Conflict of interest policy for Intellivest Financial Services
IFS has identified three main areas of possible conflicts of interest in the investment management business:
• Conflict of interest between IFS clients and IFS/IFS staff;
• Conflict of interest between IFS and the staff of IFS;
• Conflict of interest between IFS and the government of South Africa
To manage and control the possible conflicts of interest as mentioned above, the following procedures and policies have to be adhered to by staff of the company:
• The company will have its own trading accounts;
• Staff members are permitted to have their own trading accounts;
• Staff members are not allowed to have trading accounts at other brokers other than new appointees who already have trading accounts at other brokers. These accounts will be required to be closed and moved over to IFS (Standard Financial Markets) within a period of three months after appointment;
• The opening of a trading account for a staff member must be approved by a director and must be executed through IFS at Standard Financial Markets;
• Communication and reporting regarding staff personal accounts must be done according to the same procedures as those of client accounts;
• No transactions may take place between the IFS account and the account of a staff member:
o If IFS wants to sell an investment out of its account, and a staff member wants to buy the same investment, the staff member must withdraw his/her offer to purchase until such time as IFS has sold its investment;
o The same principle applies with the purchase of an investment by IFS and the sale of an investment by a staff member. The IFS transaction takes preference and must be completed before the staff member may put in a bid to buy.
• No transactions may take place between a client account and the account of IFS or a staff member:
o If a client wants to sell an investment out of its account and IFS or a staff member wants to buy the same investment, IFS or the staff member must withdraw its/his/her offer to purchase until such time as the client has sold its investment;
o The same principle applies with the purchase of an investment by a client and the sale of an investment by IFS or a staff member. The client transaction takes preference and must be completed before IFS or the staff member may put in a bid to buy.
• IFS will service the clients below on the condition that IFS will report them to the Financial Intelligence Centre (FIC) if the clients concerned:
o Are being suspected of committing terrorist activities;
o Are being suspected of committing money laundering;
o Attempt to commit or facilitate the commission of a specific offence as defined in the Protection of Constitutional Democracy against Terrorist and Related Activities Act, 2004;
o represent a specific entity identified in a notice issued by the President, under section 25 of the Protection of Constitutional Democracy against Terrorist and Related Activities Act, 2004.
• IFS staff must declare gifts/services from a single third party exceeding a cumulative of R1000 for the year up to the last gift/service was received. Such disclosures must be made in writing to the compliance officer within 30 days of exceeding this limit.
• At the start of each calendar year, IFS staff will be required to sign a declaration, as part of other undertakings, that gifts from 3rd parties – irrespective whether they are above or below R1000 per year – did not cause him/her to transgress certain internal policies of IFS and/or laws of the country.
• Employees resigning from of IFS are not allowed to service IFS clients with services/products that IFS has provided to the clients concerned.
• Within IFS the order of interest in conflict is the following:
o The government’s interest takes preference above the interests of IFS or its clients
o The client always takes preference above the interests of IFS or staff members;
o IFS takes preference before the interest of staff members;
o The interest of staff members in the case of a conflict of interest takes last preference.
- All breaches or possible breaches of this policy as well as conflicts of interest must be reported to the compliance officer.