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CONFLICT OF INTEREST MANAGEMENT POLICY

Background

Better Compare is a registered South African company under the registration number 2018/017243/07. Better Compare (PTY) Ltd is an Authorised Financial Services Provider, number 49357, authorized for

CATEGORY 1:

Long-Term Insurance: Category A
Short-Term Insurance: Personal Lines
Long-Term Insurance: Category B1
Long-Term Insurance: Category B2
Our registered and principal address is: 24 Flanders Drive, Mount Edgecombe, Durban, KwaZulu Natal, 4300

Section 3A(2)(a) of the General Code of Conduct stipulates that every provider, other than a representative, must adopt, maintain and implement a conflict of interest management policy that complies with the provisions of the Act. The policy is to provide for mechanisms in place at Better Compare (PTY) Ltd to identify, mitigate and manage the conflicts of interest to which the Better Compare (PTY) Ltd is a party. This Conflict of Interest Management Policy is designed as prescribed in the General Code of Conduct for Financial Services Providers and Representatives as amended by Board Notice 58 of 2010 and Board Notice 146 of 2014.

Objective of the Policy

This Conflict of Interest Management Policy does not change our existing conflict of interest management procedures but intends to document them in a simple form as required by the Financial Services Board.

In terms of the Financial Advisory and Intermediary Services Act, 2002, Better Compare (PTY) Litd is required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflict of interest. Better Compare (PTY) Ltd has put in place a policy to safeguard its clients’ interests and ensure fair treatment of its clients.

All providers, key individuals, representatives, associates and administrative personnel will commit to this policy and the processes will be monitored on an ongoing basis.

Better Compare (PTY) Ltd keeps and maintains a register in which all actual or potential conflicts are recorded.

Mission Statement on Conflict of Interest

Better Compare (PTY) Ltd is committed to ensuring that all its business is conducted in accordance with good business practice. To this end Better Compare (PTY) Litd conducts business in an ethical and equitable manner and in a way that safeguards the interests of all stakeholders to minimise and manage all real and potential conflicts of interests. Like any financial services provider, Better Compare (PTY) Ltd is potentially exposed to conflicts of interest in relation to various activities. However, the protection of our clients’ interests is our primary concern and so our policy sets out how:

 

Understanding the Definitions

“Conflict of Interest”

A conflict of interest may occur when in rendering a financial service to our clients we do not act objectively or do not render an unbiased or fair service to you or do not act in your interests, including but not limited to:

Any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, valuable consideration, other incentive or valuable consideration (exceeding R1000 per annum) other than:

Training, that is not exclusively available to a selected group of providers or representatives, on

“Fair Value”

Has the meaning assigned to it in the financial reporting standards adopted or issued under the Companies Act, 61 of 1973.

“New Entrant”

Is a person who has never been authorised as a financial services provider or appointed as a representative by any FSP.

“Sign-On Bonus”

Is any financial interest offered or received directly or indirectly, upfront or deferred, and with or without conditions, as an incentive to become a provider.

Here a financial interest includes but is not limited to a:

What may we Give and Receive?

We confirm that we will only receive or offer financial interest from or to the aforesaid providers or other third party in the form of:

Remuneration Policy

Our remuneration policy is

Better Compare is essentially a marketing channel for insurers to advertise their products. It is free for the insurers to be on the Better Compare panel though when we introduce a client to the insurer we charge a marketing fee. This fee is not added to the premium or directly related in any way as it is funded from the insurer advertising budgets they allocate to different marketing campaigns.

Our representatives earn a market related basic salary. Since Better Compare is neither an Insurance Company or a Broker, we don’t incentivize representatives on “making a sale”. Rather, we focus on rewarding agents based on the customer experience outcomes they deliver and that they treat customers fairly at all times.

Better Compare is not an Insurance Company or an Insurance Broker. Better Compare does not charge clients any fees, our service is free to use.

Better Compare is not an Insurance Company or an Insurance Broker. Better Compare does not earn commission.

Processes and Internal Controls

Identification of Conflict of Interest

To adequately manage conflicts of interest we will identify all relevant conflicts timeously.  In determining whether there is or may be a conflict of interest to which the policy applies Better Compare (PTY) Ltd considers whether there is a material risk of damage to the client, taking into account whether Better Compare (PTY) Ltd or its representative (s), associate (s) or employee (s):

Our policy defines possible conflicts of interest as, inter alia:

Better Compare (PTY) Ltd maintains an index of potential conflict risks, taking into consideration all business areas and income streams. The index is updated with all new conflicts identified, and to ensure completeness is reviewed on an annual basis. Apart from the register of actual conflict of interests, we will keep records of potential conflict of interest and these will be closely monitored by the KI/assigned staff.

All employees, including internal compliance officers and management, are responsible for identifying specific instances of conflict and are will notify the Key Individual of any conflicts they become aware of. The Key Individual will assess the implications of the conflict and how the conflict should be managed and act impartially to avoid a material risk of harming clients’ interests.

