We value your privacy.
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For more information, please see our privacy policy.

CL Intermediary Services (PTY) Ltd is an Authorised Financial Services Provider (FSP No: 51405) and is committed to complying with the Protection of Personal Information Act, 2013 (‘‘the Act”). The Act requires us to conduct ourselves in a responsible and lawful manner when collecting, processing, and storing (“processing”) your personal information, imposing obligations on us, as the responsible party, to protect your personal information.

1. We will only process personal information in a lawful and in a reasonable manner, that does not infringe on your rights. We will at all times abide by your constitutional right to privacy and the protection of your personal information and take steps to ensure that your personal information collected is accurate.

2. We will only process personal information, given the purpose for which it is processed, that is adequate, relevant, and not excessive. We process your personal information pertaining to your needs for BalooTM and Benefactor.lifeTM purposes. Full details of the manner in which we process personal information is more fully outlined in our Privacy Notice on our website.

3. CL Intermediary Services may disclose your personal information to subsidiaries, joint venture companies and/or an approved product or third party product supplier whose services are utilised for the provision of certain products and/or services. CL Intermediary Services may also disclose information where it has a duty or right in terms of legislation, or deemed necessary to protect the rights of CL Intermediary Services.

By completing our contact form, you confirm that you are aware and agree that we will be communicating with you by phone, email, WhatsApp, or electronically to offer and provide our products and services in respect of BalooTM and Benefactor.lifeTM needs. For more information on how we protect, process or store your personal information, you can view our privacy notices on www. clventures.co.za.

Introduction
CL Intermediary Services (Pty) Ltd and Capital Legacy Solutions (Pty) Ltd located at 1st Floor, Roland Garros, The Campus, 57 Sloane Street, Bryanston 2191 (“CL Intermediary Services”) respect and acknowledge the importance of protecting your Personal Information. This Privacy Notice sets out how CL Intermediary Services will process your Personal Information in the ordinary course of conducting its business and it also applies to CL Venture’s website. What personal information we collect

User information
CL Intermediary Services collects the information that you voluntarily submit, including the following:
• Personal Information – your full names, sex, gender, address, smoking status, highest education, identity number or passport number, employment number monthly income, banking details, email address, telephone number, cellular number, language preference, medical or health information (where applicable);
• Nomination of Beneficiaries, including Children’s details (if applicable);
• Intermediary and fulfilment preferences;
• Asset and liability values that make up the total value of your Estate;
• Online information - for example, cookies and IP address (your computer’s internet address), if you use our websites, apps and/or social media channels.
• Any other information required by CL Intermediary Services, suppliers, insurers, or third parties in order to provide you with an accurate analysis for BalooTM and Benefactor.lifeTM.
We may collect information that you submit when you contact customer support or provide feedback. We acknowledge that information about your health is special personal information as defined in the Protection of Personal Information Act. Please be assured that we will use that information strictly in accordance with applicable laws and for insurance purposes only to the extent that it is necessary for us to formulate the terms of the insurance contracts, dealing with changes to any policy and/or dealing with claims).

Information from other sources
This may include:
• Users providing your information in connection with referral programmes;
• Users requesting services for you or on your behalf;
• Publicly available sources;
• Data aggregators;
• Credit bureaus;
• Fraud prevention agencies;
• Marketing service providers.

Providing services and features
Your information will only be used for the purposes for which it was intended. These may include:
• application for Baloo, Benefactor/life or any amendments thereto;
• issuing a or providing a product or service and generally carrying out the transaction requested;
• managing and servicing your policy;
• processing your requests or instructions;
• Underwriting;
• to undertake credit reference searches and/or verification;
• assessing and processing claims;
• claims history and reporting;
• detection of fraud, crime, money laundering or other malpractice;
• conducting market or policyholder research and ensuring that the product and services remain relevant;
• provide you with information about our products and services from time to time via email, telephone or other means;
• auditing and record keeping;
• legal proceedings; and
• complying with legal and regulatory requirements.

Safety and security
We may use your data to help maintain the security of our services.

Customer support
CL Intermediary Services uses the information we collect to assist you when you contact customer support, including to:
• investigate and address your concerns;
• managing and servicing your policy;
• monitor and improve our response.

Communications from CL Intermediary Services
Subject to applicable laws, CL Intermediary Services may use information to communicate with you, regarding marketing materials. CL Intermediary Services may also use the information to promote and provide you with relevant adverts and content about our services.

How we collect personal information

We may collect your Personal Information in a variety of ways when you interact with us, including:

• a completed Application Form that gets completed and signed by you for processing;
• when you engage with us to solicit our products or services;
• when we respond to your enquiries and requests;
• as a result of communications between you and financial advisors or representatives;
• when we obtain feedback from you about our services; and
• when you access and use our websites.
We may also collect your Personal Information from third-party sources and third parties including public databases, business partners with whom we offer co-branded services or engage in joint marketing activities, and third parties that provide list enhancement or similar services, to the extent that this is permitted by applicable law. Where you provide Personal Information to us about third party individuals (e.g., information about your spouse, civil partner, child(ren), dependants or emergency contacts), where appropriate, you should ensure that such individuals are made aware of how their Personal Information will be used by us, by providing them with a copy of this Privacy Notice or otherwise making them aware of the manner in which we will use their Personal information.

Legal Grounds for Processing
By virtue of your engagement with CL Intermediary Services, you acknowledge that CL Intermediary Services shall have the right to process Personal Information provided to CL Intermediary Services by you or some other party, to enable CL Intermediary Services to fulfil its legal and contractual obligations. Personal Information may also be used based on the legitimate interests pursued by CL Intermediary Services or its affiliates, except where such interests are overridden by your interests or fundamental rights and freedoms which require the protection of your Personal Information. In the event that you refuse to permit CL Intermediary Services to utilise your Personal Information in the manner described in this Privacy Notice, CL Intermediary Services will not be in a position to offer you use of its services. CL Intermediary Services may share your information other than as described in this notice if we notify you and you consent to the sharing. In circumstances where you give us your consent for a specific purpose, you are entitled to withdraw that consent at any time. Be aware that in the event that you withdraw your consent, this will not affect any processing of your Personal Information that took place prior to such withdrawal and it will not affect the processing of your Personal Information where there are other lawful grounds for processing your Personal Information. You are responsible for informing CL Intermediary Services if your information changes.

Transfers To Third Parties
CL Intermediary Services may share the information we collect with: CL Intermediary Services subsidiaries and affiliates We share information with our holding companies, shareholders, subsidiaries and affiliates to help provide our services, for governance and regulatory requirements or conduct data processing on our behalf. CL Intermediary Services service providers and business partners CL Intermediary Services may provide information to its vendors, consultants, marketing partners, research firms, and other service providers or business partners. This may include, for example:
• payment processors and facilitators;
• cloud storage providers;
• marketing partners and marketing platform providers;
• data analytics providers;
• research partners;
• vendors that assist CL Intermediary Services to enhance the safety and security of its business activities;
• consultants, lawyers, accountants and other professional service providers;
• successors of the business, where CL Intermediary Services or the services are sold to, acquired by, or merged with another organisation, in whole or in part. Where Personal Information is shared in these circumstances it will continue to be Processed in accordance with this Privacy Notice; and
• insurance and financing partners.

Other entities for legal reasons or in the event of a dispute
CL Intermediary Services may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

Cross-Border Data Transfers
Your data may be subject to cross-border data transfers. When making cross-border transfers of Personal Information, CL Intermediary Services will ensure that the third-party processor (operator) is subject to a law, binding corporate rules or binding agreement which provides an adequate level of protection for the lawful processing of your Personal Information and includes provisions, relating to the further transfer of Personal Information from the recipient to third parties who are in a foreign country. Where applicable, CL Intermediary Services will contractually commit to employ suitable technical and organisational measures to protect your Personal Information as required by the applicable law (hereinafter referred to as “Supplier Data Processing Agreements”), as well as other suitable safeguards recognised by Data Protection Laws.

Retention
CL Intermediary Services requires Plan Holders’ information in order to provide our products and services. We retain such information for as long as you maintain your CL Intermediary Services plan or have your Will and any codicils lodged with us. Once information is no longer necessary to provide CL Intermediary Services services, enable customer support, enhance the user experience or for other operational purposes, CL Intermediary Services takes steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection. CL Intermediary Services may also retain certain information, if necessary, for its legitimate business interests, such as fraud prevention and enhancing Plan Holders’ safety and security.

Security of your personal information
CL Intermediary Services is committed to protecting your Personal Information from misuse, loss, unauthorised access, modification or disclosure by using a combination of physical, administrative and technical safeguards and contractually requiring that third parties to whom we disclose your Personal Information do the same. Whilst CL Intermediary Services makes every effort to secure its websites, you should note that the internet is not completely secure; thus when you submit or post Personal Information online, you should be aware that CL Intermediary Services cannot guarantee the security of any Personal Information that you submit or post online.

Website
By using the CL Intermediary Services website, you accept that your Personal Information may be disclosed to CL Intermediary Services employees, suppliers and marketing agents where this information is necessary for them to offer, evaluate and enhance products and services offered on the CL Intermediary Services website. CL Intermediary Services uses cookies on its website which are required for certain features to work efficiently. We recommend that you allow cookies to enjoy the full functionality of our website, however, you can adjust the settings and options on your browser to disable or enable cookies or visit www.aboutcookies. org for detailed information about managing cookies on various browsers.

