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Conflict of Interest

Loan Buddy Financial Services (Pty) Ltd – Conflict of Interest Management Policy

  1. Introduction

The purpose of this Conflict of Interest Management Policy is to ensure that Loan Buddy Financial Services (Pty) Ltd (“Loan Buddy”) and its representatives act in the best interests of our clients. This policy is designed to identify, avoid, and manage any actual or potential conflicts of interest that may arise in the course of providing financial services. Where conflicts cannot be avoided, we are committed to mitigating and adequately disclosing them to our clients.

This policy is implemented in accordance with the General Code of Conduct of the Financial Advisory and Intermediary Services Act (FAIS).

  1. Definitions
  • Conflict of Interest: Any situation where Loan Buddy or its representatives have an actual or potential interest that could affect the objective performance of their obligations to a client, or prevent them from acting in the best interests of the client.
  • Financial Interest: Includes cash, cash equivalents, vouchers, gifts, services, discounts, or any form of valuable consideration, excluding certain exempt interests such as training related to financial products or services.
  • Immaterial Financial Interest: A financial interest with a determinable value that does not exceed R1,000 in any calendar year from the same third party to Loan Buddy or its representatives.
  • Ownership Interest: Any equity or proprietary interest in Loan Buddy for which fair value was paid at the time of acquisition, excluding ownership held as a nominee on behalf of another person.
  • Third Party: Refers to any product supplier, another financial services provider, a distribution channel, or any person who provides a financial interest to Loan Buddy or its representatives.
  1. Purpose

The purpose of this policy is to:

  • Establish procedures to identify conflicts of interest.
  • Outline measures to avoid conflicts of interest, and where avoidance is not possible, provide reasons and steps to mitigate them.
  • Ensure proper disclosure of conflicts of interest to clients.
  • Establish internal controls and processes to ensure compliance with this policy.
  • Outline the consequences of non-compliance with this policy.
  1. Identifying Conflicts of Interest

Representatives and employees of Loan Buddy are responsible for identifying potential conflicts of interest when providing financial services to clients. They should evaluate whether:

  • Any situation exists that could influence their objective performance or obligations to the client.
  • Any situation prevents them from rendering an unbiased and fair service to the client.
  • Any situation prevents them from acting in the best interests of the client.

If any of these conditions are met, the representative must assess whether the conflict is due to a relationship with a third party or a financial or ownership interest. If a conflict of interest is identified, it must be disclosed immediately.

  1. Avoiding and Managing Conflicts of Interest

Where conflicts of interest cannot be avoided, Loan Buddy will take the following steps to manage and mitigate them:

  • Disclose the conflict to the client in writing.
  • Ensure the disclosure includes sufficient details for the client to understand the nature of the conflict.
  • Implement measures to mitigate the conflict and ensure it does not compromise the fairness and objectivity of the financial service provided.
  • Record the conflict of interest in Loan Buddy’s compliance manual and regularly review the situation to reassess its impact.
  1. Financial Interests

Loan Buddy may only receive or offer financial interests under the following conditions:

  • Commission or fees authorized under relevant legislation (such as the Long-term Insurance Act, Short-term Insurance Act, or Medical Schemes Act).
  • Fees agreed upon in writing by the client for services rendered.
  • Immaterial financial interests (up to R1,000 annually per third party).

Loan Buddy and its representatives may not offer or receive any financial interest that prioritizes business volume over the quality of service rendered to the client.

  1. Disclosure of Conflicts

Loan Buddy will disclose any actual or potential conflict of interest to the client in writing at the earliest opportunity. The disclosure will include:

  • The nature and source of the conflict.
  • The steps taken to mitigate the conflict.
  • Any financial or ownership interest involved.
  • Reference to this Conflict of Interest Management Policy and how clients can access it.
  1. Internal Controls and Compliance

To ensure compliance with this policy, Loan Buddy has implemented the following internal controls:

  • Regular reviews of relationships with third parties to assess any potential influence on objective service delivery.
  • Quarterly conflict of interest declarations by all representatives and employees.
  • A Gift Register for recording any gifts or financial interests received from third parties with a value exceeding R500.
  • Ongoing training to ensure representatives and employees understand their responsibilities regarding conflicts of interest.
  1. Consequences of Non-Compliance

Non-compliance with this policy will be treated as a serious matter. Representatives or employees who fail to disclose conflicts of interest may face disciplinary action, up to and including termination of employment.

  1. Review and Accessibility

This policy will be reviewed annually to ensure that it remains effective and up to date. It will be made available to the public upon request and published on Loan Buddy’s website.

For more information or queries regarding this policy, please contact:

Information Officer
Email: support@loanbuddy.co.za
Phone: 044 279 1151