 

Measurement for avoidance and mitigation of Conflict of Interests

In order for Better Compare to deal with avoidance and mitigation of conflict of interest efficiently, we will:

Once a conflict of interest has been identified we will ensure it is appropriately and adequately managed.

The Key Individual will assess each conflict, including whether the conflict is actual or perceived, what the value of the conflict or exposure is and the potential reputational risk. Compliance and management then agree on the controls that need to be put in place to manage the conflict.

Disclosure

Where there is no other way of managing a conflict, or where the measures in place do not sufficiently protect clients’ interests, the conflict must be disclosed to allow clients to make an informed decision on whether to continue using our service in the situation concerned. In all cases, where appropriate and where determinable, the monetary value of non-cash inducements will be disclosed to clients. The Key Individual will ensure transparency and manage conflict of interests. Please list measure of disclosure e.g. Client advice record, disclosure letter, any other means of separate disclosure.

Publication

We will publish our conflict of interest management policy in appropriate media and ensure that it is easily accessible for public inspection at all reasonable times.  Our COI Policy is available in hard and electronic copy.  A copy will be provided on the clients request.

Declining to act

We may decline to act for a client in cases where we believe the conflict of interest cannot be managed in any other way.

Ongoing monitoring of Conflict of Interest Management

This policy will be reviewed annually and will be included in our annual FSB compliance report, containing details on the implementation, monitoring and compliance with, and the accessibility of the conflict of interest management policy.

The Key Individual will be responsible for the supervision and monitoring of this policy.

The key individual or staff member in charge of supervision and monitoring of this policy will regularly monitor and assess all related matters.

 

Training and Staff

All employees and representatives are required to read Board Notice 58 of 2010 together with Board Notice 146 of 2014 as well as this policy and to sign a statement to the effect that they have done so and fully understand the provisions of all three documents and the application thereof.

Comprehensive training on the Conflict of Interest policy will be provided to all employees and representatives as part of specific and/or general training on the FAIS Act. Training will be incorporated as part of all new appointees’ induction and refresher training provided on an annual basis.

The Key Individual Derek Wilson will conduct ad hoc checks on business transactions to ensure the policy has been complied with.

The Compliance Officer will include monitoring of the Conflict of Interest policy as part of his/her general monitoring duties and will report thereon in the annual compliance report. 

The compliance function is outsourced to an external Compliance company with no shareholding in this FSP. The Compliance practice functions objectively and sufficiently independently of the FSP and avoids conflicts of interest.


Non-compliance will be subject to disciplinary procedures in terms of FAIS and employment conditions and can ultimately result in debarment or dismissal as applicable.

Avoidance, limitation or circumvention of this policy via an associate will be deemed non-compliance.

This policy shall be reviewed annually and updated if applicable.

 

Representative Incentives

Sign-On Bonus

We do not offer a sign-on bonus to any person other than a new entrant, as an incentive to become a Category I provider that is authorised or appointed to give advice.

Only applicable to CAT I providers that are authorised to give advice

As a Category I provider that is authorised or appointed to give advice, we confirm that we do not receive a sign-on bonus from any person.


Registers

With regard to existing third-party relationships, being the product suppliers listed in our Contact Stage Disclosure letter, we confirm that we do not have an ownership interest or are subject to exclusive training nor are there any other circumstances which could lead to a potential conflict of interest.  Should any conflicts arise with regard to any of these, prior to entering into any business transaction with you, we undertake to disclose these in the registers below.

Better Compare (PTY) Ltd has implemented the registers below:

Nature and Extent of Ownership interests

At Better Compare (PTY) Ltd we believe in open, honest and transparent interactions with our clients. In the course of our business activities, situations may arise whereby we may become entitled to certain financial interests supplied by external parties in addition to the commission that we earn or the fees that we charge

We will disclose to our client, any financial interests that we may have received, the value, and the reason for receiving this financial interest. We will inform you of whether or not we believe that the financial interests received by us constitutes a conflict of interest, and will gladly address any concerns you may have.

We may also enjoy a preferred status with one or more of the product supplier companies with whom we hold contracts. This status allows us and our customers certain benefits when dealing with these providers. We believe that disclosure of these business relationships and the benefits they include, allow you to make informed decisions.

In accordance with the General Code of Conduct we are required to disclose any ownership interest we may have in external parties.

Masthead Membership

We are proud to state that we are members of the Masthead Financial Advisors Association. This association is a voluntary body of independent financial advisors, regulated by its own constitution and code of conduct. This code of conduct requires its members to adhere to ethical and professional standards and to act in the best interest of our clients.

As members of the Association, Better Compare (PTY) Ltd may become entitled to certain discounts by virtue of our membership.

The Masthead Financial Advisors Association holds 25% of the issued share capital in Masthead (Pty) Ltd, which is a separate legal entity that specialises in providing support services to independent financial services intermediaries. We have contracted with Masthead (Pty) Ltd to deliver certain services to us, including compliance services. For these services we pay a monthly service fee.

For the sake of full disclosure, please note that we derive no financial interest from Masthead other than services that are paid for.