compliance

The Financial Advisory and Intermediary Services Act 37 of 2002 (FAIS Act) and the subordinate legislation aims to promote consumer protection and regulates the quality of financial advice as well as selling of financial products. For you as our valued client it means you are entitled to full transparency and disclose of information and fees any financial product sold to you.

Our organisation believes that the fair treatment of customers is essential to the success of its business.  Customers are our most valuable asset and are a key stakeholder in the business, both directly and because of the influence the quality of the customer experience has on the businesses’ relationships with other crucial stakeholders.

We are fully committed to providing the highest standards of customer-centric financial services and our aim is to ensure we deliver a user-friendly, robust, reliable, and cost-effective service. Treating Customers Fairly principles (TCF) are applied across all business sectors in the course of our general business activities.

Our treating customers fairly (TCF) policy is centred around the guidance provided by the financial services Regulator to ensure we consistently deliver fair outcomes to our customers and take responsibility for the business and staff (at all levels) providing an enhanced service quality to customers, based on a culture of openness and transparency.

The FFG Group of Companies are obligated to keep proper records of all transactions and client contacts. All our financial advisers are licensed with the Financial Sector Conduct Authority (FSCA), the regulating body that ensures that all representatives fulfilling the roles as Financial Advisors, Financial Planners, Portfolio Managers and Healthcare Consultants are properly trained to an acceptable industry standard.

All our representatives will be able to show you a copy of the respective FSP’s license as well as their Disclosure Notice. In terms of the FAIS Act, you will be required to sign a mandate which will ensure that your instructions are carried out in accordance to agreed parameters and shared understanding.

It is the policy of the FFG Group of Companies to provide its clients with a fair and formal complaints resolution system which enable them to exercise their rights as provided for by the Financial Advisory and Intermediary Services Act 37 of 2002 (FAIS Act).

The complaints policy forms part of the compliance framework. It serves to ensure an accessible, effective, appropriate, and fair system for the recording and resolution of all complaints, in order to ensure the fair treatment of stakeholders.

The policy gives clear and concise rules when managing complaints to ensure the compliant, successful, and fair resolution thereof.

Where a complaint arises, these are viewed as an opportunity to engage with our clients, repair relationships and improve our process and service.

Complaints management processes and procedures must at all times be transparent, visible and accessible. The process to lodge a complaint is communicated to our clients in disclosure documents and is available on our website and in our branches.

Clients will not be charged for lodging complaints.

Complaints Officer Details:

Laryn Fourie

Tel: 018 293 0656

Email: compliance@ffg.co.za

The objective of this policy is to establish a framework which will enable the FFG Group to address any conflicts of interest that may arise during the course of rendering financial services.

This policy provides for identifying, managing, avoiding, and disclosing potential conflicts of interest and the process for obtaining a conflict-of-interest review.

No illegal or unethical conduct is in our best interests, and we will not compromise our principles for short-term advantage.  All staff members are therefore expected to adhere to high standards of personal and professional integrity.

Conflicts of interest arise when someone has an affiliation or interest that will or may compromise, or have the appearance of compromising, their impartiality, incentive and/or ability to fulfil their duties, to clients.

The Financial Intelligence Centre Act 37 of 2001 (FICA) aims to combat money laundering, terrorist financing and proliferation financing.

It is the policy of the FFG Group of Companies to ensure that there is an effective, implemented, and compliant risk mitigation program to combat the risk of money laundering, terrorist financing and proliferation financing.

Money laundering is any act designed to hide or disguise funds obtained through illegal, unlawful, or criminal activities. Money launderers do not want to be linked to “dirty” money and they employ techniques, procedures or processes designed to hide the criminal nature of proceeds of crime. This includes hiding the true origin, ownership or any other factors which may show an irregularity.

Terrorism financing is the financial support of terrorism or of those who encourage, plan, or engage in terrorist activities. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes.

Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex. This means raising, moving, or making available funds or other economic resources/assets to assist, in whole or in part, with the proliferation of nuclear, chemical, or biological weapons, i.e., weapons of mass destruction (WMDs).

Client identification means ensuring we know who we are transacting with. This means checking a client’s (and related parties) identity by collecting and verifying information before providing any services to them. We identify both individual customers (people) and non-individual customers (such as companies, close corporations, or trusts).  After checking a customer’s identity, we must be satisfied that:

• an individual customer is who they claim to be.
• a customer who is not an individual is a real entity (a business or organisation that actually exists) and that the identity of the beneficial owners are verified.
• a payer, who is different to a client, really exists and is who they claim to be.
• a beneficiary who is different to a client, really exists and is who they claim to be.

Verification is a process of corroborating the person’s identity by comparing information provided by the client with information contained in documents or electronic data issued or created by reliable and independent third-party sources (such as officially issued identification documents).

All copies of the client due diligence documents obtained must be clear, legible and contain recognizable images. Where we originally sight a document, we ensure that we check the original for any tampering or discrepancies, for irregular numbers, the photo against the person, and whether details match when more than one document is presented etc.

All identification and verification documents are stored securely and confidentially for 5 years after the termination of the relationship with the client.

Failure to provide the required information and verification will usually result in our suspending any transaction until full compliance or terminating the relationship. Where this would result in tipping off a client about whom we are going to make a report, we may continue to provide services provided we submit a report to the Financial Intelligence Centre.

A suspicious financial transaction is one which is unusual or improper and is not always related to a certain criminal act. There is no standard characteristic as it is influenced by variation and development of existing financial services and instruments. General characteristics of Suspicious Financial Transactions, which can be used as a reference, include those noted below.  The existence of one or more of the factors described in this list require increased scrutiny of the transaction and person.

Any person has the right to know whether we hold any personal information about them, and where we receive a request like this, we must be able to provide the person with this information. Data subjects have the right to request a description of the personal information we hold about them as well as request copies of the actual records. They also have the right to request the details of all third parties, or categories of third parties, who currently have, or have had, access to their personal information.

This means that we must have a record of all the personal information we hold, records of which 3rd parties have access to what, and be able to produce copies of the information where necessary. This should be regularly brought up to date and be accessible to whoever will be dealing with data access requests.

Where we receive requests for access to personal information, these must be treated with confidentiality and managed in accordance with internal procedure, taking into consideration the rights and responsibilities of all affected parties.Decisions made in respect of access to information will be in accordance with the requirements of the Protection of Personal Information Act, as well as the Promotion of Access to Information Act.

Our procedures must ensure that where information or records are provided to a data subject, this is done:

• Lawfully and reasonably
• within a reasonable time or required timeframes
• in a reasonable manner
• in a generally understandable form

Where access to information is denied, this will be done fairly, ethically, and according to internal procedure on the basis of sounds and lawful reasons only.

We do not charge a fee to confirm whether we hold personal information about a data subject or not, but a regulated fee will be charged when providing copies of the information that we hold.

As required by section 51 of the Promotion of Access to Information Act, 2000 (PAIA) and to address the requirements of the Protection of Personal Information Act, 2013 (POPIA), The People Company has prepared a PAIA Manual.

The purpose of the PAIA Manual is to grant individuals access to their records if the record that is requested by the individual assists in exercising or protecting their legal rights under the law, to be open and transparent about how The People Company handles personal information, to allow individuals to access and correct their personal information and to define the information which The People Company is legally obligated to disclose under both PAIA and POPIA. It should also explain how individuals can exercise their statutory rights in terms of the said acts with regards to their records and personal information dealt with by TPC.

Deputy Information Officer of the FFG Group of Companies

Laryn Fourie

Tel: 018 293 0656

Email: compliance@ffg.co.za