The purpose of this Conflict of Interest Management Policy is to protect the integrity of Anchorguard Insurance Brokers CC ("theCompany") and ensure that the Company conducts its business in a manner that is fair, transparent, and in the best interests of its clients. The policy provides guidelines to identify, manage, and disclose any actual, potential, or perceived conflicts of interest that may arise during the course of theCompany’s business activities.

This policy applies to all employees, directors, officers, contractors, consultants, and representatives of Anchorguard Insurance BrokersCC ("Representatives"). It covers all interactions with clients, insurers, service providers, and other third parties.

A conflict of interest arises in any situation where a Representative’s personal or financial interest conflicts, or appears to conflict, with the interests of the Company or its clients. This includes situations where a Representative's decisions or actions are influenced, or appear to be influenced, by personal gain, relationships, or interests. Examples of conflicts of interest include, but are not limited to:

Personal Financial Interest: A Representative has a financial interest in a client or service provider that could influence their decision-making.
Gifts and Hospitality: Accepting gifts, entertainment, or other benefits that could influence, or be perceived to influence, the decision-making process.
Outside Employment: Engaging in outside employment or business activities that could conflict with the interests of the Company or its clients.
Relationships: A close relationship with a client, insurer, or service provider that could influence, or be perceived to influence, professional judgment.

4.1 Identification: All Representatives are responsiblefor identifying any situations where a conflict of interest might arise. Thisincludes assessing whether their personal interests could improperly influence,or appear to influence, their actions or decisions in the course of theirduties.

4.2 Disclosure: If a Representative identifies a potentialor actual conflict of interest, they must promptly disclose it to their directsupervisor or the Compliance Officer. This disclosure should include the natureof the conflict, the parties involved, and any relevant information that wouldallow the Company to assess the situation.

Upon disclosure of a conflict of interest, the Company will take appropriate steps to manage the conflict to ensure that it does not negatively impact clients or the integrity of the Company’s operations.Management actions may include, but are not limited to:  

5.1 Recusal: The Representative may be required to recuse themselves from any decision-making process or activity that could be influenced by the conflict of interest.  
5.2 Disclosure to Clients: Where appropriate, the conflict of interest may be disclosed to affected clients to allow them to make an informed decision about whether to proceed with the services being offered.  
5.3 Monitoring: The Compliance Officer will monitor the situation to ensure that the conflict is being effectively managed and that no undue influence is being exerted. 
5.4 Mitigation Measures: In cases where a conflict of interest cannot be avoided, the Company will implement mitigation measures such as appointing an independent party to oversee the decision-making process or establishing firewalls to prevent the sharing of sensitive information.

6.1 Acceptable Gifts: Representatives may accept gifts, hospitality, or other benefits from clients, insurers, or service providers, provided that such acceptance does not create, or appear to create, a conflict of interest. As a general rule, gifts or hospitality should not exceed a nominal value of R1000 and should not influence, or appear to influence, business decisions. 

6.2 Reporting: All gifts or hospitality received byRepresentatives that exceed the nominal value threshold must be reported to theCompliance Officer. The Compliance Officer will maintain a register of suchgifts and hospitality.

7.1 Disclosure: Representatives must disclose any outside employment, directorships, or other business interests that may conflict with their duties at Anchorguard Insurance Brokers CC. This includes any roles that involve a financial interest or influence over decisions related to theCompany’s clients or services.  

7.2 Approval: Any outside employment or directorships thatmay create a potential conflict of interest must be approved by seniormanagement before the Representative can engage in such activities.

8.1 Compliance Officer: The Company will appoint a Compliance Officer who will be responsible for implementing and monitoring compliance with this Conflict of Interest Management Policy. The ComplianceOfficer will also provide training and guidance to Representatives on how to identify and manage conflicts of interest.  

8.2 Audits: The Company will conduct regular audits to assess compliance with this policy and to identify any conflicts of interest that may not have been disclosed or properly managed.  

8.3 Reporting: Representatives are encouraged to report any concerns or suspicions regarding conflicts of interest to the ComplianceOfficer or through the Company’s whistleblowing procedure.

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Failure to comply with this Conflict of Interest ManagementPolicy may result in disciplinary action, including termination of employment or contract, depending on the severity of the breach. The Company may also report non-compliance to relevant regulatory authorities if required by law.

This Conflict of Interest Management Policy will be reviewed annually or whenever there are significant changes in the Company’s operations or regulatory environment. Any amendments to this policy will be communicated to all Representatives and will take effect immediately upon approval by theCompany’s senior management.

Effective Date: 14 August 2024 
Review Date: 14 August 2025 

Approved by: Tony Wilmans  
Position: Director  
Date: 14 August 2024

This policy ensures that Anchorguard Insurance Brokers CC operates with the highest level of integrity and transparency, protecting the interests of its clients and maintaining the trust of all stakeholders.