Conflict of Interest Policy

Our policy on managing conflicts of interest at MCKL.

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This policy is intended to guide customers and staff to meet Advisors & customer management process in the management of conflicts of interest. To ensure that our customers are treated fairly, and are not prejudiced in any way by the existence of a conflict of interest that may unduly influence our fiduciary responsibility.

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Scope

This policy covers all individuals working at all levels and grades, including managers, officers, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term employees, casual staff and volunteers (collectively referred to as staff or employees). All staff are responsible for their own compliance with this policy and for ensuring that it is consistently applied.

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Purpose / Summary

MCKL conducts its business honestly and ethically wherever we operate in the world. We constantly improve the quality of our services, products and operations and strive to create and maintain our reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment. No illegal or unethical conduct on the part of officers, directors, employees or affiliates is in MCKL's best interest.

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Definitions

Conflict of interest: Applies when rendering a financial service to our clients and where we (provider or representative) have an actual or potential interest that may influence the objective performance of obligations to our client, prevents us from rendering an unbiased and fair financial service to our client, or prevents us from acting in the interests of our client.

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Identifying Conflicts of Interest

To adequately manage conflicts of interest, Advisors must identify all relevant conflicts timeously. In managing conflicts of interest, our procedure is to: identify the conflicts of interest; assess and evaluate those conflicts; and decide upon, and implement, an appropriate response to those conflicts.

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Management Strategies:

1. Avoid the conflict of interest

2. Mitigate the impact

3. Where this is not possible, full disclosure of the Conflict of Interest (COI)

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Disclosure and Recordkeeping

It is this business's policy to avoid all possible conflicts of interest, but if this is not possible, then full disclosure of this conflict must be made in writing to our clients. Part of managing conflicts of interest is making appropriate disclosures. Our clients will be adequately informed about any conflicts of interest that might affect the provision of financial services to them.

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Gifts and Inducements

Representatives are permitted to receive gifts, sporting tickets, vouchers or other items from a product provider, or other FSP, to the maximum value of R1 000 per calendar year. Any items or activities which have a value exceeding this must be returned or paid for by the representative.

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Examples of Conflicts of Interest

• Personal interests may include working relationships and/or financial interests with immediate family members or relatives

• Activities include outside employment in areas similar to those in which our business is involved

• Outside work for clients, suppliers, vendors, or competitors of the business

• Operating as a supplier to the FSP

• Activities that have the potential to affect the staff member's objectivity

• Holding a financial interest in a business concern that is a supplier, client, partner, subcontractor, or competitor of our business

• Incentive remuneration for placing a quantity of business with only 1 supplier, or for only 1 product of a supplier where a choice is available

• Participating in any activity that might lead to or give the appearance of unapproved disclosures of confidential information

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Insider Trading

Officers and employees will often come into contact with, or have possession of, proprietary, confidential or business-sensitive information and must take appropriate steps to assure that such information is strictly safeguarded. Misuse of material inside information in connection with trading in securities can expose an individual to civil liability and penalties.

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Staff Training and General Awareness

Staff must be trained on this policy. A copy of the policy will be provided to each staff member at the inception of that staff member's duties and updated versions must be circulated as and when they are updated. It is our policy to inform all clients of the existence of this policy, and make it available to such clients on our website.