An Authorised Financial Services Provider FSP 5311 TREATING CUSTOMERS FAIRLY (TCF) POLICY STATEMENT

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1 An Authorised Financial Services Provider FSP 5311 TREATING CUSTOMERS FAIRLY (TCF) POLICY STATEMENT

2 TREATING CUSTOMERS FAIRLY (TCF) POLICY STATEMENT 1. Introduction: Niche International Brokers (Pty) Ltd, as an authorised financial services provider, has a strong focus on customer satisfaction. Our mission is to be a respected and recognised provider and our Treating Customers Fairly (TCF) policy is an integral part of that objective. Our TCF policy is structured according to the guidance provided by the Financial Services Board to ensure we consistently deliver fair outcomes to our clients. We take responsibility for Niche International Brokers (Pty) Ltd and all staff providing an enhanced service quality to clients, based on a culture of openness and transparency. 2. The six fairness outcomes: Niche International Brokers (Pty) Ltd will strive to comply with and contribute to the TCF fairness outcomes, viewed from the perspective of the customer: Outcome 1: Customers are confident that they are dealing with providers where the fair treatment of customers is central to the provider s culture. Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified customer groups and are targeted accordingly. Outcome 3: Customers are given clear information and are kept appropriately informed before, during and after the time of contracting. Outcome 4: Where customers receive advice, the advice is suitable and takes account of their circumstances. Outcome 5: Customers are provided with products that perform as providers have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect. Outcome 6: Customers do not face unreasonable post- sale barriers to change product, switch provider, submit a claim or make a complaint. 3. Achieving the outcomes: Niche International Brokers (Pty) Ltd will aim to demonstrate through our behaviors and monitoring that we are consistently treating customers fairly throughout the stages of the product life cycle to which we can contribute. These may include: Product and service design: Products and services and their distribution strategies are designed and developed for specific target markets, based on a clear understanding of the likely needs and financial capability of each customer group. Promotion and marketing: Products are marketed to specific target groups, through clear and fair communications that are not misleading and are appropriate to the target group. Advice: Where advice is provided, advisers are fully equipped to provide advice that is suitable to the needs of the

3 customer concerned, following the objectives of TCF and avoiding conflicts of interest. Point- of- sale: To provide clear and fair information to enable customers to make informed decisions about transacting with Niche International Brokers (Pty) Ltd, our products and services. Product risks, commitments, limitations and charges must be transparent. Information after point- of- sale: To provide customers with ongoing relevant information to enable them to monitor whether the product or service continues to meet their needs and expectations, and provide acceptable levels of service for post sale transactions or enquiries. Complaints and claims handling: To honor representations, assurances and promises that leads to legitimate customer expectations. Legitimate expectations must not be frustrated by unreasonable post- sale barriers. There is a requirement for fair and consistent handling of claims and a mechanism to deal with complaints timeously and fairly. OUTCOME 1: Customers are confident that they are dealing with providers where the fair treatment of customers is central to the providers culture All business spheres of Niche International Brokers (Pty) Ltd, will be affected by TCF and must adhere to the requirements of TCF. Recruitment processes shall adhere to TCF objectives as set out in the Companies Policy Manual which will stipulate the minimum standards and qualifications for existing personnel as well as when appointing new personnel. Senior management and Key Individuals will be responsible for the implementation and enforcement of TCF principles and objectives. Monthly TCF reports will be submitted to the TCF Forum. Quarterly audits will be conducted by the appointed compliance officer of the FSP to determine the compliance and progress with TCF. TCF training will be provided to all the employees on an annual basis. OUTCOME 2: Products and services which are marketed and sold are designed to meet the needs of identified customer groups and are targeted accordingly Products and services that are marketed and sold, must be designed to meet the needs of identified customer groups and targeted accordingly. Customers can be broadly grouped into two categories: Sole Traders Companies (Pty Ltd, Ltd, cc & Inc) The product provided will be analysed to ensure that it is suitable to that particular market segment, satisfy the needs of that market segment and the commission or fee will be justifiable. A financial needs analysis is done on each consumer. Correct information will be collated in order to provide the necessary quotations. The quotations will be set out in in a manner that the customer understand the products and services offered as well as the explanations given and the information supplied. Each product suppliers quotation will be analysed to ensure that the product provided is right for the customer. An annual critical review of all products will be performed where after the TCF forum will decide on discarding or promoting the specific products.

