RISK MANAGEMENT PLAN - FAIS COMPLIANCE



Sections

1. FAIS Act and Subordinate Legislation

Advice Process

Maintenance of Records

Client Service Level Agreement

New Client approval process

Client Exit Process

Financial Products

Licence Categories

Regulatory Accreditation

Fit and Proper Status of Key Individual and Representative

Operational ability

Representative Mandate

Representative Training

Monitoring of Representative

Representative under supervision

Debarment Process

Professional Indemnity Cover

Compliance Function

Financial Management

Non-cash Incentives and Conflict of Interest

Client Complaints

Advertisements

Premature Cancellations

Succession and Sustainability

Communication with Regulator

2. FIC Act

Client Due Diligence

Client Verification

PEP Verification

. Occasional / Ad hoc Transactions

Record Keeping

. Source of Funds Verification Staff Training

3. Income Tax Act

Record Keeping

VAT

On-time Submission

. 4. Basic conditions of Employment Act

. Staff Employment Contracts

Job Descriptions

Staff Training

Performance Management

Employment Termination

Record Keeping

Continuity Plan

5. Information Technology

. Record Keeping of Client Data and Transactions

. Access to and Protection of Client Data

. Audit Trail and Review of Client Data

.

.

. Back-up Procedure and Storage Facilities

Staff IT Training

. Internet and E-mail Policy

. Documented Business Processes

6. General Security

Access to Premises and Client Information

. Insurance

. Disaster Recovery Plan

. Budget for Risk Management

7. Occupational Health and Safety

8. Prevention of Organised Crime Act

9. Promotion of Access to Information

| FAIS Act & | | | | | | | |

|Subordinate Legislation | | | | | | | |

|Maintenance of Records |High |High |Medium |Process to maintain the |Key Individual |Weekly |Systems to be set up to |

| | | | |following: | | |ensure communication to |

| | | | |All written and verbal communications to clients | | |clients are sent. |

| | | | |relating to the rendering of financial services. | | | |

| | | | |Register of Premature Cancellations | | |Ensure that the register|

| | | | |Register for non-compliance – Compliance Reports by | | |is up to date at all |

| | | | |the Compliance Officer and any other feedback from | | |times. |

| | | | |clients and/or product providers. | | | |

| | | | |Records are stored safe from destruction. | | |Compliance |

| | | | |Records are kept for a | | |reports/feed-back from |

| | | | |period of five years after | | |clients should be kept |

| | | | |termination of the product or | | |in the compliance file. |

| | | | |after the rendering of the | | | |

| | | | |Financial service. | | |Storing facilities |

| | | | |Where electronic records are kept, electronic back-ups| | |should be fire proof and|

| | | | |are made and stored off-site. | | |locked. |

| | | | |All documents can be produced within 7 days for | | | |

| | | | |inspection by the Regulator. | | |Electronic back-ups |

| | | | | | | |should be tested and |

| | | | | | | |stored off-site. |

|Client Service Level Agreement |Medium |Medium |Medium |Service level agreement |Key Individual |Annually |Service Agreement for |

| | | | |entered into with all clients. | | |all new clients and for |

| | | | | | | |existing clients, at the|

| | | | | | | |annual review. |

|New Client Approval Process |Medium |Medium |Medium |Perform due diligence before taking on of a new client|Key Individual |As and when |New client should not |

| | | | |and obtain documentation as prescribed in the FICA | | |pose a risk to the FSP. |

| | | | |Internal Rules. | | |Refer to the FICA manual|

| | | | | | | |– process. |

| | | | | | | |Complete the FICA |

| | | | | | | |checklist. |

|Client Exit Process |Medium |Medium |Low |Process to deal with undesired clients. |Key Individual |As and when |Educate reps in the |

| | | | |Inform client in writing of suspension of services and| | |process to deal with |

| | | | |rights. | | |undesired clients. |

| | | | |Encourage client to obtain financial services | | | |

| | | | |elsewhere. | | | |

| | | | |Ensure that all business is concluded. | | | |

| | | | |Maintain records as prescribed. | | | |

| | | | |Inform product provided to cease payment of trail | | | |

| | | | |fees. | | | |

|Financial Products |High |High |Low |Internal control in place to render financial services|Key Individual |Ongoing |Ensure that reps have |

| | | | |in respect of products that qualifies as a financial | | |sub-codes with product |

