Subject Title - INSETA

what measures were taken to avoid/mitigate the conflict.any ownership interest or financial interest, except an immaterialfinancial interest, that the provider or Representative may get.any relationship/arrangement with any third party that may be aconflict, in sufficient detail so that the client can understand therelationship and the conflict.A provider/rep, must, at the first reasonable opportunity inform a client ofthe conflict of interest management policy and how it may be accessed.Conflict of interest management policy1. Every FSP must have, maintain and implement the policy, and itmust:(i) Manage conflicts of interest as well as provide: mechanisms to identify conflict. methods to avoid conflict, or reasons for conflict andhow it is mitigated. methods to disclose conflict. processes etc. to ensure compliance with the policyand consequences for non-compliance.(ii) Specify the „type and basis‟ on which a Representative willqualify for a financial interest offered and that it is notprohibited.(iii) Include a list of all associates, names of 3 rd parties who havean ownership interest in the FSP (and vice versa) as well asinclude details regarding the nature and extent of theownership interest.(iv) The Policy must be easy to understand.2. The policy must be adopted by the Board.3. Employees, Representatives and associates must be aware of policywith training and educational material.4. Providers must monitor compliance with requirements pertaining toconflicts of interest and review the policy annually.5. The policy must be published in appropriate media and be easilyaccessible.The Compliance report must include a report on the policy, including detailspertaining to implementation of the policy, monitoring compliance with thepolicy and accessibility of the policy.148 © INSETA - Section 1 12a