This page constitutes the publicly accessible version of Wealth and Legacy Group (Pty) Ltd’s Conflict of Interest Management Policy. It is intended to explain how actual or potential conflicts of interest are identified, avoided or managed when we render financial services to clients.

Purpose and principle

Wealth and Legacy™ Group is committed to conducting business ethically and equitably and to safeguarding the interests of clients. We seek to avoid conflicts of interest wherever reasonably possible and, where avoidance is not reasonably possible, to mitigate and appropriately disclose the conflict.

What is a conflict of interest?

A conflict of interest may arise where Wealth and Legacy Group (Pty) Ltd or one of its representatives has an actual or potential interest that could influence the objective performance of obligations to a client, prevent the rendering of an unbiased and fair financial service, or affect the ability to act in the client’s interests.

This may include a financial interest, an ownership interest, or a relationship with a product supplier, another financial services provider, an associate, a distribution channel or another relevant third party.

Identifying potential conflicts

Key individuals, representatives and other relevant employees are expected to consider their responsibilities, business relationships and personal interests with a view to identifying actual, potential or perceived conflicts of interest. Potential conflicts may arise from matters such as directorships or outside employment, business or professional interests, share ownership, beneficial interests, personal account trading, professional or family relationships, rebates, commissions, gifts or other benefits.

Avoidance and management

Where a potential conflict is identified, the first consideration is whether the conflict can reasonably be avoided. If it cannot, the conflict must be assessed to determine whether it can be adequately managed through disclosure, appropriate controls, separation of responsibilities, independent review, restriction of the relevant activity or another suitable measure.

Where a conflict cannot be managed to an acceptable level, Wealth and Legacy™ Group may decline to proceed with the relevant arrangement or transaction.

Related entities and ownership relationships

Wealth and Legacy™ Group may from time to time engage with related entities or other parties in which it, its shareholders, directors or associates have an interest. The existence of such a relationship does not determine whether a service or product is recommended to a client.

Any actual or potential conflict arising from such a relationship must be identified, appropriately managed and, where relevant, disclosed to the client. The client’s interests and the suitability of the service or product must remain the primary consideration.

A current record of associates and relevant ownership interests is maintained as part of our conflict-of-interest governance. Further information may be requested from .

Financial interests and remuneration

Wealth and Legacy Group (Pty) Ltd and its representatives may only receive or offer financial interests permitted under the applicable regulatory framework. These may include authorised commission or fees, fees agreed with clients, remuneration reasonably commensurate with services rendered, immaterial financial interests within the applicable regulatory limits, and other permitted financial interests for which fair value is paid.

We do not structure remuneration or financial interests in a manner that gives preference to the quantity of business secured to the exclusion of service quality, or that improperly incentivises preference for a particular product supplier or product where more than one appropriate option may be considered.

Gifts, hospitality and other benefits

Gifts, hospitality and other financial interests are subject to the limits and conditions permitted by law and to Wealth and Legacy™ Group’s internal disclosure and recording requirements. Relevant gifts and benefits must be declared and recorded so that any actual or potential conflict can be assessed and managed.

Disclosure to clients

Where a conflict of interest affects a client, we will disclose it in writing at the earliest reasonable opportunity. The disclosure will include, where applicable, the measures taken to avoid or mitigate the conflict, relevant ownership or financial interests, and the nature of any relationship or arrangement with a third party giving rise to the conflict, in sufficient detail to enable the client to understand its nature.

Internal controls and oversight

Employees and representatives are required to comply with the Conflict of Interest Management Policy and to raise potential conflicts before entering into an affected transaction or arrangement. Conflicts are considered through the company’s management and compliance processes and are subject to appropriate internal controls and record-keeping.

Non-compliance

Failure by an employee or representative to comply with the policy or to disclose an actual or potential conflict may constitute misconduct and may result in disciplinary or other appropriate remedial action.

Further information

Questions regarding this policy or a potential conflict of interest may be directed to .