Direct marketing
As our client, we are allowed to send you marketing material about our own similar products and services. As a visitor to our website, we are also permitted to approach you for your consent to receive our marketing materials. In all instances, you may opt out of receiving further marketing materials from us at any time and manage your communication preferences by:
• following the unsubscribe instructions included in each marketing email or SMS text message from us; or
• sending an email to lifeinfo@capitallegacy.co.za including your details and a description of the marketing material you no longer wish to receive from us. We will comply with your request as soon as is reasonably practicable. If you opt out of receiving marketing-related communications from us, we may still send you administrative messages as part of your ongoing use of our website, solutions, products or services. We do not provide your Personal Information without your consent to unaffiliated third parties for direct marketing purposes or sell, rent, distribute, or otherwise make Personal Information commercially available to any third party.

Social media
We operate and communicate through our designated channels, pages and accounts on some social media sites to inform, help and engage with our users. We monitor and record comments and posts made about us on these channels so that we can improve our services. The general public can access and read any information posted on these sites. We are not responsible for any information posted on those sites other than the information posted by our designated officials. We do not endorse the social media sites themselves, or any information posted on them by third parties or other users. When you engage with us through social media, your Personal Information may be processed by the site owner; this processing occurs outside of our control and may take place in a country outside South Africa that may have different privacy regulations. We regularly update and monitor our social media accounts and welcome feedback and ideas sent to us through these channels. We try to join conversations whenever possible but cannot guarantee that we will read or reply to all messages sent to official CL Intermediary Services social media accounts. Consistent feedback and helpful suggestions will be given to the relevant people within the
company for consideration, but we cannot guarantee that any feedback or suggestions will be acted upon by CL Intermediary Services.

Changes to our Privacy Notice
We may change this Privacy Notice at any time. The most updated version will be always be available on www.clventures.co.za Your Rights Upon your request, we will provide you with access to any Personal Information on you that we may hold. You may also request us to correct your Personal Information, at any time. You can contact us on popi@clventures.co.za to request access to your Personal Information or the correction of your Personal Information. You can also seek to be removed from any of CL Intermediary Services’ subscriptions lists at any time by contacting us on popi@clventures.co.za. Please note that the above rights are not absolute, and CL Intermediary Services may be entitled to refuse requests where exceptions apply. If you have any compliant about the way in which CL Intermediary Services handles your Personal Information, you may lodge a complaint with CL Intermediary Services by emailing popi@clventures.co.za. Our Information Officer will then look into your complaint and work with you to resolve the matter. If you still feel that your Personal Information has not been handled appropriately according to the law, you can contact South African Information Regulator (inforeg@justice.gov.za) and file a complaint with them.

We are committed to protecting your Personal Information.
CL Intermediary Services cares about the privacy, security, and online safety of our Client’s Personal Information. We take our responsibility to protect your Personal Information very seriously. We take every reasonable precaution to protect your Personal Information (including information about your activities from theft, unauthorised access and disruption of services.

CL Intermediary Services will use your information for several various purposes, for example to provide our services to you and others and to meet our legal and regulatory obligations.

For more information on how we collect, use, share and protect your Personal Information as required by the Protection of Personal Information Act (POPIA), please view our Privacy Notices and Policies below.

1. Definitions
In this user agreement, the terms below have the following meanings:
1.1 CL Intermediary Services” means all members of CL Intermediary Services (Pty) Ltd and the Capital Legacy group;
1.2 “Personal Information” means personal information as referred to in the Protection of Personal Information Act, 2013.
1.3 “Processing” means the automated or manual activity of collecting, recording, organising, storing, updating, distributing and removing or deleting of Personal Information;
1.4 “Terms of Use” means these terms of Use, as same may be amended by CL Intermediary Services from time to time by publication on this Website;
1.5 “we”, “us”, “our” refers to the owner of the Site, being CL Intermediary Services, whose head offices are at 1st Floor Roland Garros Building, the Campus, 57 Sloane Street, Bryanston, 2191;
1.6 “Website” means this website at www.clventures.co.za; and
1.7 “you” and “your” means the user of the Site.

2. Conditions of Access
2.1 Your access to, and use of this Website is subject to these Terms of Use.
2.2 By using this Website, you agree that these Terms of Use apply to your use of the Website. It is recommended that you regularly check this Website for any changes to these Terms of Use, as the Terms of Use displayed at the time that you make use of the Website will be applicable to your use at that time.
2.3 You may not:
2.3.1 use the Website in a manner that could damage, disable, overburden, or impair any CL Venture server (computer), or network connected to any CL Intermediary Services erver, or interfere with any other party’s use of this Website;
2.3.2 interfere with any content displayed on this Website or attempt or gain unauthorised access to the information displayed on this Website or to any secure area on the Website, a CL Intermediary Services server or any other part of CL Intermediary Services’ information system. Any attempt, whether successful or unsuccessful, to do any of the aforgoing is unlawful and is an offence in terms of the provisions of section 86 of the Electronic Communications and Transactions Act No. 25 of 2002, for which you may be prosecuted and, if found guilty, punished.
2.3.3 create a link from another website to this Website without CL Intermediary Services’ prior written consent;
2.3.4 frame this Website or any of its pages without CL Intermediary Services’ prior written consent.

3. Copyright And Trademarks
3.1 Your access to this Website and the information contained on it, does not in any way grant or convey to you any rights in or to any material displayed or accessible from the Website (including all text, layout, graphics, artworks, animation material and general representation of the Website) or in any of the trademarks, copyright, designs, patents, domain names, know-how or any other intellectual property rights which may vest in CL Intermediary Services or in the author, compiler, creator or licensor of such information.
3.2 All CL Intermediary Services’ trademarks, logos, brands, domain names and other marks and intellectual property relating to this Website, or any information contained or accessible from this Website shall remain the sole and exclusive property of CL Intermediary Services and the relevant authors or licensors, and the you undertake that you will not use, duplicate, distribute, disseminate, adapt, display, alter or otherwise deal with such intellectual property without CL Intermediary Services’ prior written approval.
3.3 You may only use information retrieved, viewed, downloaded or otherwise obtained by viewing this Website for your own personal and non- commercial use and such information and/or data may not be sold, resold, transmitted or otherwise made available or disseminated in any manner via any media to any third parties unless the prior written consent of CL Intermediary Services has been obtained.
3.4 You undertake not to change or delete any proprietary notices contained in any material, data or information downloaded or otherwise retrieved from this Website.
3.5 Under no circumstances may you use, duplicate, distribute, reverse, engineer, disassemble, decompile, reproduce, transcribe, store in a retrieval system, translate into any language or computer language, retransmit in any form or by any means, (electrical, mechanical, photo reproduction, recording on or otherwise) any of the material, information or content viewed, downloaded or otherwise retrieved from this Website without the prior written consent of CL Intermediary Services.

4. Links to third party sites
Third party websites which links may be provided (“Linked Sites”) are not subject to the control of CL Intermediary Services and CL Intermediary Services is not responsible for the contents of any Linked Site or any further link contained in a Linked Site. CL Intermediary Services provides links to you only as a convenience and the inclusion of any link does not imply that CL Intermediary Services endorses, authorises, or sponsors that Linked Site, or that CL Intermediary Services is affiliated to such website’s owners or sponsors.

5. Electronic transactions, communications, and records
5.1 When you communicate with CL Intermediary Services via forms and chatbots on this Website, you consent to receiving responses to your communications by electronic communication addressed to you by CL Intermediary Services. You thereby agree that all electronic agreements, notices, disclosures, and other communications sent by CL Intermediary Services satisfy any legal requirement that such communications should be in writing.
5.2 You accept the risks inherent in electronic communication in whatever form.
5.3 You consent to CL Intermediary Services acting on the information communicated to CL Intermediary Services electronically. You are responsible for ensuring that CL Intermediary Services has received the information communicated electronically.

6. Disclaimer
This Website and the information contained therein is provided “as is” and CL Intermediary Services makes no express or implied representations or warranties with regard thereto. Without limiting the generality of the aforegoing:-
6.1 CL Intermediary Services does not warrant that the Website or information provided will be error-free or will meet any particular criteria of performance or quality. CL Intermediary Services expressly disclaims all implied warranties, including, without limitation, warranties of merchantability, title, fitness for a particular purpose, non-infringement, compatibility, security and/or accuracy;
6.2 the content or information displayed on this Website or any Linked Site is not intended as advice but merely as information. Before making any decision or taking any action based on any information displayed on the Website or any Linked Site that may affect your personal finances or business, it is recommended that you first obtain appropriate professional advice; and
6.3 whilst CL Intermediary Services has taken reasonable measures to ensure the integrity of this Website and its contents, no warranty, whether express or implied is given that any files, downloads or applications available via this Website are free of viruses, trojans, bombs, time-locks or any other data or code which has the ability to corrupt or affect the operation of your computer devices.