4 OUTCOME 3: Customers are given clear information and are kept appropriately informed before, during and after the time of contracting Customers will at all times be given information that is clear and will at all times be kept informed. Financial advisers must understand the needs of the customers, and communicate information and marketing material to them in a way which is clear, fair and not misleading. Appropriate advice consist of the quality of advice, impartiality of advisers, assessing customer needs, clear communications and on- going advice. Disclosure is essential to enable customers to understand and iddentify the product they are buying and to help them understand whether and why it meets their requirements. Customers must be kept aware of the products performance, as well as their rights and changes in the terms and conditions. W will ensure that all sales and marketing material are written using plain English, and technical terms will be fully explained. All costs and charges will be accurate and disclosed to the customer, and all the terms and conditions associated with the product will be clear and in simple terms. All charges, including any early termination charges, will be highlighted and made clear. All correspondence before, during and after sales with the customers will be kept and will be easily accesible and retrievable. A record of provision of all the disclosure documents (initial disclosure, product disclosure, quotations, and any other written document explaining or containing information on the product) will be kept, notes on telephone calls and meeting conversations will be kept and easily retrievable. We will keep in contact with customers after the product has been sold. All customer contacts will be recorded on our database. Clarity, appropriateness and fairness of information will be assessed prior being communicated to customers. All marketing material will be signed- off by a member of the TCF forum. Before and during contracting the financial advisers will ensure that information provided is accurate and applicable to the customers in order for the customer to make an informed decision. Customers will be adequately informed of product changes in good time. Contact details of customers will be maintained. Customers will have a dedicated administrator allocated to them if they need information. OUTCOME 4: Where customers receive advice, the advice is suitable and takes account of their circumstances Where customers receive advice, it will be suitable and will take account of their circumstances. Financial advisers always receive detailed training on product technicalities with a strong focus on risks. Knowledge is always tested with case studies. Financial advisers are actively encouraged to achieve a qualification. We will, before deciding to market a product, assess whether we have the appropriate skills and business processes in place to provide advice and service that will be suitable for the target market and the product concerned. The Conflict of Interest Management policy is personalised to enable us and our representatives to identify and address any conflicts of interest between the FSP, the customers and the product providers whose products are marketed. We will regularly monitor the published decisions of the FAIS Ombud, guidance from the FSB and other relevant information sources in relation to advice practices, to ensure that our controls and practices in relation to the suitability of advice remains relevant and effective. We expect of product providers to, before contracting with any product provider to market their products, conduct an appropriate level of due diligence to satisfy them that their products and service levels are likely to meet our customers' reasonable expectations. Product providers will provide the FSP and our representatives with adequate training on the specific products the FSP markets to be in a position to provide our customers with suitable advice on those products. The training register will be kept up to date. We will have reasonable access to any product information required from the product provider in order to provide suitable advice. We will provide product suppliers with feedback in relation to any aspects of their products or services which inhibit our ability to provide suitable advice or deliver other TCF outcomes to customers.