| | | | |product as contemplated in section 1 of the Act. | | |providers who require |

| | | | |Only give advice on and sell products from authorised | | |it. |

| | | | |product providers and for which the FSP is mandated to| | | |

| | | | |sell. | | |Ensure that mandates are|

| | | | |Mandates with all product suppliers. | | |in the name of FSP as it|

| | | | |Mandates correctly reflect the name, legal entity and | | |appears on the FSB |

| | | | |licence categories. | | |licence. |

| | | | |Perform regular due diligence on product suppliers. | | | |

| | | | | | | |Due diligence at a |

| | | | | | | |minimum would require |

| | | | | | | |compliance reports and |

| | | | | | | |financials. |

|Licence Categories |High |High |Medium |Internal control to sell products and provide services|Key Individual/ |Ongoing |To ensure that no advice|

| | | | |for products that falls within the licence categories |Compliance Officer | |is provided on health if|

| | | | |and sub-categories that are reflected on the licence. | | |individual |

| | | | | | | |representative is not |

| | | | | | | |accredited and short |

| | | | | | | |term is done on a |

| | | | | | | |referral basis only. |

|Regulatory Accreditation |Medium |Medium |Low |FSB and FAIS Ombud Levies are paid when due. |Key Individual |Annually |Ensure representative |

| | | | |The FSP is fully accredited with the Council for | | |register with FSB is |

| | | | |Medical Schemes. | | |updated correctly |

|Fit and Proper Status of Key |Medium |Medium |Medium |Obtain approval from the Registrar before taking part |Key Individual |Ongoing |Ensure all |

|Individual and Representative | | | |in the conduct or management or overseeing of the | | |representatives complete|

| | | | |FSP’s business activities as Key Individual. | | |the necessary |

| | | | |Recruitment procedures must ensure that the | | |qualifications and set |

| | | | |representative have the necessary competency and | | |up training for |

| | | | |qualifications to give advice. | | |Continuous Professional |

| | | | |Perform quarterly checks on Key Individual and | | |Development. |

| | | | |Representative. The FAIS declaration signed by the Key| | | |

| | | | |Individual and representatives on a quarterly basis. | | | |

| | | | |Inform the registrar of any change in the personal | | | |

| | | | |circumstances of the Key Individual that may affect | | | |

| | | | |his fit and proper requirements. | | | |

| | | | |Key Individuals and Representatives conform to Column | | | |

| | | | |4 of the Determination for Fit and Proper | | | |

| | | | |Requirements. | | | |

| | | | |The Key Individual and Representative always act with | | | |

| | | | |honesty and integrity and with due care in the | | | |

| | | | |client’s best interest. | | | |

|Operational ability |Medium |Medium |Medium |Service level agreement for all outsourced functions. | | |Implement with |

| | | | |Key Individual manages and oversees all operational | | |accountant and IT |

| | | | |functions within the FSP. | | |support |

|Representative Mandate |Medium |Low |Low |Service contracts or mandatory agreements signed by |Key Individual |Annually |Update Disclosure |

| | | | |the representatives and Key Individuals of the FSP. | | |document when FSP/ |

| | | | |The representative mandate clearly states the | | |representative status |

| | | | |financial services for which the representative is | | |change |

| | | | |authorised. | | | |

| | | | |A register of representatives is kept of all | | | |

| | | | |representatives and an updated version provided to the| | | |

| | | | |FSB within 15 days of the change. | | | |

| | | | |The register contains the names and business | | | |

| | | | |addresses, the categories of financial services for | | | |

| | | | |the representative and whether they are employed or | | | |

| | | | |mandated. | | | |

| | | | |The disclosure letter of the representative includes | | | |

| | | | |their status as representative, a statement that the | | | |

| | | | |FSP accepts responsibility for the activities of the | | | |

| | | | |representatives as well as the Key Individual’s | | | |

| | | | |details. | | | |

| | | | |Agreement with each Juristic Representative. | | | |

| | | | |All employees of the juristic representative that | | | |

| | | | |renders financial services on behalf of the FSP are | | | |

| | | | |registered as representatives of the FSP. | | | |

|Representative Training |High |Medium |Medium |Training register to confirm that appropriate product |Key Individual |Ongoing |Discuss training needs |

| | | | |and compliance training was given to Representatives. | | |with each representative|

| | | | |Education plan for each representative to ensure that | | |and have a documented |

