Conflicts of Interest

Conflict of Interest Management Policy

Introduction

Incompass Insurance Consultants (Pty) Ltd (“Incompass”) is committed to conducting its business with integrity, transparency and professionalism.

As an authorised Financial Services Provider (“FSP”), we recognise our responsibility to identify, manage and disclose actual or potential conflicts of interest in accordance with the Financial Advisory and Intermediary Services Act, 37 of 2002 (“FAIS”), applicable subordinate legislation and guidance issued by the Financial Sector Conduct Authority (“FSCA”).

The purpose of this policy is to ensure that the interests of clients remain central to all advice, intermediary services and business decisions.

Our Commitment

Incompass is committed to:

  • Acting honestly, fairly, with due skill, care and diligence and in the best interests of clients.
  • Avoiding conflicts of interest wherever reasonably possible.
  • Identifying and appropriately managing conflicts that cannot be avoided.
  • Ensuring that clients are treated fairly at all times.
  • Maintaining appropriate governance processes to support sound decision-making.
  • Providing appropriate disclosure where a conflict of interest may exist.

What is a Conflict of Interest?

A conflict of interest may arise where any situation, relationship, financial interest, ownership interest or incentive could influence, or be perceived to influence, the objective performance of our duties to a client.

Conflicts may arise between:

  • Incompass and a client.
  • An employee or representative and a client.
  • One client and another client.
  • Incompass and an insurer or product supplier.
  • Incompass and a service provider.
  • Different business interests within the organisation.

Identification and Management of Conflicts

Incompass has implemented processes designed to identify, assess, monitor and manage actual or potential conflicts of interest.

These measures include:

  • Regular review of business relationships and remuneration arrangements.
  • Appropriate supervision and oversight of representatives.
  • Internal reporting and escalation procedures.
  • Ongoing staff training and awareness.
  • Disclosure of relevant conflicts where required.
  • Periodic review of this policy and related governance processes.

Where a conflict cannot be effectively managed, Incompass may decline to act in the matter concerned.

Financial Interests

Incompass and its representatives may only receive financial interests that are permitted in terms of applicable legislation.

Such financial interests may include:

  • Statutory commission authorised under applicable legislation.
  • Fees agreed with clients where permitted.
  • Reasonable and proportionate non-cash incentives permitted by law.
  • Remuneration received in terms of lawful intermediary, binder or other authorised agreements.

All financial interests are subject to applicable legislative requirements and internal governance controls.

Relationships with Product Suppliers

Incompass maintains relationships with various insurers, underwriting managers and other service providers in order to provide insurance-related services to clients.

Certain insurance products or services may be provided through specific insurer partnerships, underwriting arrangements or authorised agreements.

Where required, appropriate disclosure regarding such relationships will be provided to clients during the advice process.

These relationships do not remove our obligation to provide professional advice and intermediary services in accordance with applicable legislation.

Gifts and Incentives

Incompass has adopted controls relating to gifts, hospitality and other incentives.

Representatives and employees may not accept gifts, incentives or benefits that could reasonably be expected to influence objective decision-making or compromise the fair treatment of clients.

Any permitted gifts or incentives must comply with applicable legislation and internal governance requirements.

Employee Responsibilities

All directors, key individuals, representatives and employees are required to:

  • Avoid situations that may create conflicts of interest where possible.
  • Promptly disclose actual or potential conflicts.
  • Act in the best interests of clients.
  • Comply with this policy and related procedures.
  • Seek guidance where uncertainty exists.

Failure to comply with this policy may result in disciplinary action and, where applicable, regulatory reporting.

Disclosure of Conflicts

Where a material conflict of interest exists or may reasonably be expected to influence the services provided to a client, Incompass will make appropriate disclosure to the affected client in accordance with applicable legislation.

Such disclosure may include:

  • The nature of the conflict.
  • The measures taken to mitigate the conflict.
  • Relevant relationships with product suppliers or service providers.
  • Any ownership or financial interests that may be relevant.

Access to the Policy

This Conflict of Interest Management Policy is available to clients and interested parties upon request.

Policy Review

This policy is reviewed periodically and may be amended from time to time to reflect changes in legislation, regulatory requirements or business practices.

The latest version will always be available upon request.