7. Limitation of liability
7.1 CL Intermediary Services will not be responsible to you or any third party for any loss incurred or damages suffered (whether direct, indirect, special, or consequential) arising, directly or indirectly, from the use of, or reliance upon, any content displayed on this Website.
7.2 CL Intermediary Services will not be responsible for any interruption, delayed or failed transmission, loss of programs or other data, or the storage or delivery of information resulting from whatever cause and
7.3 You hereby indemnify and hold CL Intermediary Services harmless against all and any loss, liability, action, law suits, proceedings, costs, demands, and damages of all and every kind, (including but not limited to, direct, indirect, special or consequential damages), and whether in an action based on contract, negligence or any other action arising out of or in connection with the failure or delay in the performance of the services offered on this Website, or due to your use of this Website.
7.4 Online users must keep confidential their personal usernames and passwords, at all times. CL Intermediary Services shall be entitled to presume the authenticity and validity of any online communication or transaction and that the online customer is the originator of such online communication or transaction where the username and password of that online customer is used to gain access to, view and/or engage in any activity or transaction or service offered on this website.
7.5 The online users hereby indemnifies CL Intermediary Services, its employees, representatives and service providers and holds them harmless against any and all claims, losses and damages which CL Intermediary Services or any third party may incur as a result of reliance placed on any information, data and material furnished by a prospective policyholder or policyholder to CL Intermediary Services.

8. Personal information
CL Intermediary Services will be Processing your Personal Information according to the Protection of Personal Information Act, No. 13 of 2013 and additional data protection laws. To find out more about how we use your Personal Information you can access our Privacy Notice here.

9. Termination and variation
CL Intermediary Services reserves the right to alter, restrict and / or terminate the services on its Website, without notice or reason, or to revise these Terms of Use at any time. Such changes will be published on this Website and be deemed to have been accepted by You if the You continue to use the Website. The obligation is therefore on You to appraise yourself of the Terms of Use of this Website each time you make use thereof.

10. General
10.1 These Terms of Use will be governed by and construed in accordance with the laws of South Africa, and you agree to submit to the exclusive jurisdiction of the South African courts. CL Intermediary Services’ failure to exercise any particular right or provision of these Terms of Use shall not constitute a waiver of such right or provision.
10.2 By using the Website, you expressly agree to these Terms of Use. If you do not agree to the Terms of Use, you should immediately cease use of the Website.
10.3 If any of the above Terms of Use is not fully enforceable in law for any reason, the remainder of the terms shall nonetheless continue to apply.

1. Overview
This is the official Complaints Resolution Manual implemented for CL Intermediary Services (PTY) LTD.

2. Purpose
The Financial Advisory and Intermediary Services Act (FAIS Act) requires that a financial service provider (i.e. our company) must maintain an internal complaints resolution system and procedure in the event that a customer complains about a financial service rendered by the financial services provider. Treating Customers Fairly (TCF) Outcome 6 provides that “Customers do not face unreasonable post-sale barriers imposed by firms to change product, switch providers, submit a claim or make a complaint”. This document not only provides a complaints procedure in conformance with legislative expectations but it also explains the procedure should you wish to complain about any of the financial services rendered by our company, and sets out the process which our company will follow in order to resolve the complaint.

3. Objectives
•To deliver consistent, high-quality and accountable responses to complaints received, across CL Intermediary Services.
• To ensure that our complaints procedure is in line with the overall regulatory requirements and Treating Customer Fairly outcomes and industry ‘best practices’.

4. Services Covered
CL Intermediary Services provides automated services in Category 1 Long-Term Insurance. Therefore, the scope of the resolution process will pertain to such services rendered.

5. Definitions
“Client” of a financial services provider means any user, former user or beneficiary of one or more of the financial products or services provided by the financial services provider, and their successors in title. “Client query” means a request to the provider or the provider’s service supplier by or on behalf of a client, for information regarding the provider’s financial products, financial services or related processes, or to carry out a transaction or action in relation to any such product or service; “complainant” means a person who submits a complaint and includes a –
a) client;
b) person nominated as the person in respect of whom a product supplier should meet financial product benefits or that persons’ successor in title;
c) person whose life is insured under a financial product that is an insurance policy;
d) person that pays a premium in respect of a financial product;
e) member;
f) person whose dissatisfaction relates to the approach, solicitation marketing or advertising material or an advertisement in respect of a financial product, financial service or related service of the provider, who has a direct interest in the agreement, financial product or financial service to which the complaint relates, or a person acting on behalf of a person referred to in (a) to (f);
g) is a customer or prospective customer of the financial services provider concerned and has
h) a direct interest in the agreement, product or service to which the complaint relates; or
i) has submitted the complaint on behalf of a person mentioned in (a), provided that a prospective customer will only be regarded as a complainant to the extent that the complaint relates to the prospective customer’s dissatisfaction in relation to the application, approach, solicitation or advertising or marketing material contemplated in the definition of “prospective customer”. “complaint” means an expression of dissatisfaction by a person to a provider or, to the knowledge of the provider, to the provider’s service supplier relating to a financial product or financial service provided or offered by that provider which indicates or alleges, regardless of whether such an expression of dissatisfaction is submitted together with or in relation to a client query, that -
a) the provider or Its service supplier has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on the provider or to which it subscribes;
b) the provider or its service supplier’s maladministration or wilful or negligent action or failure to act, has caused the person harm, prejudice, distress or substantial inconvenience; or
c) the provider or its service supplier’s has treated the person unfairly; “compensation payment” means a payment, whether in monetary form or in the form of a benefit or service, by or on behalf of a provider to a complainant to compensate the complainant for a proven or estimated financial loss incurred as a result of the provider’s contravention, non
-compliance, action, failure to act, or unfair treatment forming the basis of the complaint, where the provider accepts liability for having caused the loss concerned, but excludes any -
a) goodwill payment;
b) payment contractually due to the complainant in terms of the financial product or financial service concerned; or
c) refund of an amount paid by or on behalf of the complainant to the provider where such payment was not contractually due;
and includes any interest on late payment of any amount referred to in (b) or (c); “FAIS” means the Financial Advisory and Intermediary Services Act No. 37 of 2002 which was designed to protect customers of financial services providers; regulate the selling and advice-giving activities of the FSP (FSPs); ensure that the consumers are provided with adequate information about the financial product they use and about the people and institutions who sell these financial products and establish a properly regulated financial services profession. “FAIS Ombud” the FAIS Ombud deals with complaints submitted to the Office by a specific customer against a financial services provider. “Financial Services Provider” means CL Intermediary Services (PTY) LTD with FSP Number 51405 and place of business as 1st Floor, Roland Garros, The Campus, 57 Sloane Street, Bryanston, 2129. “Goodwill payment” means a payment, whether in monetary form or in the form of a benefit or service, by or on behalf of a provider to a complainant as an expression of goodwill aimed at resolving a complaint, where the provider does not accept liability for any financial loss to the complainant as a result of the matter complained about; “member” in relation to a complainant means a member of a -
a) pension fund as defined in section 1(1) of the Pension Funds Act, 1956 (Act 52 of 1956);
b) friendly society as defined in section 1(1) of the Friendly Societies Act, 1956 (Act 25 of 1956);
c) medical scheme as defined in section 1(1) of the Medical Schemes Act, 1998 (Act 131 of 1998); or
d) group scheme as contemplated in the Policyholder Protection Rules made under section 62 of the Long-term Insurance Act, 1998, and section 55 of the Short-term Insurance Act, 1998; “Prospective customer” of a financial services provider means a person who has applied to or otherwise approached the financial services provider in relation to becoming a customer of the financial services provider, or a person who has been solicited by the financial services provider to become a customer or has received marketing or advertising material in relation to the financial institution’s products or services. “rejected” in relation to a complaint means that a complaint has not been upheld and the provider regards the complaint as finalised after advising the complainant that it does not intend to take any further action to resolve the complaint and includes complaints regarded by the provider as unjustified or invalid, or where the complainant does not accept or respond to the providers proposals to resolve the complaint; “reportable complaint” means any complaint other than a complaint that has been -
a) upheld immediately by the person who initially received the complaint;
b) upheld within the provider’s ordinary processes for handling client queries in relation to the type of financial product or financial service complained about, provided that such process does not take more than five business days from the date the complaint is received; or
c) submitted to or brought to the attention of the provider in such a manner that the provider does not have a reasonable opportunity to record such details of the complaint as may be prescribed in relation to reportable complaints; and “Resolved” in relation to a complaint means that the complaint has been finalised in such a manner that the complainant has explicitly accepted that the matter is fully resolved or that it is reasonable for the financial services provider to assume that the complainant has so accepted. A complaint should only be regarded as resolved once any and all undertakings made by the financial services provider to resolve the complaint have been met. “Routine Complaints” is where a customer submits an expression of dissatisfaction together with a customer query or relating to a customer query and which further can be resolved internally within a period of fifteen (15) days. Routine complaints are therefore customer queries which have been previously escalated by the customer but now the customer has become dissatisfied with the process being followed to resolve the customer query. “Serious Complaints” are complaints that contravene regulatory requirements and are likely or may already have caused a customer to suffer financial prejudice. “Service provider” means another person with whom the financial services provider to whose products or services the complaint relates has
an arrangement in relation to the marketing, distribution, administration or provision of such products or services, regardless of whether or not such other person is the agent of the financial services provider. “TCF” Treating Customers Fairly is an outcome-based regulatory and supervisory approach designed to ensure that specific, clearly articulated outcomes for fairness regarding financial services to customers are delivered on by regulated FSPs. Financial Service Providers are expected to demonstrate that they deliver the required six (6) TCF Outcomes to their customers throughout the product lifecycle, from product design and promotion, through advice and servicing, to complaints and claims handling – and throughout the product value chain.

