SAIY Asset Management (SAIY) is an independent asset management company, charged with discretionary management of client investment portfolios. Our clients are either direct clients who have signed a discretionary mandate with us (as approved by the FSCA) or are indirectly invested in our regulated collective investment schemes.

This policy outlines SAIYs approach to incorporating the 6 TCF Outcomes into our investment approach and our relationship with our clients. The fair treatment of clients is a core principle upon which our business is based – our success depends on delivering the best possible outcome for all our clients all the time.

This policy has been developed by our Head of Risk and Compliance and has been approved and adopted by the management board.

OUTCOME 1: Clients are confident that they are dealing with firms where the fair treatment of clients is central to the firm culture.

The culture of SAIY encompasses TCF principles at all levels from top leadership (board level) to support staff as outlined below.

SAIY has a dedicated Head of Risk and Compliance, Philippa Owen, who is tasked with overseeing operations from a risk and compliance perspective. Philippa reports to the management team (and the board of directors) and has been tasked with ensuring that the internal policies and procedures at SAIY integrate all aspects of the General Code of Conduct.

As outlined in the Risk Management Framework, the Head of Risk and Compliance meets formally on a quarterly basis with the SAIYs management team. TCF is a standing item on this quarterly risk and compliance agenda.

In addition:

All new business initiatives that are considered include in their outline an analysis and consideration of the possible impact they may have on TCF outcomes.

There is ongoing evaluation of whether the company has been effective in achieving TCF outcomes (annual).

Our external compliance (Masthead) assists us to monitor and respond to changes in the broader environment (such as economic and regulatory developments), enabling us to identify TCF related risks so that we can proactively adjust our policies and procedures as needed and ensure ongoing compliance.

process has been circulated to all staff members and staff members are encouraged to make suggestions to the management team on how the fair treatment of our clients might be further enhanced.

Employment and service agreements allow for the imposition of meaningful consequences (such as retraining, re-assignment or disciplinary action, as appropriate) for staff members or management who do not achieve agreed TCF deliverables.

OME 2: Services marketed and sold are designed to meet the needs of identified client groups and are targeted accordingly.

SAIY clients are broadly categorised into two groups: those that invest into our collective investment scheme products directly and those for whom we manage segregated bespoke portfolios governed by the terms of our FSCA approved mandate.

Our investment process as outlined is consistently applied across the funds and stand-alone mandates that we manage on behalf of our clients, the only difference being the weightings applied.Higher risk portfolios are invested with higher weightings and exposures compared to the lower risk portfolios. The risk level appropriate to each client is assessed prior to investment and the risk profiles of each investment solution are clearly discussed and explained.

In all our marketing material, presentation packs, communications, and face to face meetings with clients we ensure that our investment approach is clearly defined and consistently applied so that all clients and potential clients know what to expect from our investment solutions and our services.

OUTCOME 3: Clients are provided with clear information and are kept appropriately informed before, during and after the point of sale.

SAIY policies and procedures are clear and well defined and are designed to ensure that we communicate clearly with all our clients and potential clients. Across all forms of communication our process is explained in clear language. Our reporting is designed to ensure that the characteristics of each fund and investment solution are plainly articulated and that the different risk profiles are easily understood.

Our clients, by nature of our business model and the funds we offer are all qualified investors. Our regulated collective investment schemes are distinctly qualified investor (QIHF) funds, and we use the same minimum investment requirements when onboarding discretionary clients with segregated portfolios. Our communication with our clients and our prospective clients’ centres around our vision, our investment approach, and the specific risk characteristics of each of our fund sand investment solutions. SAIY always promises to do our best for all our clients: we want our client to be our partners as we strive to generate exceptional and consistent long-term risk adjusted growth. We are transparent in this vision so that investors know what to expect over the short, medium, and longer terms and are comfortable with the level of risk taken.

Our unique fee structure, which ensures that SAIY is only paid once clients have received the return promised to them, is transparently and consistently applied, and clearly communicated prior to investment.

SAIY is responsible for all internally produced marketing and client feedback material. We do not use marketing material produced by third parties. Our marketing and reporting documentation is independently approved by our external Compliance Officer (Cobus van Schalkwyk at Masthead) for adherence to the Code and approved by the appointed MANCO for the collective investment scheme funds to ensure adherence to Board Notice 92 (BN 92 OF 2017). SAIY has an Advertising and Marketing Policy.