5 Agreements between the FSP and the product providers whose products we market must set out the respective responsibilities in relation to providing customers with advice, information and service support. Customers must understand who they should look to in relation to different aspects of the financial products or service provided to them. We will regularly test the representatives knowledge and skills on the products of the FSP and market and prevent our representatives providing advice on products where they do not have adequate product training. We will record and monitor feedback or complaints received from customers, product suppliers or other third parties regarding the quality of advice they have received from the representatives, to identify any training needs and/or risk of inappropriate advice. We will conduct regular monitoring on the advice and services the representatives provide customers to identify instances and mitigate the risk to customers where the representatives have provided inappropriate advice or misleading information to customers. We will record and analyse insurance claims, early termination data, type and frequency of product changes in relation to the customers associated with the representatives, to identify and mitigate risks of inappropriate advice or poor customer outcomes attributable to the representatives concerned. Clear TCF measures are included in the criteria that the representatives are required to satisfy to meet incentive or remuneration targets, regardless whether the remuneration or incentive is determined by the product provider or by the FSP. The FSP will implement controls to identify and act on instances where the representatives have provided advice which they are not authorised to provide, either in terms of their specific contract or mandate with the FSP and/or with any product provider, or as a result of non- compliance with the FSP s FAIS licence conditions or other legal requirements OUTCOME 5: Customers are provided with products that perform as providers have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect The FSP s products must perform as they have led their customers to expect and the associated service must be of an acceptable standard. Customers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect. The foundation of complying with this is found in the General Code of Conduct speaking about the annual review process. Section 7(4) A provider who has provided advice to a customer or is rendering on- going financial services to the customer in respect of one of more financial products, must on a regular basis (but not less than annually) provide the customer with a written statement identifying such products where they are still in existence, and providing brief current details of: Any on- going monetary obligations of the customer in respect of such product The main benefits provided by the products Ongoing training to be provided on the product sold Any on- going incentives, commission, fee or brokerage payable to the provider in respect of such products. An annual review process includes keeping close to the customers, keeping them informed and delivering on the promises made, provide the customers with an annual written statement containing the information as set out in Section 7(4) above and processes will be in place to alert the customers to the risks of non- action on their part, such as a failure to review insurance cover needs. To annualy gather and analyse the customers needs and to identify risks where products or services are not meeting expectations created, and to test the service standards to determine whether they are in line with customer expectations and monitor and act on feedback, complaints and suggestions received from customers or staff that identify the need for improvements in types of services offered and/or service standards. Processes are in place to protect customer information as required by legislation.

6 OUTCOME 6: Customers do not face unreasonable post- sale barriers to change product, switch provider, submit a claim or to make a complaint There are no unreasonable post sale barriers to change product, switch provider, submit a claim or make a complaint. We have appointed a dedicated complaint handler with appropriate authority to resolve the complaint and to ensure a consistent message and regular updates for the customer. Customers will be informed timeously and guided as to how to make changes or modifications to the product that they have taken, should their needs change. Customers will be informed of the risk of switching providers, and this will impact on their business. Complaints will be responded to in writing and reasons for the decision will be provided. 4. In order to fulfill our commitment to treating our customers fairly we will focus on the following aspects: We will follow the requirements of the FAIS General Code of Conduct as embedded in the FIA Code of Conduct. We will adhere to our Conflicts of Interest policy in dealing with customers. We will put management information mechanisms in place that are designed to monitor and measure Niche International Brokers (Pty) Ltd s performance in delivering the relevant fairness outcomes. All our members of staff are trained to deal with our clients and are committed to maintaining high standards of service. Our staff are not remunerated or incentivized in ways, which encourage them to deal with our clients in an unfair or biased manner. We will always tell customers what they can expect from our relationship. We will provide appropriate after sales information and service to customers. We will monitor the continuing performance of products or funds that we have recommended and sold to customers to assess the ongoing suitability of the product for the customer. We will ensure open communication lines with product suppliers we deal with and ensure that we understand their products and services. We will review our TCF policy on an ad hoc basis but at least annually. 5. Complaints handling: We will handle complaints fairly, promptly and impartially. In dealing with complaints we will treat like situations alike' and give careful consideration to whether an error might have affected a wider class of customers; and what should be done to remedy this. We will pay attention to the outcomes of complaints, which can serve as an important source of intelligence about the health of our business and systems. We will investigate the root causes of complaints and obtain feedback from customers who have experienced our complaints process in order to improve the level of service that we provide. We will measure the length of time taken to deal with a complaint, the outcome, and the way in which the outcome is communicated to the customer in order to ensure that we are treating our customers fairly.

7 6. Treating Customers Fairly in our business: We encourage and welcome feedback from staff and customers on our services and procedures. Staff objectives include TCF as an explicit and measurable objective and performance against this objective will form part of staff competency ratings. All staff will complete refresher training and testing on an ad hoc basis. Before we contract with a third party we will satisfy ourselves of their commitment to treating our customers fairly. In particular, we will consider their TCF policy and the management information that they can provide to demonstrate the fair treatment of our customers. Our complaints process will be clear and easy to understand. For any queries or feedback in relation to Treating Customers Fairly at Niche International Brokers (Pty) Ltd you can contact us at the following contact number or e- mail address: Contact person: Jolien Brough Telephone: Fax: Post: P O Box 4458, Honeydew, 2040 APPROVED AND IMPLEMENTED ON: 6 January 2014

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