6. Components
The components of the CL Intermediary Services Complaints Management Framework are:
● The Complaints Management Policy
● Complaints Management Framework Register
The Complaints Management Policy provides for the business, staff, and clients with a clear and considered process to manage and resolve client complaints. It explains the steps customers could take when making complaints. It identifies the steps in discussing, considering, addressing, and resolving complaints and indicates some of the solutions offered to resolve complaints. The Complaints Management Framework Register serves as a formal document in which complaints are recorded in terms of client details, the complaint received, the TCF category the complaint belongs to, the dates that the complaint was dealt with and resolved etc. This allows complaints to be resolved effectively and with due process followed.

Receive complaint
(in writing)

Add the complaint to the Complaints register or dashboard
Allocate responsible person to handle the complaint
Classify and categorise the complaint (link to TCF outcome)
Acknowledge the complaint
Investigate and analyse the complaint
Resolve and confirm
Discuss in management meetings
Implement solutions and improve systems
Communicate solution to clients (send letter and update Complaints dashboard)
If client is satisfied close file on Complaints dashboard
If client is not satisfied, inform client of rights (update the Complaints dashboard)
Update the Complaints management framework register/dashboard Confirm escalation process in writing to the client (Update the Complaints dashboard)
Monitor changes and adapt if required

7. Review
The CL Intermediary Services undertakes to review its Complaints Management Framework and document the changes thereto on an
annual basis, alternatively whenever there are changes in the business that impact the Complaints Management Framework. A Review Register is set out in Annexure A. The Key Individual, is responsible for reviewing and updating the Complaints Management Framework.

8. Process Overview
The following key steps must be followed for all customer complaints received by the staff of CL Intermediary Services. The requirements for each step are detailed below.

1. Lodge/Receive a Complaint
The client is to submit the complaint to the FSP in writing to the contact details that appear herein. The complaint can be submitted by:
• Hand
• Post
• Fax
• Email
(If a complaint is submitted telephonically, CL Intermediary Services will send the client an email to request the relevant details regarding the complaint. The client needs to respond and provide the requested information in writing (e.g. hand, post, fax or email).
• The client must submit sufficient detail of the complaint, this includes their:
- Name and surname
- Policy number
- ID number
- Postal address
- Financial Advisor
- Product Supplier
- Product Type: Risk, Investment, Short term, Endowment, Employee Benefits, Disability, Medical Aid, Unit Trust, Wills etc.
- Complaint Category: Product features and charges; Information Disclosures; Product performance; Client Services; Access; Changes or Switches; Complaints Handling; Claims; or Other complaints.
- Brief detail of the complaint

2. Acknowledge CL Intermediary Services will:
• Acknowledge all complaints within 24 hours of receipt.
• Where an acknowledgement is made telephonically it will be followed up with a written response whether by SMS or email.
• Clearly and transparently communicate the availability and contact details of the relevant Ombud services to complainants (clients) at all relevant stages of the relationship with a client, including at the start of the relationship and in relevant periodic communications.
• Ensure all communication with a complainant is in plain language.
• Provide, wherever feasible, clients with a single point of contact for submitting complaints.
• Promptly inform a complainant of the process to be followed in handling the complaint, including-
- Contact details of the person or department that will be handling the complaint;
- indicative and, where applicable, prescribed timelines for addressing the complaint;
- details of the internal complaints escalation and review process if the complainant is not satisfied with the outcome of a complaint;
- details of escalation of complaints to the office of a relevant Ombud and any applicable timeline; and
- details of the duties of the provider and rights of the complainant as set out in the rules applicable to the relevant Ombud
• Despatch a complaint reference number to the complainant on the acknowledgment of the complaint.
• Disclose to the client:
- the type of information required from a complainant, if this has not been provided already;
- where, how, and to whom a complaint and related information must be submitted, if this has not been provided already;
- expected turnaround times concerning complaints; and
- any other relevant responsibilities of a complainant.
• Despatch the details of the person allocated to the complaint to the complainant within 48 hours from receipt.

3. Allocate a Responsible person
CL Intermediary Services will ensure that:
• The complaint is allocated and dealt with by a trained staff member.
• The person responsible for the clients’ complaint will furnish the client with his/her contact details and the reference number of the complaint (if applicable)
• The Key Individual has oversight over the complaints allocated to various personnel such as the Complaints Manager.

4. Classify CL Intermediary Services will:
• Ensure that all potential issues are captured and classified for escalation, review, and action, as required;
• Reduce any complaint, issue or negative client interaction to writing then log and classify for action in the Complaint Management Framework Register;
• Where a third party is acting on behalf of a complainant, CL Intermediary Services will ensure that such third party
delivers a certified or original consent or power of attorney to act on behalf of a complainant:
- no further dealings will be pursued with such a third party until the proper authority is obtained, however
- the complaint will be taken up directly with the complainant on whose behalf the complaint is made
• Formally log all complaints using a relevant process / Complaints Management Framework Register.

RISK
All complaints will be prioritised as follows:
Risk 1 - These are routine complaints with potentially low business impact.
• Routine complaints:
• require a response to the client within 15 working days;
• have the potential of becoming serious or official complaints if disregarded or ignored by the FSP;
• require staff to review the complaint and its priority with the Complaints Manager before proceeding to the next step;
• requires the Complaints Manager to decide on the appropriate person(s) to carry out subsequent steps, including the investigation.
Risk 2 - These complaints are urgent and can have a serious business impact.
Serious complaints:
• require a response to the client within 5 - 10 working days;
• are logged on media platforms, received from Legal Advisors or immediately evidence contravention of legislation requirements such as failure to conduct a proper needs analysis;
• can cause reputational harm to a business and/or may cause financial loss to a client;
• need to be handled by the Complaints Manager/Key Individual or a suitable senior person delegated to the task by the Complaints Manager or Key Individual;
• Complaints received from third parties and/or Legal Advisors will be responded to within 24 hours:
- acknowledge receipt of the complaint;
- further requesting authority to act on the complainant’s behalf such as a power of attorney or consent by the complainant to deal with the complaint on the complainant’s behalf. No information will be divulged to a third party who does not have the proper authority to act on a complainant’s behalf.
Risk 3 - These are urgent official complaints received from Authorities e.g. FAIS Ombud. The regulator usually stipulates a
response time of 30 days from receipt of the complaint. Urgent official complaints:
• are handled by the Complaints Manager/Key Individual.
• Alternatively, the investigation of the complaint may be delegated to a suitable senior person selected by the Complaints Manager/Key Individual.
• The required draft response and attachments will be collated by such senior person as decided upon by the Complaints Manager/Key Individual.
• The Complaints Manager is responsible for compiling the response to the Authority.
• The response to the Authority will be made within the stipulated turnaround time stated on the official correspondence.

5. Categorisation The FSP will categorise reportable complaints as per the following minimum categories:
• The design of a financial product, financial service, or related service, including the fees, premiums, or other charges related to that financial product or financial service;
• Information provided to clients;
• Financial product or financial service performance;
• Service to clients, including those relating to premium collection or lapsing of a financial product;
• financial product accessibility, changes or switches;
• Complaints handling;
• Insurance risk claims which include non-payment of claims; and
• Other complaints which can be additional categories relevant to the FSPs chosen business model, financial products, financial services, and client base that will support the effectiveness of its Complaints Management Framework in managing conduct risks and effecting improved outcomes and processes for its clients.
Group the Complaints
The FSP will thereafter:
• Categorise, record, and report on reportable complaints by identifying the category to which a complaint closely relates and group complaints accordingly.
• Narrow down the categories to the impact on clients
• Measure the impact of the complaint by further categorising it according to the following TCF Outcomes
TCF Outcome 1
Includes complaints:
• other complaints relating to management issues
TCF Outcome 2
Includes complaints:
• relating to the design of a product/service
• relating to product features and charges that affect this TCF outcome
TCF Outcome 3
Includes complaints:
• relating to unsuitable or inaccurate, misleading, confusing, or unclear information provided to a client throughout the life cycle of a product
• This could vary from product information, information provided in advertising or marketing material about a product or service rendered etc.
• CL Intermediary Services is to include the Conflict of Interest disclosures required by the FAIS General Code of Conduct (Code); Section 4 and 5 of the Code or any other disclosure requirements in terms of the Code or any other legislation in these disclosures
TCF Outcome 5
Includes complaints:
• about product performance and service-related issues
• relating to a client’s disappointment with limitations in a product/service performance of which they were unaware
• relating to the inability of a product to meet a client’s expectations
• related to a Product Supplier’s exercise of a right to terminate a product or amend its terms
TCF Outcome 6
Includes complaints:
• relating to product accessibility or changes.
• relating to handling and complaints relating to claims

