Legal & Compliance

Conflict of Interest Management Policy

Excessible is committed to acting with honesty, fairness and objectivity. This policy explains how we identify, avoid, disclose and manage any actual or potential conflicts of interest — so that your interests always take precedence.

This Conflict of Interest Management Policy is maintained in compliance with the Financial Advisory and Intermediary Services Act, 2002 (FAIS Act) and the General Code of Conduct for Authorised Financial Services Providers and their Representatives.

Our commitment

Excessible is committed to:

  • Rendering financial services honestly, fairly, and with due skill, care and diligence;
  • Avoiding or mitigating conflicts of interest that could harm clients;
  • Disclosing any unavoidable conflicts to affected clients clearly and promptly; and
  • Ensuring that the client's interest always takes precedence over the interests of Excessible or its representatives.

What is a conflict of interest?

A conflict of interest is any situation in which Excessible or its representatives have an actual or potential interest that may influence the impartial rendering of financial services to a client — for example, a financial interest, an ownership interest, or a relationship with a third party — that could prevent us from acting fairly and in the client's best interests.

How we identify conflicts

All employees, representatives and key individuals are trained to recognise situations where conflicts may arise, including:

  • Relationships with product suppliers — where financial incentives or close relationships could influence the objectivity of advice or service;
  • Personal interests vs client interests — where a representative's personal or financial interests might conflict with a client's best interests; and
  • Third-party incentives and commissions — where commissions, bonuses or rewards could create pressure to favour certain products.

How we avoid conflicts

  • We screen and conduct due diligence on partnerships, suppliers and client dealings;
  • We set clear boundaries for acceptable gifts and incentives; and
  • We promote independence in decision-making, so recommendations remain objective.

How we disclose conflicts

Where a conflict cannot be avoided, we disclose it to the affected client in writing, clearly and promptly. Our disclosure addresses:

  • The nature and extent of the conflict, and how it could influence our service;
  • The measures we have taken to mitigate it (such as enhanced oversight, separation of advisory and sales roles, and internal controls); and
  • A client-centric assurance that your best interests remain our priority.

Financial interests and benefits

Excessible, its employees and representatives may only receive or offer financial interests as permitted under the FAIS General Code of Conduct:

  • Commission as authorised by law — strictly in accordance with the Long-term Insurance Act or the Short-term Insurance Act, and directly related to the services or policies provided to you;
  • Fees for services rendered — reasonable, transparent, disclosed to you beforehand, and agreed in writing; and
  • Immaterial financial interests — the aggregate value of which does not exceed R1,000 per representative per calendar year from the same third party.

Any financial interest or benefit that falls outside these categories is strictly prohibited.

Associates and third parties

Excessible acts as an intermediary and places business with a panel of authorised product suppliers (underwriters).

Short-term insurers

  • Hollard Insurance
  • Santam
  • New National
  • Old Mutual Insure
  • MiWay Insurance
  • GuardRisk (cell captive insurer)
  • iTOO Special Risks (specialty lines)

Long-term (life & funeral) insurers

  • 1Life Insurance Ltd (FSP 24769) — including My Life Plus and our Essential and Exclusive funeral plans.
  • Liberty Group Ltd (FSP 2409) — including Lifestyle Protector and Business Life Cover.

We also work with authorised insurance administrators and broker-technology partners in support of these arrangements. Our relationships with all these third parties are managed under this policy, and any conflict arising from them is identified, disclosed and mitigated as set out above.

Our Conflict of Interest Register

We maintain a Conflict of Interest Register recording identified conflicts, the mitigation measures taken, and the disclosures made to clients. The register is reviewed and updated regularly and is available to compliance officers, auditors and regulators.

Monitoring and review

Our Compliance Officer monitors adherence to this policy, and breaches are investigated and addressed in line with our disciplinary procedures. This policy is reviewed at least annually.

Approved by the Key Individual on 26 May 2025.
Last reviewed: 14 September 2026 · Excessible (Pty) Ltd · FSP No. 55248 · Authorised Financial Services Provider regulated by the FSCA.