Conflict of Interest Policy
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.
Scope & Objectives
This policy applies to all Tirhelo employees, representatives, and Key Individuals in the execution of their duties relating to financial service activities.
- Promote transparency and ethical behaviour.
- Provide a formal framework for managing and disclosing actual, potential, or perceived conflicts of interest.
- Meet legal and regulatory requirements under FAIS and related legislation.
Governance & Responsibilities
🔹 Board & Management
Approve and oversee implementation of this policy.
Ensure all staff are trained and aware of conflict disclosure obligations.
Make this policy publicly available via the Tirhelo website.
🔹 Key Individuals (KIs)
Oversee FAIS-related functions and monitor employee and representative conduct.
Review declarations and ensure proper reporting to the compliance function.
🔹 Compliance Officer
Maintain the Conflicts of Interest Register.
Support management with training, monitoring, and compliance reporting.
Assist in assessing disclosures and advising on mitigation.