| | | | |the required qualification is obtained. | | |plan is in place and |

| | | | |Ongoing training regarding FAIS regulations and | | |kept up to date. |

| | | | |compliance requirements. | | | |

|Monitoring of Representative |Medium |Medium |Medium |Regular Monitoring of a Representative by completing |Key Individual/ |Monthly – |Equip the branch |

| | | | |the Key Individual checklist to: |Appointed Branch | |administrators with the |

| | | | |Ensure the advice process complies with the Code of |Administrator | |skills to have a |

| | | | |Conduct. | | |checklist in place to |

| | | | |Review implementation of remedial action for | | |ensure ongoing |

| | | | |non-compliance. | | |monitoring as well as |

| | | | |Confirm that the representative has remained within | | |monitoring of files |

| | | | |the categories he is authorised for. | | | |

|Representative under Supervision |Medium |Medium |Medium |Appointed qualified and competent supervisor. |Key Individual |Weekly/ |Each representative |

| | | | |An agreed supervision plan including training and | |Monthly |acting under supervision|

| | | | |progress monitoring programme. | | |must have a Supervision |

| | | | |Conduct regular performance appraisals, as well as | | |agreement in place and |

| | | | |continuous reviewing and assessing services rendered | | |this must be monitored |

| | | | |by the representative under supervision. | | |by the appointed |

| | | | |Disclose to clients that representative is acting | | |supervisor and feedback |

| | | | |under supervision. | | |via Performance |

| | | | |The Register of Representatives clearly indicates the | | |Appraisal. |

| | | | |representatives acting under supervision and the | | | |

| | | | |categories they are authorised. | | | |

| | | | |Supervision of the supervisor (if supervisor is a | | | |

| | | | |person different from the Key Individual) | | | |

|Debarment Process |Medium |Low |Low |Disciplinary process. |Key Individual |Ongoing |Ensure adherence to |

| | | | |Debarment process that ensures that authority to give | | |Labour legislation and |

| | | | |advice is withdrawn and that interests of clients are | | |requirement from FSB. |

| | | | |not prejudiced. | | | |

| | | | |Remove the Key Individual /Representative from the | | | |

| | | | |register and inform the Registrar within 30 days of | | | |

| | | | |debarment. | | | |

| | | | |Process to inform clients and conclude any outstanding| | | |

| | | | |business. | | | |

|Professional Indemnity Cover |Low |Low |Low |Adequate cover and premiums are duly paid. |Key Individual |Annually |On an annual basis, |

| | | | |Disclose whether or not the FSP holds cover to | | |review what is being |

| | | | |clients. | | |covered and what is |

| | | | | | | |excluded. Review |

| | | | | | | |indemnity limits. |

|Compliance Function |High |Medium |Medium |Maintain an efficient compliance function. |Key Individual/ |Key Individual|Recommended actions of |

| | | | |Staff members are regularly trained on compliance |Compliance Officer |– daily |CO as contained in |

| | | | |requirements. | |CO – monitors |reports are analysed, |

| | | | |The Compliance Officer performs monitoring procedures | |as per SLA |implemented & |

| | | | |and provides feedback and recommendations as per SLA. | | |communicated to staff. |

| | | | | | | |Provide the CO access to|

| | | | | | | |all business activities.|

| | | | | | | |Actively promote a |

| | | | | | | |culture of compliance |

| | | | | | | |within the FSP. |

|Financial Management |Medium |Low |Low |Monthly accounting records are kept up to date. |Key Individual |Monthly |Appointment of |

| | | | |Annual Financial Statements are submitted to the | | |Accountant to ensure |

| | | | |Registrar within six months of financial year end. | | |compliance with SARS and|

| | | | |Assets (excluding goodwill) to exceed liabilities by | | |auditing of financials. |

| | | | |31/12/2010. | | | |

| | | | |Inform product provider if deemed Personal Services | | | |

| | | | |Company (where commission of one product provider | | | |

| | | | |exceeds 80% of all commission income) | | | |

|Non-cash Incentives and Conflict |Low |Low |Low |Disclose to client if the FSP: |Key Individual |Ongoing |Review commission income|

|of Interest | | | |Holds more than 10% of any insurers shares | | |on an annual basis and |

| | | | |Received more than 30% commission from any one insurer| | |update disclosure letter|