We provide all clients with written statements at least once a quarter. These statements outline the client’s investment value and performance. Each of the funds and segregated portfolios are managed Pari-passu, adjusted only for the level of risk applied, ensuring complete fairness across client mandates. The performance of the collective investment schemes is publicly reported and variations between this performance and individual client performance is purely a result of cash flow timings and risk levels. Our reporting ensures that each client can clearly understand the information provided.

OUTCOME 4: Where clients receive advice, the advice is suitable and takes account of their circumstances.

SAIY Asset Management, as a discretionary asset manager, does not give advice.

We have tailored our risk profiled products to meet the needs of two distinct investment groups: those that are able to tolerate higher risk and those that are comfortable with more moderate risk levels. Outside of these groups we can adjust (dial up or dial down) individual client portfolios or investment solutions to meet the needs of clients that do not readily fall into the risk profile groups catered for by the collective investment schemes. For these clients we can structure any level of risk which is suitable within a segregated mandate.

The risk and return profiles of each of the collective investment schemes are clearly defined and communicated via the Minimum Disclosure Document (MDD). Similar disclosures for segregated portfolios are defined in the individual discretionary investment mandates.

The Head of Risk and Compliance, together with the management team has formalised existing client on-boarding procedures to ensure that discretionary investment services rendered to or for a client are appropriate to their financial circumstances, appetite for risk and long-term financial goals. Client relationship managers will ensure that they have sufficient understanding of the client’s situation to put together a relevant financial solution for each individual client.

Conflict of Interest

At all times we adhere to our Conflict of Interest Policy in recommending investment solutions to clients. SAIY and its staff receive no compensation for recommending one solution over another. All remuneration is based purely on individual and team performance measured by client satisfaction, quality of service and performance of client investments.

OUTCOME 5: Clients are provided with advice/products/portfolios that perform as the firm has led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.

SAIY’s range of investment solutions are each individually clearly defined. While the investment process is consistently applied across all funds and segregated accounts, the different levels of risk define the return expectations of each.

Our clients understand the nature of each investment solution and their expectations should be realistic. Our reporting is transparent and detailed enough for each client to be able to understand the attribution of their returns, as well as the nature and amount of fees charged.

Our service levels are communicated clearly prior to investment – we view our clients as our long-term partners. SAIY’s vision is to “change the face of investments” by setting a new benchmark for financial growth through simplicity, honesty, and consistency. Our long-term goal is to grow with our clients.

OUTCOME 6: Clients do not face unreasonable post-implementation barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Each of our portfolios is designed to ensure attractive medium to long term performance. Over shorter time periods these funds and segregated accounts may experience periods of negative growth, with the extent of any losses variable in relation to the risk profile as communicated to each investor. Returns targets are stipulated over a 12 month period, and our fees calculated on excess returns over this period. To best position our investors to achieve the return target we have set; we therefore recommend a minimum investment period of at least 12 months. To the extent that investors choose not to remain invested for this minimum period we charge an early redemption penalty of 5% which is paid to the fund in the case of our collective investment schemes, and to SAIY Asset Management in the case of segregated accounts. SAIY may waive this fee at its discretion depending on the circumstances of the client. This early redemption penalty is designed to compensate for administration and trading expense in lieu of performance fee not earned over periods of less than 12 months.

Other than this financial barrier there are no other lock-in mechanisms across our investment solutions. The QIHF funds and the segregated mandates allow for monthly redemptions with 90 days’ notice.

ONGOING MONITORING OF THE ABILITY TO MEET THE TCF OUTCOMES

Staff receive ongoing product training and skills development. A register of training is kept by management.

Complaints are noted and acted upon in line with SAIY’s Complaints policy and procedure, which is available on our website at www.saiy.co.za. Should there be any repeat complaints this will be investigated further.

Staff are surveyed to ascertain their awareness of TCF and its implementation across our services; and

SAIY management and advisory board assess annually the effectiveness of this policy and our ongoing adherence to the Code and the principles of TCF. Improvements and enhancements to the general practice within the company, as well as to this policy, are implemented in line with our ethos of continuously striving towards global best practice.

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