Conflict of Interest Management Policy

FSP Details

FSP Name: Holtzhausen Financial Services (Pty) Ltd

FSP Number: 10002

Key Individual: BJP Holtzhausen (ID: 5907115097082)

Representative: MM Holtzhausen (ID: 6405210070087)

Background

Holtzhausen Financial Services is a proprietary limited company (Reg No. 1999/23849/07), wholly owned by the Benmar Family Trust. It employs two directors and four additional staff members, three of whom are administrative personnel.

The company does not hold any interest in product providers. It operates as a brokerage for employee benefits, medical schemes, life assurance, and investments, with broker contracts across multiple assurers, CIS managers, and LISPs. Provider details are available in our company profile and disclosure documents.

Holtzhausen Financial Services maintains a Satellite Front Office agreement with Sanlam Employee Benefits, trading as Holtzhausen Group Risk. Most group risk schemes are placed here due to superior administration support.

Potential conflicts may arise where this arrangement offers higher administrative fees than other regulated commissions. It is our policy to disclose all related fees and revenues clearly to clients.

Premium Handling

Client premiums are paid into a dedicated account and transferred to Sanlam Employee Benefits. Operational fees are only transferred after risk premiums are confirmed as paid.

Policy Objective

This policy aims to document existing conflict management procedures as required by the FAIS Act and Board Notice 58 of 2010. We commit to identifying, managing, and mitigating conflicts of interest in a structured and transparent way.

Mission Statement

We are committed to conducting ethical and fair business, safeguarding stakeholder interests, and minimizing real or perceived conflicts of interest by:

  • Identifying risks that may harm client interests.
  • Implementing controls and structures to manage conflicts.
  • Maintaining ongoing prevention and disclosure practices.

Key Definitions

Conflict of Interest

A conflict may arise when we do not act objectively or in your best interest. This includes:

  • Financial interest
  • Ownership interest
  • Relationships with third parties

Financial Interest

Any form of benefit exceeding R1,000 per annum, unless it is:

  • Ownership interest
  • Training related to product knowledge or technology (excluding travel/accommodation)

Ownership Interest

Equity or proprietary interest for which a fair value was paid, including dividends and profit shares.

Permissible Remuneration

We only accept financial interest from providers in forms allowed by legislation:

  • Commission under Long-term/Short-term Insurance Acts
  • Fees under the Medical Schemes Act
  • Agreed service-based fees
  • Remuneration from third-party services
  • Immaterial financial interests or fairly compensated value

Remuneration Policy

We aim to transition to fee-based remuneration where permitted. We do not exceed 30% commission from any one provider and avoid minimum targets or perverse incentives. Representatives receive a fixed salary plus performance bonuses.

Internal Controls

Conflict Identification

We assess all potential conflicts where our interests may not align with client interests. Key examples:

  • Financial gain at client's expense
  • Biased advice due to relationships or incentives
  • Client information misuse

Register & Monitoring

We maintain a comprehensive conflict risk index, reviewed annually. Staff must report all conflicts to the Key Individual for assessment and action.

Mitigation Measures

  • Staff training on FAIS and the General Code of Conduct
  • Ongoing monitoring of all commissions and incentives
  • Disclosure to clients when conflicts arise
  • Annual review and public availability of this policy
  • Right to decline acting where conflict is unmanageable

Ongoing Monitoring

The policy is reviewed annually and forms part of the FSB compliance report. BJP Holtzhausen oversees monitoring, with compliance officer support. Non-compliance is subject to disciplinary action and may lead to dismissal or debarment.

Training & Induction

All staff and reps must read Board Notice 58 and this policy, confirm understanding, and undergo annual refresher training. The Key Individual conducts regular spot checks for compliance.

Representative Incentives

No incentives are offered for:

  • Prioritizing volume over service quality
  • Favouring one supplier over others
  • Promoting a specific product over others

Registers Maintained

Holtzhausen Financial Services maintains the following registers:

  • Nature and extent of ownership interests
  • Financial interests received
  • Nature and extent of business relationships
  • Associations

No current ownership interests or exclusive training obligations exist with product suppliers. Any future conflicts will be disclosed accordingly.