| | | | | | | |accordingly. |

| | | | |Received any non-cash incentives or indirect | | |Make sure that the |

| | | | |consideration from any other person | | |registers are updated if|

| | | | |The existence of any personal interest in the relevant| | |there are any |

| | | | |service, of any circumstance that gives rise to an | | |circumstances that are |

| | | | |actual or potential conflict of interest. | | |not at arm’s length. |

| | | | |Process to take reasonable steps to ensure fair | | |Special care should be |

| | | | |treatment of the client. | | |taken and details |

| | | | |Non-cash incentives and/of indirect consideration is | | |disclosed |

| | | | |duly entered on the register. | | |upfront(contact stage |

| | | | |Policy in place on how to deal with non-cash | | |disclosure letter) |

| | | | |incentives and conflict of interest. | | | |

|Client Complaints |High |Medium |Medium |Comprehensive internal complaints policy and process |Key Individual |Ongoing |Complaints resolution |

| | | | |which ensures that clients have full knowledge and | | |policy to be understood |

| | | | |accessibility to the procedures, and which enables | | |by all within the FSP. |

| | | | |complaints to be dealt with effectively, timeously and| | | |

| | | | |fairly. | | | |

| | | | |Appoint a person to be in control of Complaints | | | |

| | | | |Register. | | | |

| | | | |Inform clients on disclosure letter of complaints | | | |

| | | | |policy and procedure. | | | |

| | | | |Each complaint is entered into the register. | | | |

|Advertisements |Low |Low |Low |Advertising process for disclosure requirements to |Key Individual |Ongoing |Advertising to contain |

| | | | |ensure all advertisements and marketing material | | |reference that the FSP |

| | | | |complies with the Code. | | |is an authorised |

| | | | |Reference to being an Authorised Financial Services | | |financial services |

| | | | |Provider is contained in all business communication | | |provider. |

| | | | |and advertisements. | | |Any advertising to be |

| | | | |Display a certified copy of the licence within every | | |done must be approved by|

| | | | |business premises of the FSP. | | |Key Individual |

| | | | |Recordings kept of all telephonic advertisements. | | | |

|Premature Cancellations and |High |Medium |Medium |Complete the policy comparison template for all |Key Individual/ |Weekly |Ensure Comparison Policy|

|Replacement of financial products | | | |financial products that are replaced. |Representatives/ | |Advice Record as |

| | | | |Enter all replacements/ cancellations of financial |Branch administrators | |provided and provide |

| | | | |products on the premature cancellations register. | | |client with a copy. |

| | | | |Note all consequences and reasoning of the replacement| | | |

| | | | |on the client advice record and provide client with | | |Changes to policies: |

| | | | |copy of the product comparison document. | | |Ensure the differences, |

| | | | |Inform the product supplier that the product is | | |costs and financial |

| | | | |replacing another financial product where a long term | | |implications as well as |

| | | | |contract is replaced. | | |the reasons are detailed|

| | | | | | | |on your client advice |

| | | | | | | |record. |

| | | | | | | | |

| | | | | | | |Ensure the register is |

| | | | | | | |timeously updated. |

|Succession and Sustainability |High |Medium |Medium |Documented plan to provide for voluntary and |Key Individual | Annually |Succession plan to be |

| | | | |involuntary succession, temporary disability and | | |done for each |

| | | | |absence. | | |representative as well |

| | | | |Marketing and business plan in place to ensure | | |as business. |

| | | | |sustainability of the business. | | |Third party agreements |

| | | | |Documented arrangements for all business alliances and| | |to be implemented |

| | | | |strategic partners. | | | |

|Communication with the Regulator |High |Low |Low |Process to inform the Registrar within 15 days of any |Key Individual |Ongoing |Inform National |

| | | | |change within the business on the prescribed forms | | |Compliance of all |

| | | | |FSP1, FSP3, FSP4, FSP9, FSP10, FSP10A or FSP11. | | |changes required. Keep |

| | | | | | | |record of submissions to|

| | | | | | | |the FSB as well as |

| | | | | | | |confirmation received |

| | | | | | | |from the FSB. |

| | | | | | | | |

|Financial Intelligence Centre Act | | | | | | | |

|Client Verification |Medium |Low |Low |Obtain the required documentation for all active |Key Individual/ |Ongoing | |

| | | | |clients as prescribed by the Internal Rules. |All representatives/ | | |

| | | | | |Branch administrators | | |

|PEP Verification |Medium |Low |Low |Process to establish whether the client is a |Key Individual/ |Ongoing | |

