Conflict of Interest Policy

5 • all Managing Directors; • the Group Risk Manager; and • The relevant client in such a way as to be considered prominent, specific and meaningful. Additionally, the conflict of interest policy will be made available to the public upon request. The affected client will also be provided with the reasons for the conflict of interest’s unavoidability and Kganya’s gift register. 7. FACILITATION OF COMPLIANCE WITH THE POLICY In terms of Section 3A(2)(b)(i)dd of the FAIS General code of Conduct a conflict of interest management policy must provide processes, procedures and internal controls to facilitate compliance with the policy. Accordingly, on behalf of the Board, the Non-Executive Deputy Chairman will ensure the following, all of which will be confirmed by the Group Risk Manager to Kganya’s Board meeting reports: • The policy will be kept on the compliance file; • All staff will sign the policy; • All Annexures required will be completed; • All contracts with 3rd parties will be reviewed annually; • All declarations confirming the presence or absence of any actual or potential conflicts of interest are signed on an annual basis; • Lists of all Kganya’s Associates, parties in which Kganya holds an ownership interest and parties who hold an ownership interest in Kganya are attached hereto and will updated annually; • Details of all gifts received by Kganya in excess of R1000.00 will be recorded in a gift register; • All records associated with the identification of actual or potential conflicts of interest will be kept as part of the compliance file; and • Proper disclosure requirements are communicated to the client. 8. CONSEQUENCES OF NON-COMPLIANCE In terms of Section 3A(2)(b)(i)(ee) of the FAIS General Code of Conduct a conflict of interest management policy must provide for the consequences of non-compliance with the policy by Kganya’s employees. If there is reason to believe that one of Kganya’s employees has failed to disclose actual or potential conflicts of interest, the respectiveManagingDirector shall afford that person the opportunity to explain the alleged failure to disclose. If after hearing the response from the employee and making such