Last updated: 19 October 2026
This is a summary of our Conflict of Interest Management Policy, adopted in terms of section 3A of the General Code of Conduct for Authorised Financial Services Providers and Representatives. A full copy is available on request.
1. Our commitment
We act honestly, fairly and with due skill, care and diligence in the interests of our clients. Where an actual or potential conflict of interest exists, we will avoid it, or where it cannot be avoided, manage it and disclose it to you.
2. What is a conflict of interest?
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 financial service. This includes a financial interest, an ownership interest or a relationship with a third party.
3. Financial interests we may receive
We and our representatives may only receive or offer the following financial interests:
- Commission authorised under the Insurance Act and its regulations
- Fees for services, where the fee has been agreed with you in writing and can be stopped at your discretion
- Fees or remuneration for specific services rendered to a third party, where reasonable and commensurate with the service
- Immaterial financial interests (for example, small gifts or hospitality) up to the limit set by the General Code of Conduct, which are recorded in a gift register
- Remuneration of employees in the ordinary course of employment, which is not linked to the sale of a specific product supplier's products
We will not accept any financial interest that is not listed above, or any incentive linked to the quantity of business placed with one insurer over another.
4. Ownership and relationships
We hold no ownership interest in any insurer and no insurer holds an ownership interest in us. We place business with several insurers, listed in our FAIS disclosure.
5. How we manage conflicts
- Identifying potential conflicts when we take on new clients, products or relationships
- Comparing options from more than one insurer where appropriate, and recording the reasons for our recommendation in a record of advice
- Disclosing any unavoidable conflict to you in writing before rendering the service
- Keeping a register of conflicts and of immaterial financial interests received
- Training our staff and representatives on this policy and monitoring compliance
- Disciplinary consequences for breaches of the policy
6. Review
The policy is reviewed at least annually by our key individual and compliance officer, Horizon Compliance (Pty) Ltd.