| | | | |politically exposed person and due care to obtain |All representatives/ | | |

| | | | |verification documents and proof of source of funds. |Branch administrators | | |

|Recurring/ Ad hoc Transactions |Medium |Low |Low |Process to verify the nature and frequency of |Key Individual/ |Ongoing | |

| | | | |occasional transactions. |All representatives/ | | |

| | | | | |Branch administrators | | |

|Record Keeping |High |Low |Low |Process to maintain the following: |Key Individual/ |Daily | |

| | | | |FICA Internal Rules |All representatives/ | | |

| | | | |Process for Reporting |Branch administrators | | |

| | | | |Suspicious Transactions | | | |

| | | | |Staff training register | | | |

| | | | |FICA Training Manual | | | |

| | | | |Records are stored safe from destruction. | | | |

| | | | |Records are kept for a period of five years after | | | |

| | | | |termination of the product or after the rendering of | | | |

| | | | |the financial service. | | | |

| | | | |If stored by third parties, then FIC to be informed. | | | |

|Source of Funds Verification |High |Low |Low |Take reasonable measures to establish source of |Key Individual/ |Ongoing |Complete the FICA |

| | | | |income. |All representatives/ | |checklist found in the |

| | | | |Verification process to establish source of |Branch administrators | |Internal Rules. |

| | | | |investments funds. | | | |

|Staff Training |High |Medium |Medium |Staff trained on FICA and completed a competency test.|Key Individual/ |Annually |Staff refresher training|

| | | | |Money Laundering Officer (MLO) appointed. |All representatives/ | |on an annual basis as |

| | | | |Regular ongoing and refresher training for all |Branch administrators | |well as FICA test |

| | | | |employees, at a minimum annually. | | | |

|INCOME TAX ACT | | | | | | | |

|VAT |Medium |Medium |Medium |Records kept up to date and stored safe from |Key Individual/ |Monthly | |

| | | | |destruction. |Appointed Accountant | | |

|On Time Submission |Medium |Medium |Medium |Process to submit VAT and Income Tax within the |Key Individual/ |VAT – two | |

| | | | |prescribed period. |Appointed Accountant |monthly | |

| | | | | | |Income Tax – | |

| | | | | | |Annually | |

|BASIC CONDITIONS OF EMPLOYMENT | | | | | | | |

|Job Descriptions and segregation |Medium |Low |Low |Job descriptions of the role functions and duties for |Key Individual |Annually | |

|of duties | | | |each staff member. | | | |

|Staff Training |High |Medium |Medium |Ongoing training regarding FAIS regulations, |Key Individual |Ongoing | |

| | | | |operational and administrative functions as well as | | | |

| | | | |technical knowledge. | | | |

| | | | |Staff training register kept up to date with in-house | | | |

| | | | |and external training. | | | |

| | | | | | | | |

|Performance Management |Medium |Low |Low |Conduct regular performance monitoring and provide |Key Individual |Bi-annually |The actions are |

| | | | |staff member with feedback and recommendation for | | |contained in the control|

| | | | |remedial action. | | |column. |

|Employment Termination |High |Medium |Low |Disciplinary process. |Key Individual |Ongoing |The actions are |

| | | | |An employment termination process that ensures that | | |contained in the control|

| | | | |the correct procedures are followed as described by | | |column. |

| | | | |Labour legislation. | | | |

| | | | |Process to consult with Labour Lawyer if necessary. | | | |

|Record Keeping |High |Low |Low |Keep all staff records up to date and safe from |Key Individual |Monthly | |

| | | | |destruction. | | | |

|Continuity Plan |High |Medium |Medium |Documented continuity plan to ensure that all |Key Individual |Monthly |Staff and administration|

| | | | |functions are performed when a key person is absent or| | |continuity plan |

| | | | |leave the FSP’s employment. | | | |

|INFORMATION TECHNOLOGY | | | | | | | |

|Access to and Protection of Client|High |Medium |Low |Confidentiality agreement signed by the representative|Key Individual/ |Monthly |Ensure all staff are |

|Data | | | |and client. |All representatives/ | |aware of this process |

| | | | |Confidentiality clause part of staff employment |Branch administrators | | |

