Conflicts of interest

MidSquare Capital (Pty) Ltd maintains a Conflict of Interest Management Policy in terms of the General Code of Conduct under the Financial Advisory and Intermediary Services Act, 37 of 2002. This page summarises the policy; a copy of the policy is available on request by email to info@midsquare.io.

What we treat as a conflict. A conflict of interest is any situation in which the firm or a representative has an actual or potential interest that may influence the objective performance of obligations to a client, or prevent the rendering of unbiased and fair financial services to a client or acting in a client's interests. This includes financial interests, ownership interests, and relationships with third parties such as product suppliers, other providers and distribution channels.

How conflicts are managed. The primary responsibility for identifying conflicts rests with the firm's representatives, employees and directors, who are required to test every financial service against the policy's identification questions. Identified actual or potential conflicts are escalated to the key individuals and the board of directors, which determines whether the conflict can be avoided and the appropriate course of action; where a conflict is avoidable its cause is removed, and where it is genuinely unavoidable the reasons are recorded and the conflict is mitigated, monitored and reported to the Financial Sector Conduct Authority through the firm's compliance reporting.

Financial interests and gifts. The firm and its representatives may give or receive financial interests from or to third parties only as permitted under the General Code of Conduct. Immaterial financial interests received by representatives are recorded in the firm's gift register. Representative remuneration may not be structured to reward the quantity of business secured without due regard to fair outcomes for clients, or to reward preference for a particular product supplier or product.

Disclosure to clients. At the earliest reasonable opportunity the firm and its representatives disclose to a client, in writing, any conflict of interest in respect of that client, including the measures taken to avoid or mitigate it, any relevant ownership or financial interest, and the nature of any third party relationship giving rise to the conflict, in sufficient detail for the client to understand its exact nature. Clients are also informed of this policy and how it may be accessed.