Conflict of Interest Management Policy

Issued in terms of the General Code of Conduct for Authorised Financial Services Providers and Representatives, 2003 (as amended). Last updated May 2026.

1. Purpose

The purpose of this policy is to:

• Identify circumstances that may give rise to actual, potential, or perceived conflicts of interest
• Establish measures to avoid such conflicts where possible
• Mitigate, manage, and disclose conflicts that cannot reasonably be avoided
• Ensure compliance with section 3A(2)(c) of the General Code of Conduct under FAIS

2. What is a conflict of interest

A conflict of interest is any situation in which Heptagon, a representative, or any associate has an actual or potential interest that may, in providing a financial service to a client:

• Influence the objective performance of obligations to that client
• Prevent the rendering of an unbiased and fair financial service to that client
• Prevent the rendering of a financial service to that client in their best interest

This includes financial interests, ownership interests, and any relationships with third parties such as product suppliers or distribution channels.

3. Heptagon's structure and inherent conflicts

Heptagon operates through two licensed entities, each of which gives rise to specific structural conflicts that we manage transparently:

3.1 Heptagon Wealth (FSP 9968)

An independent Financial Services Provider with access to products across the entire market. Conflicts arising from this structure typically relate to the receipt of commission from product providers. We disclose all commission and fee arrangements to clients before advice is implemented.

3.2 Heptagon Capital (FSP 703)

An accredited Old Mutual franchise. This franchise relationship gives rise to a potential conflict where Old Mutual products may be considered alongside or in preference to products from other providers. We manage this conflict by:

• Disclosing the franchise relationship in writing to every client before advice is given
• Maintaining objective product selection criteria based on the client's needs and not the provider
• Through the dual structure with Heptagon Wealth, retaining genuine market access where the Old Mutual product range does not best meet client needs

4. Types of conflicts that may arise

4.1 Financial interests

Commission, fees, rebates, and any other monetary or non-monetary benefits received from product providers or third parties. Heptagon will:

• Disclose all financial interests received in respect of a client's product before implementation
• Not receive financial interests in the form of cash, gifts, prizes, or hospitality that exceed the de minimis threshold prescribed by the General Code of Conduct (currently R1 000 per third party per calendar year)
• Maintain a register of financial interests received above the de minimis threshold

4.2 Ownership interests

Any direct or indirect ownership interest in a product provider, distribution channel, or referral partner held by Heptagon, its directors, key individuals, or representatives. All material ownership interests are disclosed.

4.3 Relationships with associates

Heptagon may collaborate with attorneys, tax practitioners, accountants, trust administrators, and other professional partners. Where Heptagon has a referral or revenue-share arrangement with such partners, the arrangement is disclosed to affected clients.

4.4 Personal interests of representatives

Representatives may not place their own interests above those of clients. Personal account dealing, outside business activities, and other potential personal conflicts must be disclosed to the Key Individual and managed in line with this policy.

5. Avoidance, mitigation, and disclosure

5.1 Avoidance

Where possible, conflicts are avoided entirely, for example by declining business that cannot be conducted in the client's best interest, or by referring the client to an independent provider.

5.2 Mitigation

Where conflicts cannot be avoided, mitigation measures include:

• Independent review of advice by another representative or Key Individual
• Segregation of duties between advice and product implementation
• Limits on the acceptance of gifts, entertainment, and other non-cash benefits
• Ongoing training of representatives on conflicts of interest

5.3 Disclosure

Conflicts that cannot be avoided are disclosed to clients in writing prior to or as part of providing the relevant financial service. Disclosure includes:

• The nature of the conflict
• The measures taken to mitigate it
• The nature of any financial or ownership interest

6. List of associates and third parties

The principal third parties with whom we have an existing relationship that may give rise to conflicts include:

• Old Mutual and its affiliated entities, through our franchise relationship under FSP 703
• Product providers across the South African long-term insurance, short-term insurance, investment, retirement, and medical aid markets, from whom we receive standard commission and fees

A current register of financial interests and a full list of associates is available on request from the Compliance Officer.

7. Compliance and monitoring

Compliance with this policy is monitored by our Compliance Officer:

8. Breach and consequences

Any breach of this policy is treated seriously. Consequences may include disciplinary action up to and including termination of employment or termination of the relevant representative's mandate. Material breaches are reported to the FSCA in line with our regulatory obligations.

9. Review

This policy is reviewed at least annually by the Key Individual and Compliance Officer, and updated as required to reflect changes in our business, regulation, or industry practice.

10. Contact

Questions about this policy, or requests for the financial interest register or associate list, may be directed to:

Email: talktous@heptagonc.com
Telephone: +27 11 660 1291
WhatsApp: +27 60 541 4685