| | | | |contracts and representatives mandates. | | | |

| | | | |Access to client data is password protected. | | | |

| | | | |An audit trail is printed regularly to review data | | | |

| | | | |captured and/or updated. | | | |

|Audit Trail and Review of Client |Medium |Medium |Medium |The Key Individual performs checks to ensure all data |Key Individual |Monthly |Electronic data to be |

|Data | | | |is correctly and timeously captured. | | |reviewed regularly. |

| | | | |The Key Individual regularly reviews the audit trail | | | |

| | | | |and follows up on inconsistencies. | | | |

|Back-up Procedure and Storage |High |Medium |Medium |Regular back ups of electronic records. |Key Individual |Daily/ |Back-ups to be tested. |

|Facilities | | | |Back ups are consistently tested to ensure that | |Weekly | |

| | | | |information was correctly backed up and are easily | | | |

| | | | |retrieved. | | | |

| | | | |Back-ups are stored offsite and are easily accessible.| | | |

| | | | |Offsite storing facilities are regularly inspected. | | | |

| | | | |Records are stored safe from destruction. | | | |

|Staff IT Training |High |Low |Low |Ongoing staff training | |Quarterly |The actions are |

| | | | |Staff training register is updated with in-house and | | |contained in the control|

| | | | |external training. | | |column. |

|Internet and E-mail Policy |Medium |Low |Low |Virus protection and firewalls are included in the | |Quarterly |The actions are |

| | | | |contract from the internet service provider and are | | |contained in the control|

| | | | |updated on a daily basis. | | |column. |

| | | | |The contract with the internet service provider | | |Make use of read |

| | | | |provides for assistance during system failures within | | |receipts. |

| | | | |reasonable time. | | | |

| | | | |Confirm all e-mail correspondence containing client | | | |

| | | | |information with a reply e-mail or telephone call. | | | |

| | | | |Process in place to ensure the usage of licensed | | | |

| | | | |software. | | | |

| | | | |Process to allow for formal IT audits. | | | |

| | | | |Staff are trained and restricted in terms of internet | | | |

| | | | |usage and access. | | | |

|Documented Business Processes |Medium |Medium |Medium |All business processes and electronic workflow are |Key Individual/ |Ongoing |Workflow manuals to be |

| | | | |duly documented. |Branch Administrators | |created. |

|GENERAL SECURITY | | | | | | | |

|Insurance |High |Low |Low |Adequate short term policy in place to cover loss of |Key Individual/ |Annually |Review policy on an |

| | | | |equipment, assets, premises and includes public |All Representatives/ | |annual basis. |

| | | | |liability. |Branch Administrators | | |

|Disaster Recovery Plan |High |Low |Low |Documented plan to provide for natural disasters. |Key Individual/ |Annually |To be implemented. |

| | | | | |All Representatives/ | |Include back-up process,|

| | | | | |Branch Administrators | |insurance, budget and |

| | | | | | | |adequate security |

| | | | | | | |measures. |

|Budget for Risk Management |High |Low |Low |Budget is provided for the implementation of |Key Individual |Annually | |

| | | | |appropriate controls and mitigating actions for the | | | |

| | | | |effective maintenance of the risk management plan. | | | |

1. OCCUPATIONAL HEALTH AND SAFETY ACT

|Medium |Medium |Medium |Complete the Occupational Health and Safety questionnaire regularly. |Key Individual/

All representatives/

Branch Administrators |Annually |Every employer shall provide and maintain, as far as is reasonably practicable, a working environment that is safe and without risk to the health of his employees. All branches to have Occupational Health and Safety Poster | |PREVENTION OF ORGANISED CRIME ACT

|Low |Low |Low |It is a criminal offence for anyone who knows, or ought to reasonably to have known, that property is or forms part of the proceeds of a criminal offence, to enter into any agreement with anyone connected with such proceeds. |Key Individual/

All representatives/

Branch Administrators |Annually |Educate all on this requirement | |PROMOTION TO ACCESS TO INFORMATION ACT

|Low |Low |Low |This Act aims to give effect to the right of access to any information held by the State and any information that is held by another person and that is required for the exercise or protection of any rights. |Key Individual/

All representatives/

Branch Administrators |Annually | | |

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Risk Management Plan

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FAIS Compliance and Licensing CC • CK Number: 2010/091291/23 Practice Number: 5878 • Member: Mrs A Govender

FAIS Compliance and Licensing CC • CK Number: 2010/091291/23 Practice Number: 5878 • Member: Mrs A Govender

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