Conflict of


1. Definitions

1.1 Clients: refers to institutions or individuals which have a signed Mandate with Lefika to provide financial services.
1.2 Compliance department: refers to Lefika Securities’ compliance officer and team that works with the compliance officer
1.3 Consultant: refers to an individual or expect providing services to Lefika Securities on a temporary or contractual basis
1.4 Dealer: refers to a trader employed by Lefika Securities
1.5 Human resources department: refers to Lefika Securities department responsible for human resources
1.6 Key Individual: refers to the individual appointed as Lefika Securities’ Key Individual in terms of the Financial Advisory and Intermediary Services Act, 37 of 2022
1.7 Managing Director: refers to Mr Vusimuzi Mkhondo
1.8 Mandate: refers to the agreement entered into between Lefika Securities and a Client
1.9 Staff: refers to individuals that have entered into an employment contract with Lefika Securities.

2. Introduction

Lefika Securities Proprietary Limited (“Lefika Securities”) recognises that regulatory compliance is critically important to the integrity of the company. As such, as a financial services provider (FSP), Lefika Securities manages all conflicts of interest in accordance with:


a) Section 3A(2)(b) of the General Code of Conduct provided for under the Financial Advisory and Intermediary Services Act 81 of 2002.


Lefika Securities is aware of its responsibility as an FSP to avoid conflicts where avoidable. Lefika Securities does however recognise that certain conflicts are unavoidable due to the nature of the services it provides. In such instances, Lefika Securities takes all reasonable steps to mitigate all conflicts of interest as far as possible.

3. Mechanisms for identifying conflict of interest

3.1 Introduction
The mechanisms for identifying conflicts are formal in Lefika Securities. Additionally, the identification of conflict will be executed informally as part of an ongoing assessment and communication between the directors, traders and compliance department.


3.2 Mechanisms
Lefika Securities in addition to ongoing assessments and communication between the Directors, Traders and Compliance team, will implement the following mechanisms in an effort to identify actual or potential conflicts of interests:


3.2.1 management and internal, together with external compliance, legal, and audit where required will conduct bi-annual reviews on: all contracts held with Third parties and re-examine whether this relationship influences Lefika Securities’:
a) objective performance towards its clients,
b) ability to render fair and unbiased financial services towards its clients
c) ability to act in the interest of the client declarations signed by all Key Individuals, and Representatives confirming the presence or absence of any actual or potential conflict of interest and update accordingly. the list of identified actual or potential conflict of interests, as discussed in clause 3.3 below and update accordingly.

3.3 Identification of Conflict of Interest
The management and internal compliance of Lefika Securities have identified the following activities as potential conflict of interest:


3.3.1 Giving and Receiving of Gifts,
3.3.2 Personal Account Trading,
3.3.3 Trade order prioritisation, and
3.3.4 Key Individual and shareholder conflict of interest
3.3.5 Employee with dual employment.


Identification of conflict as stated in clause 3.1 above, will continuously be done as part of an ongoing assessment and communication between the Directors, traders and compliance department.


The above potential conflict of interest list is not exhaustive and will be amended from time to time as mentioned in clause above.


The employees of Lefika Securities are to adhere to the policies outlined in clauses 3.3.1 – 3.3.5 below in order to mitigate against the potential conflict of interest listed above.


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