6. Investigate CL Intermediary Services will:
• Analyse the root cause of the complaint to enable the complaint to be appropriately dealt with and avoid, if possible, its re-occurrence
• Identify and clarify internal and external key facts.
• Should a complaint relate to product features or services handled solely by a product supplier, this matter will be
escalated and appropriately dealt with in conjunction with the product supplier, ensuring that the matter is resolved to
the satisfaction of the complainant.
• Whenever a complaint is escalated or reviewed ensure that:
- A balanced approach is followed, bearing in mind the legitimate interests of all parties involved including the fair treatment of clients
- Internal escalation of complex or unusual complaints at the instance of the initial complaint handler is provided for;
- Clients may escalate complaints not resolved to their satisfaction
- the escalation is allocated to an impartial, senior functionary within the provider or appointed by the provider for managing the escalation or review process of the provider.
• Ensure that procedures within the complaints escalation and review process are not overly complicated or impose unduly burdensome paperwork or other administrative requirements on complainants (clients).
• Document all areas of interaction and communication.
• Ensure accurate, efficient, and secure recording of complaints and complaints-related information.
• In respect of each reportable complaint, keep a record of:
- All relevant details of the complainant and the subject matter of the complaint;
- Copies of all relevant evidence, correspondence, and decisions;
- The complaint categorization;
- The progress and status of the complaint, including whether such progress is within or outside any set timelines;
• Concerning reportable complaints categorised on an ongoing basis record the number of complaints:
- Received,
- Upheld,
- Rejected and their reasoning,
- Escalated by complainants (clients) to the internal complaints escalation process,
- Referred to an Ombud and their outcomes;
- and amounts of Compensation payments made,
- and amounts of goodwill payments made,
- the total number of complaints outstanding.
• Ensure complaints information recorded is scrutinised and analysed on an ongoing basis and utilised to manage conduct risks and effect improved outcomes and processes for clients, and to prevent recurrences of poor outcomes and errors.
• Obtain consent from the complainant to ensure that no personal information is divulged or processed without the complainant’s knowledge or consent.
• Keep the complainant appropriately updated on the progress of the investigation.

7. Resolve and Confirm CL Intermediary Services will:
• Ensure that the proposed resolution meets the Treating Customers Fairly Outcomes, does not prejudice CL Intermediary Services or complainant, and does not involve any unnecessary legal or financial implications.
• Document and assess the proposed action agreed upon with the Complaints Manager and/or Key Individual and Representative.
• Discuss and review the signed off resolution with the complainant to ensure fairness and clarity and to further ensure that the resolution deals with the root cause of the complaint.
• Include recognition and documentation of any underlying issues that have contributed to the complaint and recommendations for actions to prevent the further occurrence in the review.

8. Respond to Client CL Intermediary Services will:
• Ensure the complaint process is accessible through channels that are appropriate to CL Intermediary Services’ clients.
• Ensure there are no charges for making use of the complaint process.
• Ensure communication is in plain language.
• Clearly explain the details of the findings and proposed resolution to the client - within the agreed timeframes.
• Where a complaint is upheld, if there has been any commitment by CL Intermediary Services to make a compensation
payment, goodwill payment, or to take any other action ensure it is carried out without undue delay and within the agreed timeframes.
• Where a complaint is rejected, the complainant must be provided with clear and adequate reasons for the decision and must be informed of any applicable escalation or review processes, including how to use them and any relevant time limits.
• Send a written acknowledgment of the complaint to the complainant, with contact details of the FAIS Ombud, if the complaint cannot be addressed within three weeks and a single point of contact for submitting complaints.
• If within six weeks of receipt of a complaint CL Intermediary Services has been unable to resolve the complaint to the satisfaction of a complainant, the complainant may:
• refer the complaint to the Office of the FAIS Ombud if he/she wishes to pursue the matter; and
• the complainant must do so within six months of receipt of such notification.
• Appropriate processes for engagement with the Ombud.

9. Follow up and review CL Intermediary Services will:
• Diarise complaints to ensure it remains within the appropriate turnaround times.
• Keep complainant appropriately informed of the progress of their complaint.
• Keep complainant appropriately informed of causes of any delay in the finalisation of a complaint and revised timelines, should a complaint exceed the turnaround time due to unforeseen and reasonable circumstances.
• Keep complainant appropriately informed throughout the complaints process of the resolution being sought.
• Conduct a follow-up on the resolution of the complaint, to ascertain whether the client was satisfied with the complaints-handling process and the resolution sought and whether the resolution was proper and fair.
• Any negative responses will be actioned in the quarterly review of complaints.

10. Quality Assurance and Close
CL Intermediary Services will:
• Ensure that the Complaints Manager ensures that all employees of the business have access to the Complaints Management Policy.
• Ensure the Key Individual approves and oversees the effectiveness of the implementation of the Complaints Management Framework.
• Ensure the responsible person, making a decision or recommendation is adequately trained, has an appropriate mix of experience, knowledge, and skills in complaints handling, fair treatment of customers, subject matter concerned, relevant legal and regulatory matters also not subject to conflict of interest and be adequately empowered to make impartial decisions or recommendations.
• Ensure clients will be made aware of the Complaints Management Policy and will have access to the manual upon
request.
• All complaints will be reviewed quaterly and will be used as TCF Management Information to improve overall TCF outcomes.
• Action all complaints to prevent re-occurrence of poor outcomes and errors, where feasible.
• Ensure complaints are scrutinised and analysed on an ongoing basis.
• Ensure complaints are utilised to manage conduct risks.
• Ensure complaints effect improved outcomes and processes for its clients.
• Update the Complaints Management Framework Register.
• Ensure compliance with any prescribed requirements for reporting complaints information to any relevant designated authority or the public as may be required by the Registrar.
• Close the matter.

9. Suppliers
CL Intermediary Services will follow the same process as set out above.

10. Decisions Relating to Complaints
CL Intermediary Services Institute undertakes to ensure that:
• where a complaint is upheld, any commitment by CL Intermediary Services to make a compensation payment, goodwill payment or to take any other action will be carried out without undue delay and within any agreed timeframes.
• where a complaint is rejected, CL Intermediary Services will provide the complainant with clear and adequate reasons for the decision and inform the complainant of any applicable escalation or review processes, including how to use them and any relevant time limits.

11. Complaints Escalation and Review Process
11.1. The FSP will use the following process for the escalation and review of complaints:
• Should a complaint relate to product features or services handled solely by a product supplier, this matter will be escalated and appropriately dealt with in conjunction with the product supplier, ensuring that the matter is resolved to the satisfaction of the complainant.
• Whenever a complaint is escalated ensure that:
- A balanced approach is followed, bearing in mind the legitimate interests of all parties involved including the fair treatment of clients
- Internal escalation of complex or unusual complaints at the instance of the initial complaint handler is provided for;
- Clients may escalate complaints not resolved to their satisfaction
- the escalation is allocated to an impartial, senior functionary within the provider or appointed by the provider for managing the escalation or review process of the provider.
•Ensure that procedures within the complaints escalation and review process are not overly complicated or impose unduly burdensome paperwork or other administrative requirements on complainants (clients).
•Document all areas of interaction and communication.
•Ensure accurate, efficient, and secure recording of complaints and complaints-related information.
•In respect of each reportable complaint, keep a record of:
- All relevant details of the complainant and the subject matter of the complaint;
- Copies of all relevant evidence, correspondence, and decisions;
- The complaint categorization;
- The progress and status of the complaint, including whether such progress is within or outside any set timelines;
•Concerning reportable complaints categorised on an ongoing basis record the number of complaints:
- Received,
- Upheld,
- Rejected and their reasoning,
- Escalated by complainants (clients) to the internal complaints escalation process,
- Referred to an Ombud and their outcomes;
- and amounts of Compensation payments made,
- and amounts of goodwill payments made,
- the total number of complaints outstanding.
•Ensure complaints information recorded is scrutinised and analysed on an ongoing basis and utilised to manage conduct risks and effect improved outcomes and processes for clients, and to prevent recurrences of poor outcomes and errors.
• Obtain consent from the complainant to ensure that no personal information is divulged or processed without the complainant’s knowledge
or consent. Keep the complainant appropriately updated on the progress of the investigation.
11.2. The Complaints Manager is responsible for managing the escalation and review process of complaints.
11.3. Complaints may be escalated and/or reviewed in the following instances:
• Where the complaint is of a complex or unusual nature. In such an instance the initial complaint handler may escalate the complaint.
• Complainants may escalate complaints that were not resolved to their satisfaction (Complainants must be notified of this).

12. Record keeping, monitoring and analysis
12.1. CL Intermediary Services will follow the process below for: record keeping, monitoring and analysing of complaints.
CL Intermediary Services must ensure accurate, efficient and secure recording of complaints and complaints related information. The Complaints Management Framework Register is to be used to record complaints and related information. The following must be recorded in respect of each reportable complaint:
• all relevant details of the complainant and the subject matter of the complaint,
• copies of all relevant evidence, correspondence, and decisions,
• the complaint categorisation,
• progress and status of the complaint, including whether such progress Is within or outside any set timelines.
CL Intermediary Services must maintain the following data, on categorised reportable complaints, on an ongoing basis:
• number of complaints received,
• number of complaints upheld,
• number of rejected complaints and reasons for the rejection,
• number of complaints outstanding.
Complaints Information that has been recorded, must be scrutinised and analysed by the Compliance Department on an ongoing basis. CL Intermediary Services must use this information to manage conduct risks and implement improved outcomes and processes for its clients, and to prevent recurrences of poor outcomes and errors.
12.2. The monitoring and analysis of complaints will be reported by the Compliance Department to the FSP’s Key Individual on a monthly basis. The report will include:
• Information on the categorisation of complaints.
• What risks have been identified since the last report.
• What trends have been identified.
• What actions could be taken to manage risks and implement improved outcomes.
12.3. The FSP will keep records of these reports, monitor changes and consider whether the Complaints Management Framework may need to be adapted in response to the findings.
12.4. Responsible person/s
The Complaints Manager will be responsible for the recordkeeping requirements. The Key Individual and Compliance Department will be responsible for the monitoring requirements. The Complaints Department and the Compliance Department will be responsible for the analysis requirements.

