1. Purpose
This policy establishes measures to identify, avoid and, where avoidance is not reasonably possible, mitigate and disclose conflicts between the interests of EJS Finance, its associates, representatives, employees, product suppliers, dealers and clients.
2. Core principle
Clients’ interests and fair outcomes take priority over sales targets, commissions, gifts, ownership relationships or other incentives. No person may provide advice or intermediary services where an unmanaged conflict prevents objective, suitable and lawful service.
3. Identification
Potential conflicts are assessed when appointing product suppliers, dealers, representatives or service providers; designing remuneration; allocating leads; recommending products; receiving gifts or hospitality; handling related-party business; and responding to complaints. Staff must disclose actual, potential or perceived conflicts promptly.
4. Avoidance and mitigation
Controls may include declining or ending an arrangement, removing a person from a decision, independent review, separating responsibilities, restricting information, comparing suitable alternatives, changing remuneration, refusing a financial interest, enhanced supervision and clear client disclosure before the service is rendered.
5. Financial interests
Only financial interests permitted under the FAIS General Code may be offered or received. Immaterial financial interests are monitored against the applicable aggregate limit, currently R1,000 per calendar year from the same third party, subject to regulatory amendment. Cash incentives, gifts, benefits or remuneration intended to influence unsuitable advice, quantity of business or unfair preference are prohibited.
6. Ownership and third-party relationships
Ownership interests, associates and relationships with product suppliers or dealers that could create a conflict must be recorded and disclosed where required. A current list of relevant associates and third parties is maintained internally and is available to the regulator or clients where legally required.
7. Remuneration
Remuneration must be reasonably commensurate with the service, permitted by law and structured so it does not encourage unfair treatment, unnecessary products or unsuitable advice. Quality, compliance and customer outcomes must be considered alongside commercial measures.
8. Disclosure to clients
Where a conflict cannot reasonably be avoided, the client receives timely, prominent and sufficiently detailed disclosure of its nature, source, extent, ownership or financial interest and the measures used to mitigate it. Disclosure does not by itself cure an unacceptable conflict.
9. Register, monitoring and training
Conflicts, gifts, financial interests, disclosures, decisions and remedial actions are recorded in controlled registers. Management and compliance review trends and breaches, and relevant staff receive training. Non-compliance may result in disciplinary action, reversal of an arrangement, client remediation and regulatory reporting.
10. Reporting concerns
Clients may raise a concern through the Complaints Handling Process. Staff must report conflicts internally without fear of retaliation for a good-faith report.
11. Review
The policy is reviewed at least annually and when material business, ownership, product, remuneration or regulatory changes occur. Transaction-specific disclosures remain controlling where they provide greater detail.