How we identify, manage, and disclose conflicts of interest that could affect the advice we give you. Required under FAIS.
Last updated: April 2026
1.1 This policy sets out the arrangements OceanMind (Pty) Ltd maintains for the identification, avoidance, management, and disclosure of conflicts of interest arising in the provision of financial services. 1.2 The policy is maintained in accordance with the General Code of Conduct for Authorised Financial Services Providers and Representatives issued under the Financial Advisory and Intermediary Services Act, 2002. 1.3 It applies to all employees, representatives, directors, and authorised agents of OceanMind.
2.1 A conflict of interest exists where OceanMind, any representative, or any associate has an actual or potential interest — financial or otherwise — that may influence the objective performance of obligations to a client, or prevent the rendering of a fair and unbiased financial service. 2.2 Conflicts may arise between OceanMind and a client, between two or more clients, or between OceanMind and a product supplier.
3.1 Representatives are required to consider, at every stage of client engagement, whether any conflict exists or could reasonably be perceived to exist. 3.2 OceanMind maintains registers of: (a) financial interests received from product suppliers (commissions, fees, incentives); (b) ownership interests and relationships with third parties; and (c) associates as defined by the Act. 3.3 The registers are reviewed on a quarterly basis by the Compliance Officer.
4.1 Where a conflict can reasonably be avoided, OceanMind will avoid it. 4.2 Where avoidance is not reasonable, the conflict will be managed through one or more of: independent review of the recommendation by a second representative; oversight by the Compliance Officer; written disclosure to the client; or, where necessary, declining the engagement. 4.3 OceanMind does not operate financial-incentive arrangements for representatives that could bias recommendations toward a particular product or supplier. 4.4 OceanMind does not accept gifts, hospitality, or other benefits from product suppliers where, in aggregate, their value exceeds the threshold set from time to time by senior management. Any benefit received above this threshold must be disclosed to, and approved by, the Compliance Officer.
5.1 Before any recommendation is made, OceanMind discloses to the client in writing: the commission or fee payable to OceanMind in respect of the product; any ownership or relationship interest with the product supplier; and any other material interest relevant to the advice. 5.2 Disclosure is provided as part of the Statement of Intermediary Services, the Record of Advice, and the engagement-opening documentation. 5.3 Where disclosure is not sufficient to mitigate the conflict, OceanMind will decline the engagement or refer the client to an alternative provider.
6.1 OceanMind maintains commercial relationships with multiple product suppliers across short-term, long-term, and specialist lines of insurance. These relationships are commercial in nature and do not create any ownership, control, or other relationship capable of compromising independent advice. 6.2 A current list of product suppliers is maintained by the Compliance Officer and is available to clients on request.
7.1 All representatives receive training on this policy upon appointment and annually thereafter. 7.2 Breach of this policy is grounds for disciplinary action, up to and including termination of employment and reporting to the Financial Sector Conduct Authority. 7.3 The Compliance Officer maintains records of all disclosed conflicts, management steps taken, and outcomes, for a minimum of five years.
Effective date: April 2026 Version: 1.0 Next review: April 2027 Owner: Compliance Officer, OceanMind (Pty) Ltd This policy is reviewed annually by the Compliance Officer and senior management, and following any material change to the regulatory framework or the nature of OceanMind's business.
Questions? Contact our compliance team at info@oceanmind.co.za.