13. Communication with Complaints
CL Intermediary Services will ensure that:
• Its complaint processes and procedures are transparent, visible and accessible through channels that are appropriate to the provider's clients.
• It does not impose any charge for a complainant to make use of complaint processes and procedures.
• All communications with a complainant will be in plain language.
• Wherever feasible, it will provide clients with a single point of contact for submitting complaints.
• The following information is disclosed to a client:
- the type of Information required from a complainant.
- where, how and to whom a complaint and related information must be submitted.
- expected turnaround times in relation to complaints.
- any other relevant responsibilities of a complainant.
• Within a reasonable time after receipt of a complaint, it will acknowledge receipt thereof and promptly inform a complainant of the process to be
followed in handling the complaint including:
- contact details of the person or department that will be handling the complaint.
- indicative and, where applicable, prescribed timelines for addressing the complaint.
- details of the internal complaints escalation and review process if the complainant is not satisfied with the outcome of a complaint.
- details of escalation of complaints to the office of a relevant ombud and any applicable timeline.
- details of the duties of the provider and rights of the complainant as set out in the rules applicable to the relevant ombud.
● Complainants will be kept adequately informed of:
- the progress of their complaint
- causes of any delay in the finalisation of a complaint and revised timelines, and
- the FSP's decision in response to the complaint.

14. Engagement with Ombud and reporting
CL Intermediary Services must:
• Should there be a complaint raised by the Ombud, it is of utmost importance that the matter is raised and communicated to the Key Individual of CL Intermediary Services.
• The Key individual, or a designated department will request relevant information pertaining to the complaint raised by the Ombud from the Complaints Manager in order to obtain records, root cause, complaint management framework register, exchange of previous communications regarding the complaint if possible and any other relevant information that could be obtained.
• Once the investigation has completed within the time frame specified by the Ombud, the Key Individual will provide feedback to the Ombud with all evidence that may be helpful to resolve the complaint.
• At all times, the Ombud contact details will be communicated to clients clearly and transparently at all relevant staged of the relationship with a client.
• Display and/or make available information regarding the availability and contact details of the relevant Ombud services, at the premises and/or on the company website.
• Maintain specific records and carry out specific analysis of complaints referred to CL Intermediary Services by the Ombud and the outcomes of
such complaints.
• Monitor determinations, publications, and guidance issued by any relevant Ombud to identify failings or risks in their policies, services, or practices.
• Maintain open and honest communication and co-operation between itself and any Ombud with whom it deals; and
• Endeavour to resolve a complaint before a final determination or ruling is made by an Ombud, or through the business’ internal escalation process, without impeding or unduly delaying a complainant’s access to an Ombud.

15. Important Contact Details
CL Intermediary Services
Post: Private Bag X3, Bryanston, 2021
Email: info@clis.co.za
Telephone: 010 036 4033

Guardrisk Life Limited
Post: PO Box 786015, Sandton, 2146
Telephone: 011 669 1000
Email: complaints@guardrisk.co.za

The Ombudsman for Long-term Insurance
Post: Private Bag X45, Claremont, 7735
Telephone: 021 657 5000 / 086 010 3236
Fax: 021 674 0951
Email: info@ombud.co.za

The Financial Sector Conduct Authority (FSCA)
Post: PO Box 35655, Menlo Park, 0102
Telephone: 012 428 8000
Fax: 012 346 6941
Email: info@fsca.co.za

The FAIS Ombudsman
Post: PO Box 74571, Lynnwood Ridge, 0040
Telephone: 012 762 5000
Fax: 012 348 3447
Email: info@faisombud.co.za

1. Introduction
In terms of the Financial Advisory and Intermediary Services Act, 2002, CL Intermediary Services (Pty) Ltd is required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage Conflict of Interest (COI). Section 3A(2)(a) of the FAIS General Code of Conduct (GCOC) stipulates that every financial services provider, other than a representative, must adopt, maintain and implement a conflict-of-interest management policy that

complies with the provisions of the Act.

2. Purpose
The purpose of this policy is to comply with these obligations and provide for mechanisms in place to identify, mitigate and manage the conflicts of interest to which CL Intermediary Services is a party. In addition, to ensure alignment between the values of the organization and the conduct of its people by safeguarding clients’ interests and ensuring the fair treatment of clients. CL Intermediary Services is committed to ensuring that all business is conducted in accordance with good business practice. To this end, CL
Intermediary Services conducts business in an ethical and equitable manner and in a way that safeguards the interests of all stakeholders to minimise and manage all real and potential conflicts of interests. Like any financial services provider, CL Intermediary Services is potentially exposed to conflicts of interest in relation to various activities. However, the protection of our clients’ interests is our primary concern and so our policy sets out how:
• we will identify circumstances which may give rise to actual or potential conflicts of interest entailing a material risk of damage to our clients’ interests;
• we have established appropriate structures and systems to manage those conflicts; and
• we will maintain systems in an effort to prevent damage to our clients’ interests through identified conflict of interest. To achieve the objectives set out above, this policy sets out the rules, principles and standards of CL Intermediary Services’ COI management procedures, by documenting them in a clear and understandable format.

3. Scope of application
This policy is applicable to CL Intermediary Services, all providers of CL Intermediary Services, key individuals, representatives, associates and administrative personnel. CL Intermediary Services is committed to ensuring compliance with this policy and going forward, the processes will be monitored on an ongoing basis. Any non-compliance with the policy will be viewed in a severe light. Non-compliance will be subject to disciplinary procedures in terms of FAIS and employment conditions and can ultimately result in debarment or dismissal as applicable. Avoidance, limitation or circumvention of this policy via an associate will be deemed non-compliance. CL Intermediary Services is a private company consisting of several representatives closely monitored and managed. The products provided to clients are financial products within its mandated license categories from multiple Service Providers with whom CL Intermediary Services has contracts to market their products. The processes involved in effectively managing internal controls are further elaborated on in paragraph 5 of this Policy.

4. Understanding Conflict of Interest
4.1 When is it a Conflict of Interest?
A COI means any situation in which CL Intermediary Services or one of our representatives has an actual or potential interest that may, in rendering a financial service to our clients -
• influence the objective performance of obligations to that client; or
• prevents us from rendering an unbiased and fair financial service, or
• prevents us from acting in the interests of that client. An “actual or potential interest” includes but is no limited to:
• A financial interest, which includes any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, valuable consideration, other incentive or valuable consideration which exceeds R1 000 per calendar year. (1)

• An ownership interest which means any equity or proprietary interest and any dividend, profit share or similar benefit derived from hat equity or ownership interest.
• Any relationship with a third party, meaning any relationship with a product supplier, other FSP’s, an associate of a product supplier or an associate of CL Intermediary Services. A third party also includes any other person who, in terms of an agreement or arrangement, provides a financial interest to CL Intermediary Services representatives.
• An immaterial financial Interest, which is any financial interest with a determinable monetary value, the aggregate of which does not exceed R1 000 in any calendar year from the same third-party in that calendar year received by –

- a provider who is a sole proprietor; or

- a representative for that representative’s direct benefit;
- a provider, who for its benefit or that of some or all of its representatives, aggregates the immaterial financial interest paid to its
representatives;

4.2 What type of interest may we give and receive?

CL Intermediary Services and our representatives may only offer to and receive specific financial interests from a third party(2)
, which includes the following:
1. Commission as authorised under the Long-term Insurance Act (52 of 1998;
2. Fees as authorised under the Long-term Insurance Act (52 of 1998);
4.3 On what basis may we give and receive financial interests? The financial interest referred to in points 2, 3, and 4 above may only be offered or received by CL Intermediary Services or it’s representatives, if:
• The financial interests are proportionate (reasonably commensurate) to the service being rendered, considering the nature of the service, the resources, skills and competencies that are reasonably required to perform it.
• The payment of those financial interests does not result in CL Intermediary Services or the representative being remunerated more than once for performing the same service.
• Any actual or potential conflicts between the interests of clients and the interests of the person receiving those financial interests are effectively mitigated; and
• The payment of those financial interests does not impede the delivery of fair outcomes to clients.

5. Processes and internal controls to manage Conflict of Interest
5.1 Identification of Conflict of Interest
To adequately manage COI, CL Intermediary Services must identify all relevant conflicts timeously. In determining whether there is or may be a COI to which the policy applies, CL Intermediary Services considers whether there is a material risk of unfair treatment or bias for the client, taking into account whether CL Intermediary Services or its associate or employee:
• is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
• has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
• has a financial or other incentive to favour the interest of another client, group of clients or any other third party over the interests of the client;
• receives or will receive from a person other than the client, an inducement in relation to a service provided to the client in the form of monies, goods or services, other than the legislated commission or reasonable fee for that service.
Our policy defines possible conflicts of interest as, inter alia:
• conflicts of interest between CL Intermediary Services and the client;
• conflicts of interest between our clients if we are acting for different clients and the different interests conflict materially;
• conflicts of interest where associates, product suppliers, distribution channels or any other third party is involved in the rendering of a financial service to a client;
• storing confidential information on clients which, if we would disclose or use, would affect the advice or services provided to clients. We may only receive commissions authorised in terms of applicable legislation.

