Subject Title - INSETA

An FSP or representative may not avoid, limit or circumvent or attempt toavoid, limit or circumvent compliance through an associate or anarrangement involving an associate.A financial service must be rendered in accordance with thecontractual relationship and reasonable requests or instructions ofthe client, which must be executed as soon as reasonably possibleand with due regard to the interests of the client which must beaccorded appropriate priority over any interests of the provider or arepresentative.Transactions of a client must be accurately accounted for.The FSP involved must not deal in any financial product for own benefit,account or interest where the dealing is based upon advance knowledge ofpending transactions for or with clients, or on any non-public information thedisclosure of which would be expected to affect the prices of such product.These requirements include the following:A provider may not offer any financial interest to a representative ofthat provider for:(i) giving preference to the quantity of business secured for theprovider to the exclusion of the quality of the servicerendered to clients; or(ii) giving preference to a specific product supplier, where arepresentative may recommend more than one productsupplier to a client; or(iii) giving preference to a specific product of a product supplier,where a representative may recommend more than oneproduct of that product supplier to a client.Every provider, other than a representative, must adopt, maintainand implement a conflict of interest management policy that complieswith the provisions of the Act.A conflict of interest management policy must be adopted by the soleproprietor of a provider, the board of directors of a provider or, in thecase where a provider is not a company, the governing body of theprovider.A provider must ensure that its employees, representatives and,where appropriate, associates are aware of the contents of its conflictof interest management policy and provide for appropriate trainingand educational material in this regard.© INSETA - Section 1 12a 149