COMPLIANCE MANUAL

In terms of the Financial Advisory and Intermediary Services Act (FAIS)

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1. Introduction
   This Compliance Manual outlines the policies, procedures, and internal controls that MONO.insure Brokers (Pty) Ltd ("the FSP") has implemented to comply with the Financial Advisory and Intermediary Services Act, 2002 ("FAIS Act"), the General Code of Conduct, and other relevant subordinate legislation.
    

2. Business Information
   - Registered Name: MONO.insure Brokers (Pty) Ltd
   - FSP Number: 52923
   - Authorised Services:
        - Short-term Insurance – Personal Lines (1.2)
        - Short-term Insurance – Commercial Lines (1.6)
        - Long-term Deposits (1.17)
        -   Short-term Deposits (1.18)
        - Short-term Insurance – Personal Lines A1 (1.23)
   - Key Individuals: Andrew Lobban
   - Compliance Officer: Omega Compliance Solutions, c/o Bryan Thomas (Practice No. 7375)
   - Contact Details: bryan@omegacs.co.za
    

3. Complaints Procedure
   Complaints should be lodged in writing and directed to:
   Complaints Officer: Andrew Lobban
   Email: andrew@mono.insure
   Tel: +27 10 595 3899
    

4. Regulatory Framework
   MONO.insure complies with:
   - FAIS Act (Act No. 37 of 2002)
   - General Code of Conduct for Authorised Financial Services Providers
   - Fit and Proper Requirements (Board Notice 194 of 2017)
   - Determination of Categories of Financial Services Providers
   - FAIS Ombud Rules
    

5. Appointment of Representatives
   - Representatives are appointed in writing.
   - All representatives meet the Fit and Proper requirements in terms of honesty, competency, and operational ability.
   - MONO.insure maintains a central register of appointed representatives.
   - Supervision is in place for representatives under supervision as per BN194.
    

6. Conflict of Interest Management
   - The FSP maintains and implements a Conflict of Interest Management Policy.
   - All employees and representatives are trained on conflict identification and management.
   - Gifts and benefits are recorded in a Conflict of Interest Register.
   - Disclosure of conflicts to clients occurs before rendering any financial service.
    

7. Complaints Handling Procedure
   - The FSP has a documented complaints resolution process aligned with the General Code of Conduct.
   - Complaints are acknowledged in writing within 5 days.
   - Resolutions are provided within 6 weeks.
   - A complaints register is maintained and regularly reviewed.
    

8. Record Keeping
   - All client advice and transaction records are kept for a minimum of 5 years.
   - Documents are stored securely and are accessible for regulatory inspection.
   - Records include advice files, disclosures, application forms, and correspondence.
    

9. Risk Management & Internal Controls
   - Regular risk assessments are performed.
   - Compliance reports are submitted to the Key Individual quarterly.
   - Internal controls ensure separation of duties, access management, and transaction monitoring.
    

10. Advertising and Marketing
    - All marketing and advertisements are reviewed for compliance with Section 14 of the General Code.
    - Misleading claims, comparisons, and statements are strictly prohibited.
    - Marketing must include the FSP’s name and registration number.
     

11. Fit and Proper Monitoring
    - The competence, experience, and qualifications of representatives and key individuals are regularly monitored.
    - Continuous Professional Development (CPD) is tracked annually.
    - A training plan is in place and updated yearly.
     

12. Compliance Reporting
    - The Compliance Officer conducts regular monitoring and audits.
    - An annual compliance report is submitted to the FSCA.
    - The FSP maintains open communication with the FSCA.
     

13. Debarment
    - Representatives who no longer meet Fit and Proper requirements are subject to a fair debarment process.
    - Debarments are reported to the FSCA in the prescribed format and timeframe.
     

14. FAIS Ombud
    - Clients are informed of their rights to lodge complaints with the FAIS Ombud.
    - The FSP co-operates fully with any Ombud investigations.
     

15. Training and Awareness
    - All staff receive annual FAIS compliance training.
    - Induction training is provided to new staff.
     

16. Updates and Review
    - This manual is reviewed annually or upon regulatory updates.
    - Changes are approved by the Key Individual.

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(Published 1 June 2025)

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