Footnotes:
1. Financial Interest excludes an ownership interest and Training, that is not exclusively available to a selected group of providers or representatives where that training is related to products and legal matters relating to (1) those products, (2) General financial and industry information, (3) Specialised technological systems of a third party necessary for the rendering of a financial service, but excluding travel and accommodation associated with that training and (4) qualifying enterprise development contribution to a qualifying beneficiary entity.
2. FAIS GCOC S3A. FAIS GCOC S1 “third party” means a product supplier, another provider, associate of a product supplier or a provider, a distribution channel and any person who in terms of an agreement or arrangement with a person referred to previously provides a financial interest to a provider or its representatives.
3. “Other fees” specifically agreed to by the client and which can be stopped by the client at their discretion but only if agreed in writing with the client, including details of the amount, frequency, payment method and recipient of those fees, as well as the details of services to be provided in exchange for the fees.
4. Fees or remuneration for services that were rendered to a third party.
5. An immaterial financial interest.
6. Any other financial interest not mentioned above for which a consideration, fair value or remuneration that is reasonably commensurate is paid by that provider or representative, at the time of receiving that financial interest.

All employees are responsible for identifying specific instances of conflict and are required to notify the Key Individual of any conflicts they become aware of. The Key Individual will assess the implications of the conflict and how the conflict should be managed, acting impartially to avoid a material risk of harming clients’ interests.

5.2 Measures for avoidance and mitigation of Conflict of Interest

To ensure that CL Intermediary Services can identify, avoid and mitigate COI situations, we create awareness and knowledge of applicable stipulations, through training and educational material. Where a COI situation cannot be avoided, these instances are recorded on CL Intermediary Services’ conflict of interest register. We ensure the understanding and adoption of CL Intermediary Services’ conflict of interest policy and management measures by allemployees, and associates through training on the COI policy. The Key Individual will assess each conflict, including whether the conflict is actual or perceived, what the value of the conflict or exposure is and the potential reputational risk. Compliance and management then agree on the controls that need to be put in place to manage theconflict. Once a conflict of interest has been identified it needs to be appropriately and adequately managed and disclosed, in line with the below steps.

5.3 Measures for Mandatory Disclosure of Conflict of Interest
Where there is no other way of managing a conflict, or where the measures in place do not sufficiently protect clients’ interests, the conflict must be disclosed to allow clients to make an informed decision on whether to continue using our service in the situation concerned. In all cases, where appropriate and where determinable, the monetary value of non-cash inducements will be disclosed to clients. The Key Individual will ensure transparency and manage conflict of interests. The client must be informed on the Conflict-of-Interest Policy and where they may access the policy.

5.4 Ongoing monitoring of Conflict-of-Interest management
The key individual or staff member in charge of supervision and monitoring of this policy will regularly monitor and assess all related matters. CL Intermediary Services will conduct ad hoc checks on business transactions to ensure the policy has been complied with. The Compliance Officer will include monitoring of the Conflict-of-Interest policy as part of his/her general monitoring duties and will report thereon in the annual compliance report. This policy shall be reviewed annually and updated if applicable. The compliance function is outsourced to an external Compliance company with no shareholding in CL Intermediary Services. The Compliance practice functions objectively and sufficiently independently of CL Intermediary Services and monitors the process, procedures, and policies that CL Intermediary Services has adopted to avoids conflicts of interest.

5.5 Training and staff
Comprehensive training on the Conflict of Interest is provided to all employees as part of specific and/or general training on the FAIS Act and GCOC. Training will be incorporated as part of all new appointees’ induction. Ongoing and refresher training on CL Intermediary Services’ Conflict of Interest management processes and policy is provided on an annual basis.

5.6 Registers
With regard to existing third-party relationships, being the product suppliers listed in our Contact Stage Disclosure letter, we confirm that we do not have an ownership interest or are subject to exclusive training nor are there any other circumstances which could lead to a potential conflict of interest. Should any conflicts arise with regard to any of these prior to entering into any business transaction with you we undertake to disclose these in the registers below. CL Intermediary Services has implemented the registers below:
1. Financial Interest Received
2. Business Relationships
3. Ownership Interests

1. Introduction
The Directors of CL Intermediary Services (Pty) Ltd took a decision to formally adopt the TCF outcomes and principles to assist to guide business to embrace and enforce the principles of fairness and objectivity in all daily processes of the business.
Our ethos and culture has always been to:
• Operate with transparency and honesty;
• Empower our clients to enable them to make informed decisions;
• Aim to “Wow” all client’s in our approach to service delivery;
• Work with purpose and as a team, delivering simple and practical solutions to complex problems;
• To accept nothing less than the best for our clients in terms of service excellence, client centricity and all business related communication; and
• Be sensitive and understanding of our clients’ needs

2. Objectives
CL Intermediary Services, as an authorised financial services provider, is fully committed to ensuring that our customers are treated fairly at all times. To ensure that a TCF culture is cultivated within our FSP, we have focused attention on high quality service delivery, fair treatment of customers and transparency remaining the centre of our focus as an organisation at all times. We undertake to ensure that quality management systems, processes, procedures and controls are formulated, implemented, reviewed and monitored to ensure, as far as possible, that clients experience professional servicing standards and fair treatment on all levels of interaction. We undertake to provide training and to equip each staff member on the principles contained herein and also to be and remain active participants in cultivating the TCF culture.

3. The six outcomes of Treating Customer Fairly
As a financial services provider, we embrace the spirit of the principle-based outcomes as published by the Financial Sector Conduct Authority; we are committed and will continuously strive to comply with these outcomes:
Outcome 1
Customers are confident that they are dealing with providers where the fair treatment of customers is central to the FSP’s culture.
Outcome 2
Products and services marketed and sold in the retail market are designed to meet the needs of the 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.

4. Achieving the outcomes
We realise that the success of achieving the fairness outcomes first and foremost lies in the way that we manage our FSP. We are convinced that quality management systems, policies, procedures, controls and appropriate training are necessary for bringing to fruition our best intentions which rise from these Outcomes. We further agree that each role player within our FSP must embrace the TCF outcomes and understand that each person has an important contribution to make in order for the FSP to consistently achieve these goals, collectively. We also aim to demonstrate through our behaviour and monitoring that we are consistently treating customers fairly through our governance structures as well as throughout the stages of the product life cycle, which are summarised below.
4.1 Leadership
4.1.1 The TCF objectives have been adopted by CL Intermediary Services management and who have taken responsibility for them.
4.1.2 Management shall endeavour to conduct regular reviews of the main business processes to identify areas requiring improved TCF outcomes.
4.1.3 TCF objectives shall be communicated to all staff across the business.
4.1.4 A process for assessing staff and management understanding of TCF and the organisation’s TCF commitments will be sourced and implemented.
4.1.5 Staff who contribute to the provision of financial services to retail customers are required to understand their role in delivering TCF outcomes to those customers.
4.1.6 We have incorporated the TCF outcomes as part of our vision, mission and values statement.
4.2 Strategy
4.2.1 As part of our strategic planning process, we shall provide for the explicit consideration of TCF implications of any new strategy or change in strategy and the FSP’s strategic plan shall include the TCF deliverables.
4.3 Decision-Making
4.3.1 We will consider TCF objectives when taking decisions in all business cases or projects (including expenditure) undertaken by CL Intermediary Services.
4.3.2 We have established an internal TCF forum for the purpose of providing an opportunity for all role-players within our FSP to raise any questions or concerns regarding TCF-related matters and engage in healthy debate thereof.

