Conflict of Interest Policy

1. Introduction

At Tirhelo (Pty) Ltd, we recognise the importance of effective corporate governance — not only to uphold the integrity of our operations but to protect and serve the best interests of our clients. Our compliance framework is integrated into our overall risk management strategy, aligned with the requirements of the Financial Advisory and Intermediary Services Act (FAIS) 37 of 2002, and monitored through our appointed FAIS Compliance Officer and Key Individual(s).

This policy sets out Tirhelo's approach to identifying, managing and disclosing potential conflicts of interest in relation to the provision of financial services, and it complies with the General Code of Conduct, including Board Notice 58 as published in Government Gazette No. 33133 on 19 April 2010.

2. Scope and objectives

This policy applies to all Tirhelo employees, representatives and Key Individuals in the execution of their duties relating to financial service activities.

The objectives of this policy are to:

• promote transparency and ethical behaviour;
• provide a formal framework for managing and disclosing actual, potential or perceived conflicts of interest; and
• meet legal and regulatory requirements under FAIS and related legislation.

3. Governance and responsibilities

Tirhelo's conflict-of-interest governance is structured across three levels of responsibility.

Board and management

Key Individuals

Compliance Officer