CONFLICT OF INTEREST MANAGEMENT POLICY AS REQUIRED BY THE FAIS GENERAL CODE OF CONDUCT FOR THE LAWYER S VOICE PTY LTD FSP NO.32782

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1 CONFLICT OF INTEREST MANAGEMENT POLICY AS REQUIRED BY THE FAIS GENERAL CODE OF CONDUCT FOR THE LAWYER S VOICE PTY LTD FSP NO.32782

2 Definitions COI means conflict interest Conflict of interest means any situation in which a person has an actual or potential interest that may, in rendering a financial service to clients: a) Influence the objective performance of their obligations towards such client, or b) Prevent a person from rendering unbiased and fair financial service to the client, including but not limited to: A financial interest An ownership interest Any relationship with third party Compliance Officer means a compliance officer for an authorized financial services provider referred to in section 17 of the FIAS ACT. Employee for the purpose of this policy, will include All directors and full time employees of the Lawyer s Voice. All temporary contracted employees. All employed representatives excluding independent agents, and Associate Brokers. FIAS means the financial Advisory and Intermediary service Act. No. 37 of Financial Interest means any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, hospitality, accommodation, sponsorship, other incentive or valuable consideration, other than: a) An ownership interest b) Training that is not exclusively available to a selected group of providers or representatives, on Product and legal matters relating to those products; General financial and industry information; Specialized technological systems of a third party necessary for the rendering of a financial service Financial Service means any service contemplated in paragraph (a), (b), or (c) of the definitions of financial service provider, including any category of such services. FSB means Financial Service Board. Financial service provider means any person, other than a representative, who as a regular feature of the business of such person-

3 a) Furnishes advice; or b) Furnishes advice and render any intermediary service; or c) Render an intermediary service FSP means Financial Service Provider Immaterial Financial Interest means any interest with a determinable monetary value, the aggregate of which does not exceed R (one thousand rand) in any calendar year from the same third party in that calendar year received by- a) A provider who is sole proprietor; or b) A representative for that representative s direct benefit c) A provider, who for its benefits or that of some or all of its representatives, aggregates the immaterial financial interest paid to its representatives. Provider means an Authorised Financial Services Providers registered as such with the FSB. Representative means any person, including a person employed or mandated by such first-mentioned person, who renders a financial service to a client for or on behalf of a financial services provider, in terms of conditions of employment or any other mandate, but excludes a person rendering clerical, technical, administrative, legal, accounting or other service in subsidiary or subordinate capacity, which service- a) Does not require judgement on the latter person; or b) Does not lead a client to any specific transaction in respect of a financial product in response to general inquiries. Third party means a) A product supplier b) Another provider c) An associate of a product supplier or provider d) A distribution channel e) Any person who in terms of an agreement or arrangement with a person referred to in paragraphs (9a) to (d) above provides a financial interest to a provider or its representatives.

4 INTRODUCTION The objective of the Lawyer s Voice conflict of interest policy is to provide a framework within which to address areas where conflicts of interest may arise. It aims to establish broad principles and guidance and it prescribes processes that are essential to ensuring compliance with the code of Ethical Conduct applicable to Lawyer s Voice as well as other regulatory measures e.g. FIAS ACT. This policy aims to promote transparency and fairness in the interest of consumers, employees, providers and Lawyer s Voice. The policy defines how conflicts of interest are to be managed, that is, to identify potential conflicts, to avoid conflicts where possible and how to disclose. OBJECTIVES The objective of this policy is to provide a framework within which to address areas where conflicts of interest may arise. It aims to promote transparency and fairness in the interest of consumers, employees, providers and Lawyer s Voice. Managing of conflicts of interest Once a conflict of interest has been identified, it must be appropriately and adequately managed. 1. Avoidance of conflict of interest Once an actual potential conflict of interest has been identified, steps must be taken where possible, to avoid such a conflict. Should such avoidance not be possible, steps us be takes to mitigate and adequately manage such an actual or potential conflict of interest and the conflict of must be disclosed to all impacted parties. 2. Process and procedures to ensure Compliance The Compliance Office is responsible for managing and updating this policy and will provide guidance to Lawyer s Voice management thereon (including the preclearance of business process that potentially may cause a conflict of interest). The onus is on the individual subject to this policy to avoid creating conflict of interest, and if this is unavoidable, to take effect steps to mitigate such a COI and ensure that proper disclosure is made in respect thereof.

5 All employees are responsible for identifying specific instances of COI or potential COI and are required to notify the Compliance Office of any conflicts of interest they become aware of. The compliance Officer will escalate the conflict of interest to the MD with recommendation as how the conflict of interest should be managed if it cannot be avoided. Documentation and process which have been formulated to identify, avoid, mitigate and disclose conflict of interest include the following: a) The central register for the recording of conflict of interest b) Continuous monitoring of compliance to the COI policy Employment contract must include the necessary termination and/or sanction clauses to manage the risk of an actual or potential conflict of interest situation created by employee s acts or omissions. Disciplinary procedures in Lawyer s Voice must provide for the review of any breach by employees and determine appropriate sanctions. If employees are of the view that their own conduct has caused this policy to be breached, they must inform their manager at the earliest available opportunity after they have become aware of the breach. Management must report this breach to the Compliance Officer for further investigation. When employees reasonably suspect that a co-worker a contractor is in a breach of this policy, they must report it as soon as possible and in their strictest of confidence, to their manager of the Compliance Officer for further investigation. 3. Disclosure of conflict of interest The Lawyer s Voice and its employees must at all the earliest reasonable opportunity disclose to client any conflict of interest in respect of that client and all other impacted parties. The disclosure must be made in writing to the client and contain the information which included, but is not limited to: a) The measure taken in accordance with this policy, to avoid or mitigate the conflict; b) The nature of any relationship or arrangement with a third party that gives rise to a conflict c) Informing the client of the existence of the COI policy and how this document may be accessed. Accessibility of policy This policy document will be available on the website to ensure that it is easily accessible by employees, clients, and third parties at all reasonable times.

6 Training and awareness All Lawyer s Voice employees, contractors, temporary workers will be annually receive appropriate training and awareness on this policy. All newly recruited employees should attend a training session during their induction program. Consequences of Non- Compliance The FIAS Act provides for penalties in the event that a person is found guilty of contravening the Act, or of non-compliance with the provisions of the Act. The registrar of the FIAS is empowered to refer instance of non- compliance to an Enforcement Committee that may impose administrative penalties on offenders. The FIAS ACT gives the Registrar the power to revoke the license of an FSP. Employees failure to provide disclosures will be seen as a transgression of the Code of Conduct and will be dealt with in terms of The Lawyer s Voice Disciplinary Procedures. Certain transgressions of this policy may result in civil or criminal prosecution. All potential transgressions of this policy must be investigated fairly and objectively and be reported by the relevant compliance department to the MD s office for decision. Revision This policy document shall be reviewed annually and submitted to the Managing Directors for evaluation and amendment where necessary.