4.4 Governance & Controls
4.4.1 Oversight and monitoring of the TCF outcomes has been assigned to our internal TCF forum as well as an external compliance services provider.
4.4.2 CL Intermediary Services shall formulate, implement, regularly review and monitor processes.
4.4.2.1 to ensure formal and regular reporting of the progress of the implementation of TCF deliverables.
4.4.2.2 for identifying and reporting TCF risks or failures.
4.4.3 The management of TCF and market conduct risks shall be formally included in the risk management framework of CL Intermediary Services.
4.4.4 CL Intermediary Services governance framework shall be evaluated continually to ensure that it is effective in achieving the TCF outcomes.
4.5 Performance Management
4.5.1 Staff members have been identified who will be responsible for the delivery of the TCF outcomes within CL Intermediary Services.
4.5.2 Performance evaluation criteria shall be formulated and implemented to incorporate TCF objectives and shall be rigorously applied at all levels.
4.5.3 All staff members are required to undergo continuous training on TCF principles, standards and deliverables.
4.5.4 Recruitment processes have been formulated and implemented to ensure staff in relevant positions will have the necessary skills to deliver the FSP’s TCF objectives.
4.6 Measurement and Management Information
4.6.1 Management Information (MI) measures are designed and implemented for TCF monitoring.
4.6.2 CL Intermediary Services will furthermore determine processes to obtain MI on customer expectations and how these expectations are updated and amended on an ongoing basis.
4.6.3 Processes are formulated and implemented to collate and summarise TCF related MI in a meaningful way that provides a complete overview of the progress to which CL Intermediary Services is delivering TCF outcomes to customers, including, but not limited to, concrete examples of such progress.
4.6.4 Processes are formulated and implemented to enable CL Intermediary Services to analyse and act on MI findings to improve TCF outcomes for customers.
4.6.5 MI findings will be analysed to identify staff training needs as well as for performance management purposes.
4.6.6 CL Intermediary Services shall communicate transparently with our stakeholders (including the market conduct regulator) on our progress in achieving TCF outcomes and also make information regarding our progress publicly available.
4.6.7 Over and above “business as usual” MI, CL Intermediary Services shall have mechanisms in place when requested to monitor and respond to changes in the broader environment, to enable us to pro-actively identify TCF related risks.
4.6.8 CL Intermediary Services will provide concrete examples, supported by MI, of improvement in the extent to which we are delivering TCF Outcomes to customers, particularly in respect of products and services.
4.7 Clear and Appropriate Information
4.7.1 CL Intermediary Services shall assess the clarity, appropriateness and fairness of product information provided to customers, whether produced by CL Intermediary Services, or other third parties in order to ensure that any information we provide regarding our services are accurate, clear, fair and not misleading.
4.7.2 CL Intermediary Services shall formulate, implement, regularly review and monitor an approval process for all product related information for which compulsory sign-off by senior management is required.
4.7.3 CL Intermediary Services shall regularly review standardised product information we use to ensure that it remains accurate, clear and appropriate to the applicable customer groups.
4.7.4 CL Intermediary Services monitor and act on feedback, complaints and suggestions received from customers, staff or any other interested party that identifies the need for improvement in our product information.
4.7.5 CL Intermediary Services shall ensure relevant and adequate product information is provided to customers (whether by our own staff or by other third parties) at an appropriate time to enable them to make an informed decision as to whether to enter into the relevant contract.
4.7.6 CL Intermediary Services is required to provide existing customers with key information on products on a regular ongoing basis after contracting, through appropriate channels.
4.7.7 CL Intermediary Services commits to ensure that clients are informed of any recent or pending changes to the changes to client’s products and portfolio’s, contractual events or any actions required from them, in sufficient time, to enable them to reasonably respond to or act on the information.
4.7.8 CL Intermediary Services shall control the accuracy and quality of product information provided by staff.
4.7.9 CL Intermediary Services is required to maintain up-to-date contact details of existing customers.
4.7.10 CL Intermediary Services commits to ensure that our customers have current and accessible contact points if they need product or service information and need to get in touch with CL Intermediary Services for any reason whatsoever.
4.7.12 CL Intermediary Services is required to ensure that accurate, retrievable, secure records are maintained of all product information which has been provided to customers and any other material interactions with customers.
4.8 Advice
4.8.1 Prior to any decision to market a product, the provider is required to assess whether or not we have the appropriate skills and business processes in place to provide advice and service that will be suitable for our target market and product concerned.
4.8.2 Prior to contracting with any product supplier to market their products, the provider shall conduct a full due diligence, customer research and appropriate testing to ensure we have the appropriate comfort to satisfy ourselves that such products and service levels are likely to meet our customers reasonable expectations.

4.8.3 CL Intermediary Services shall monitor and act on feedback or complaints received from customers or other third parties regarding thequality of service.

4.8.4 Over and above complaints, CL Intermediary Services is required to monitor potential TCF indicators such as insurance claims experience, product retention, early termination data, type and frequency of product changes, etc. in relation to the customers associated, to identify and mitigate risks.
4.8.5 CL Intermediary Services formulate and implement controls to identify and address any conflicts of interest between ourselves and our customers.
4.8.6 Agreements between CL Intermediary Services and any other FSP must clearly set out the parties’ respective responsibilities in relation to customer selection of products, information and service support. Customers must be able to understand who they should look to in relation to different aspects of the financial products or service provided to them.
4.8.7 CL Intermediary Services for the compensation of customers who have been financially prejudiced as a result of poor service provided by ourselves.
4.8.8 CL Intermediary Services will be required to ensure that published decisions of the FAIS Ombud, guidance from the regulators and other relevant information sources in relation to products selected are analysed by management so as to evaluate whether our existing practices remain relevant and effective.
4.9 Product Performance Expectations
4.9.1 CL Intermediary Services will thoroughly analyse the product retention, product switching, early termination behaviour of our customers to identify risks that products or services are not meeting expectations created.
4.9.2 CL Intermediary Services shall formulate and implement:
4.9.2.1 processes to alert customers to the risks of particular actions on their part (such as early termination, non- payment of contributions, product s switches, benefit reductions) in reasonable time for them to respond to or act on the information.
4.9.2.2 processes to alert customers to the risks of non-action on their part, such as a failure to review insurance cover needs, beneficiary nominations and other relevant requirements.
4.9.2.3 clear service standards for customer service processes which shall be communicated to customers.
4.9.2.4 CL Intermediary Services shall implement processes to protect the confidentiality of all customer information.
4.9.3 CL Intermediary Services may conduct research or test the service standards to determine whether we are in line with customer/ member expectations.
4.9.4 Although CL Intermediary Services explicitly cannot accept responsibility for the performance of products or of product suppliers, or which product options the customer has selected, processes are to be formulated and implemented to mitigate the risks to our customers/members where it becomes apparent that products are not performing or are unlikely to perform as customers have been led to expect.
4.10 Changing Products
4.10.1 CL Intermediary Services commits to ensure that customers are informed (in good time, not only upon request) of the types of changes they may make to their products if their needs or circumstances change and of any important limitations on their ability to access funds or make changes.
4.10.2 CL Intermediary Services is required to ensure that when/if we become aware of a change in a customer’s needs or circumstances (including affordability difficulties), they are informed of changes they may consider making to their products to meet their changed requirements.
4.10.3 CL Intermediary Services has clear service standards in place for processing product changes (including where we need to refer the request to another party to deal with) and these are communicated to our customers.
4.10.4 Where a request for a product change is declined by any party in the value chain, the customer will advise the customer with clear reasons for this.
4.10.5 When a request is received to change a product, CL Intermediary Services is required to inform the customer of any potential risks associated with the change, in reasonable time, for them to respond to or act on the information.
4.11 Switching Providers
4.11.1 CL Intermediary Services must have clear service standards in place for processing switches to other providers which shall also form part of the customer servicing mandate.
4.11.2 When we receive a request to switch providers (whether directly or through another party), CL Intermediary Services shall inform the customer of any potential risks associated with the switch.
4.12 Claims and Disbursement Handling
4.12.1 CL Intermediary Services commits to ensure that customers are informed of how to submit a claim or disbursement request and of our service standards for claims and disbursement processing and what information we will need to process the claim or request.
4.12.2 CL Intermediary Services shall ensure that customers are informed prior to contracting, of the circumstances under which claims, or disbursement requests will not be processed and must ensure that the customer’s obligations are explained.
4.12.3 CL Intermediary Services commits to ensure that once a claim has been received, that customers/members are constantly informed of progress.
4.12.4 CL Intermediary Services shall analyse types of claims and claims repudiation experience to identify any miss-selling risks.
4.13 Complaints Handling
4.13.1 Our complaints process has been tested to ensure it is accessible and appropriate for our customer groups.
4.13.2 CL Intermediary Services shall implement a robust complaints management, record keeping and root cause analysis process.
4.13.3 CL Intermediary Services commits to ensure that customers are informed (before complaint stage) of how to complain and of options for further recourse if they are dissatisfied with the outcome of a complaint.

4.13.4 CL Intermediary Services may benchmark our complaints handling (volumes, resolution rates, Ombud complaints) against competitors.
4.13.5 CL Intermediary Services commits to ensure that once a complaint is received, we keep customers informed of the progress (including the contact person details) whether we are dealing with the complaint ourselves or have referred it to another party.
4.13.6 CL Intermediary Services will, when responding to a complaint, endeavour to provide clear reasons for our response (including where the response is favourable to the customer), with supporting evidence where relevant.
4.13.7 CL Intermediary Services will ensure that where a request for redress is declined, wholly or partially, we inform the customer/member of what steps they can take to have the decision reviewed.
4.13.8 CL Intermediary Services has clear service standards in place for processing complaints and ensures these are communicated to our customers.
4.13.9 CL Intermediary Services shall ensure that specific training is provided to staff that are tasked with complaints handling.
4.13.10 CL Intermediary Services shall ensure that complaints processes are structured to ensure that decisions will be objective, fair, consistent for similar complaints and that decision makers do not have a conflict of interest.
4.13.11 CL Intermediary Services may implement follow-up processes to determine customer satisfaction levels after complaints are finalised.
4.13.12 CL Intermediary Services is required to implement processes to ensure consistency in complaints handling.
4.13.13 CL Intermediary Services for fair compensation of customers who have been financially prejudiced by unfair treatment, and is not limited only to those customers who complain.
4.13.14 CL Intermediary Services will analyse complaints to identify any risks.
4.13.15 CL Intermediary Services is required to consider the nature of complaints received and complaints handling performance of different product suppliers in deciding whether to do business with them or recommend them or their products to customers.

5. Ownership and Accountability
This policy is owned by CL Intermediary Services (Pty) Ltd, an authorised financial services provider in terms of the Financial Advisory & Intermediary Services Act (37 of 2002). CL Intermediary Services accepts responsibility for the successful implementation of Treating Customers Fairly processes, procedures and controls in respect of the TCF Outcomes and objectives. As Key Individual of the provider, Eduann Vorster, hereby confirms the adoption of the policy.