Conflict of Interest Policy

4 as possible; • Any negative impact on clients owing to the removal of actual or potential conflict of interest will be kept to a minimum; • The reason(s) why the actual or potential conflict of interest was determined to be avoidable will be recorded; • All determinations and interventions as it pertains the avoidance of the actual or potential conflict of interest will be documented and kept on the compliance file; and • Similar conflicts of interest will be avoided in the future. If the Board decides that the actual or potential conflict of interest is unavoidable, the following processes will be adhered to: • The Board will convene and review an appropriatemitigation process given the unavoidability of the given set of circumstances; • The reason(s) why the actual or potential conflict of interest is considered to be unavoidable will be recorded and kept on the compliance file; • The Group Risk Manager will be made aware of the unavoidability as well as the reasons for such unavoidability; • The mitigation process will include the adoption of the following measures: • The actual or potential conflict of interest will remain only for as long as it is absolutely necessary given the unavoidability of the actual or potential conflict of interest; • Alternative arrangements to a proposed transaction, contract or arrangement that is the subject of the conflict of interest will be investigated on an ongoing basis; • The rendering of financial services will at all times be conducted as to the best interest of the client (in as far as possible given the unavoidability of the actual or potential conflict of interest); • Full disclosure of the actual or potential conflict of interest will be made to the client at the earliest available opportunity; • Full disclosure of the actual or potential conflict of interest will be made to the Financial Services Board during Kganya Insurance Administrators (Pty) Ltd (RF)’s annual compliance reports. 6. DISCLOSURE In terms of Section 3A(2)(b)(i)(cc) of the FAIS General code of Conduct, a conflict of interest management policy must provide measures for the disclosure of conflicts of interest. Accordingly, on discovery of an actual or potential conflict of interest and the subsequent determination of its unavoidability, full disclosure of such will be made in writing, within 30 days to: