In order to ensure ongoing compliance with the Code, and to clearly communicate our position on conflict of interest, SAIY and SFG have adopted this conflict of interest policy. This policy has been developed by our Head of Risk and Compliance, has been adopted by all employees and is publicly available on our websites (www.saiy.co.za/www,saiyfg.com)

Each responsible person at SAIY is required confirm and acknowledge that they have declared all potential conflicts to the Head of Risk and Compliance Philippa Owen. It is company policy to avoid potential conflict, where this is not possible, the Head of Risk and Compliance will work with the externally appointed compliance officer (Alwie Carstens of Masthead) to mitigate the conflict and to ensure clear and adequate disclosures.

On a quarterly basis, responsible persons at SAIY complete a detailed Fit and Proper declaration, confirming ongoing adherence to the Code.

CONFLICT OF INTEREST POLICY STATEMENT

SAIY (and its representatives) is committed to acting in the best interests of our clients. We strive to avoid all conflict of interest in our business. Where we are unable to avoid a conflict, we will take all necessary precautions to ensure that any actual (or potential) conflict of is mitigated and disclosed to our clients.

Our conflict of interest policy is available on our website www.saiy.co.za and www.saiygf.com .

PURPOSE OF THIS POLICY

The purpose of this conflict of interest policy is therefore to:

establish internal controls and procedures for the identification of potential conflict of interest;

establish measures to avoid conflict of interest, and where avoidance is not possible, to provide the reasons therefore;

establish measures to ensure that any unavoidable conflict of interest is mitigated;

establish measures to ensure the proper disclosure of any conflict of interest;

establish processes, procedures, and internal controls to facilitate compliance with the policy; and

communicate the consequences of non-compliance with the policy.

IDENTIFYING CONFLICT OF INTEREST

The primary responsibility for the identification of a conflict rests with the representatives, employees, and individual members of the governing body of SAIY. While a conflict is usually associated with financial interests, conflicts may arise when a person’s personal interest conflicts with their professional obligations.

In order to try and identify possible conflicts, this policy requires the following questions to be asked:

Will you (or someone you know), receive any unearned benefits or gain competitive advantage from this situation or relationship?

Does your own personal interest in this situation compete or conflict with the interests of SAIY or its clients?

Could your actions or decisions go against the best interests of SAIY or its clients?

Will you be taking advantage of SAIY or its clients’ proprietary or confidential information for your own benefit?

Could a gift or benefit (given or received) affect your judgment in any way?

Could this situation or relationship damage the trust that others – for example, your clients, colleagues, or the public – have in you?

If the answer to all of these questions is “no”, then there is no conflict of interest associated with the financial service. If the answer to any one of the three questions is “yes”, the representative must proceed to answer the following additional questions:

s the situation caused as a result of an actual or potential relationship with a third party?

is the situation caused by an actual or potential financial or ownership interest?

If the answer to any one of these questions is “yes”, an actual or potential conflict of interest will have been identified. Where a potential conflict has been identified the situation needs to be escalated to SAIY’s Head of Risk and Compliance in order for guidance to be given on how to avoid, mitigate or disclose the potential conflict. The Head of Risk and Compliance will escalate as needed to the externally appointed compliance officer, and written guidance will be provided to the representative.

Records of potential conflict of interest, and guidance provided will communicated to management and be kept on file for compliance purposes. Failure to declare a potential conflict situation adequately and timeously may result in disciplinary measures being taken against the employee involved.

 INTERNAL CONTROLS

SAIY has adopted a clear remuneration structure that ensures the alignment of interests of employees, representatives, and directors with the interests of the business and it’s clients.  SAIY will not offer any financial Interest to its employees outside of the scope of the remuneration structure. Should a situation arise whereby a potential financial interest does/may fall outside the scope of the existing remuneration structure, the Head of Risk and Compliance will seek management approval and sign off prior to updating the remuneration structure. The remuneration structure is outlined in the remuneration policy.

In the appointment of third party service providers, SAIY will conduct a thorough and objective due diligence of competing service providers and will appoint the selected service provider for a maximum of one year. Service levels will be monitored, and service level agreements reviewed annually. Neither financial nor non-financial interests of SAIY representatives in an appointed third party will be tolerated.

In relation to the delivery of fair outcomes for clients, SAIY’s remuneration structure is designed to ensure that all clients are treated fairly in line with the company’s Treating Customers Fairly (“TCF”) Policy.

The Head of Risk and Compliance, with SAIY management conducts annual reviews of:

Contracts held with third parties in order to assess whether the contractual relationship in any way influences the SAIY’s ability to render fair and unbiased financial services towards its clients, to be objective towards clients and to act in the best interests of the client;

All relationships where an ownership interest exists between SAIY and a third party. The purpose of the review is to assess whether the relationship in any way influences SAIY’s ability to render fair, unbiased, and objective financial services towards its clients;

Ownership interests held by SAIY (and related entities) and held in SAIY (and related entities) and a list of SAIY associates (third parties) is attached as an annexure hereto;

CONSEQUENCES OF NON-COMPLIANCE

Non-compliance with the provisions of this policy, the Code, and the Acts  may lead to disciplinary action and dismissal, and representatives may be debarred from operating within the financial services industry in the event of dishonesty.

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