Conflict of Interest Policy.

Our clients’ interests come first. This policy sets out how Alpina Brokers identifies, avoids and — where avoidance is not possible — mitigates and discloses conflicts of interest, so that the advice and service you receive is fair and objective.

A conflict of interest is any situation in which we or our representatives have an actual or potential interest that may influence the objective performance of our obligations to you, or prevent us from rendering an unbiased and fair service. This includes financial interests, ownership interests and relationships with third parties.

We and our representatives may only receive or offer the following financial interests:

• Commission authorised under the Insurance Act and the Short-term Insurance Act.
• Fees for specific services, agreed with you in writing and able to be stopped at your discretion.
• Fees or remuneration for rendering a service to a third party, reasonably commensurate with the service.
• Immaterial financial interests — as defined in the Code, not exceeding R1 000 in aggregate per product supplier per calendar year.

We do not accept any financial interest that is offered on the basis of the quantity of business placed with a specific insurer, or that gives preference to one product supplier over another.

Alpina Brokers is an independent intermediary. Alpina Brokers has no ownership interest in any product supplier, and no product supplier holds an ownership interest in Alpina Brokers.

• Identify: staff and representatives must declare any actual or potential conflict as soon as they become aware of it.
• Avoid: where a conflict can be avoided, it will be.
• Mitigate: where it cannot be avoided, we put controls in place — such as independent review of advice — to protect the client.
• Disclose: we disclose any conflict to you in writing, in a clear and timely way, so that you can make an informed decision.
• Record: all conflicts and gifts received are recorded in a conflict of interest and gift register.

All staff and representatives are trained on this policy. Our compliance officer monitors adherence and reports on it to the FSCA as part of the annual compliance report. Breaches of this policy are dealt with through our disciplinary processes.

This policy is published on our website and a copy is available on request from our offices, free of charge.