CONFLICTS OF INTEREST MANAGEMENT POLICY

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

​​​​​​​​

1. Purpose and Scope
   This policy outlines MONO.insure Brokers (Pty) Ltd's (Mono) commitment to identify, avoid, and manage actual or potential conflicts of interest when rendering financial services, in accordance with the requirements of the Financial Advisory and Intermediary Services Act (FAIS Act) and its subordinate legislation.
   This policy applies to all directors, key individuals, representatives, and staff members of Mono.
    

2. Definition of Conflict of Interest
   A conflict of interest means any situation in which Mono or its representatives have an actual or potential interest that may:
   - Influence the objective rendering of financial services;
   - Impair their ability to act in the best interests of the client;
   - Result in the FSP or its representatives receiving a financial interest other than permitted by law.
    

3. Types of Conflicts of Interest Covered
   This policy addresses, among others:
   - Receiving or offering incentives (cash, gifts, travel, entertainment) from or to product suppliers or third parties;
   - Ownership interests in or by product suppliers;
   - Preferential treatment to certain clients or suppliers;
   - Personal financial interest in the outcome of services provided to clients;
   - Dual relationships, such as acting for both the insurer and the insured.
    

4. Measures to Avoid and Manage Conflicts
   Mono has adopted the following internal procedures to identify and mitigate conflicts of interest:
   - Gifts and Entertainment Register: All gifts, sponsorships, or hospitality exceeding R1,000 must be declared and recorded.
   - Financial Interest Limits: Only financial interest permitted under Section 3A(1) of the General Code of Conduct is allowed.
   - Training: All staff receive annual training on conflict identification and reporting obligations.
   - Disclosure: Any unavoidable conflict must be disclosed to the client in writing before rendering services.
   - Independence: All representatives are expected to act independently and in the best interest of the client.
    

5. Financial Interest Policy
   Mono does not:
   - Accept more than 30% of total annual income from a single product supplier;
   - Hold an ownership interest in any product supplier or associated entity (unless otherwise disclosed);
   - Offer or receive any non-cash incentives that contravene the FAIS Code.
   Only the following are permitted:
   - Commission as regulated in the Long-term/Short-term Insurance Acts;
   - Fees authorized by the client in writing;
   - Limited immaterial financial interests (maximum R1 000 per representative per year).
    

6. Reporting and Escalation
   All staff must report potential conflicts of interest to the Key Individual or Compliance Officer immediately.
   A log of reported conflicts is maintained and monitored quarterly.
    

7. Disclosure to Clients
   Before rendering a financial service that involves an actual or potential conflict of interest, the representative must disclose to the client in writing:
   - The nature of the conflict;
   - Any ownership or financial interest held;
   - The mitigation steps taken;
   - The client’s right to decline the service if uncomfortable.
    

8. Monitoring and Review
   This policy will be:
   - Reviewed annually;
   - Amended as needed to comply with regulatory updates;
   - Communicated to all staff and acknowledged in writing.
    

9. Access to Policy
   This policy is available:
   - On request by any client;
   - On MONO.insure’s website: https://www.mono.insure;
   - At the business premises during working hours.

​

(Published 1 June 2025)

​​​