to their respective managers on an ongoing basis where they become aware of any conflicts of interest; 4.5 All records associated with the identification of an actual or potential conflict of interest are kept with the Group Risk Manager which is available for inspection purposes. 5. AVOIDANCE AND MITIGATION Once a potential or actual conflict of interest is identified in terms of the above, the following steps will be taken: 5.1 The Board will convene to review the actual or potential conflict in an open an honest forum; 5.2 All information surrounding the actual or potential conflict of interest will be disclosed to all interested parties; and 5.3 All information surrounding the actual or potential conflict of interest will be disclosed to the Group Risk Manager. In this event, the Board will consider the consequences of avoidance and unavoidability as well as the subsequent negative impact it will have on Kganya’s clients, the integrity of the financial services industry and Kganya itself, amongst others as registered financial services providers. Additionally, the Board will apply its mind whether Kganya can obtain a more advantageous transaction, contract or arrangement with reasonable efforts from a person or entity that would not give rise to a conflict of interest. Should this not be possible the Board shall determine by a majority vote whether the transaction under review is in Kganya’s best interest and any affected clients and accordingly make its decision as to whether to enter the transaction with such determination. If the Board decides that the actual or potential conflict of interest is avoidable, the following processes will be adhered to: • The Board will approve by majority vote the removal of the underlying cause of the actual or potential conflict of interest; • The underlying cause of the actual or potential conflict of interest will be removed as soon