1. Introduction:

This policy outlines a suitable, effective and sustainable approach to the identification and management of conflicts of interest (“COI”).

 

The policy aims to comply with the best practice and statutory requirements as per the General Code of Conduct for Financial Services Providers and Representatives published in Board Notice 80 of 2003 as amended by Board Notice 58 of 2010 as well as other applicable requirements as set out in the Financial Advisory and Intermediary Services Act, 37 of 2002 (“FAIS”).

 

2. Purpose:

This document embodies the Conflict-of-Interest Management Policy for Catalyx Capital Proprietary Limited, a Member of the Johannesburg Stock Exchange with Alpha code LYXM  and Catalyx Investments Proprietary Limited, an Authorised Financial Services Provide FSP number 50311, together Catalyx.

 

The purpose of this policy is:

1. to provide guidance on the behaviours expected in accordance with Catalyx’s standards;
2. to promote transparency and to avoid or mitigate any business-related COI that may arise between [insert FSP Name], its clients, vendors and/or employees respectively;
3. to ensure fairness in the interests of employees and Catalyx;
4. to document the process for the disclosure, approval and review of activities that may amount to actual, potential or perceived COI;
5. to provide a mechanism for the objective review of personal outside interests.

Catalyx is committed to ensuring that all business is conducted in accordance with good business practice.  To this end Catalyx conducts business in an ethical and equitable manner and in a way, that safeguards the interests of all stakeholders to minimize and manage all real or potential conflict of interest (“COI”). Catalyx and its representatives must therefore avoid (or mitigate where avoidance is not possible) any COI between Catalyx and a client or its representative and a client.

 

3. Definitions

For purposes of this policy, the following words and/or phrases are defined herein:

 

“Conflict of interest” means any situation in which Catalyx or its representatives has an actual or potential interest that may, in rendering a financial service to a client influence the objective performance of his, her or its obligations to that client; or prevent Catalyx or its representatives from rendering an unbiased and fair financial service to that client, or from acting in the interests of that client, including, but not limited to

1. a financial interest;
2. an ownership interest;
3. any relationship with a third party (“third party”) means
   1. a product supplier,
   2. another provider,
   3. an associate of a product supplier or a provider;
   4. a distribution channel;
   5. any person who in terms of an agreement or arrangement with a person referred to in paragraphs (a) to (d) above provides a financial interest to a provider or its representatives.)

“FAIS” means the Financial Advisory and Intermediary Services Act, 37 of 2002.

 

“Financial interest” means any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic and foreign travel, hospitality, accommodation, sponsorship, other incentive or valuable consideration, other than –

1. an ownership interest
2. training, that is not exclusively available to a selected group of providers or representatives on products and legal matters relating to those products; general financial and industry information; specialized technological systems of a third party necessary for the rendering of a financial service; but excluding travel and accommodation associated with that training.

“Immaterial financial interest” means 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 –

1. a provider who is a sole proprietor; or
2. a representative for that representative’s direct benefit;
3. a provider, who for its benefit or that of some or all of its representatives, aggregates the immaterial financial interest paid to its representatives.

“Representative” means duly appointed representative and/or representative under supervision of Catalyx Strategic Advisors.

 

“Ownership interest” means

1. any equity or proprietary interest, for which at fair value was paid by the owner at the time of acquisition, other than equity or a proprietary interest held as an approved nominee on behalf of another person; and
2. includes any dividend, profit share or similar benefit derived from that equity or ownership interest.

“Provider” means Catalyx, including Catalyx Capital and Catalyx Investments jointly.

 

4. Procedures:

Catalyx or its representatives may only receive or offer financial interest from or to a third party as determined by the Commissioner of Financial Services Providers from time to time.

 

Catalyx may not offer any financial interest to its representatives for giving preference to the quantity of business secured for the provider to the exclusion of the quality of the service rendered to clients; or giving preference to a specific product supplier, where a representative may recommend more than one product supplier to a client; or giving preference to a specific product of a product supplier, where a representative may recommend more than one product supplier to a client

 

• 4.1 Identification of Conflicts of Interest
  Conflicts of interest can arise in various ways. Common examples include:
  • Financial interests, such as personal ownership of shares in a company recommended to clients.
  • Personal relationships, such as family or close friendships, that might influence business decisions.
  • Outside business activities or directorships that could create a conflict with the interests of clients or the Company.
  • Receiving gifts, hospitality, or other benefits that may compromise impartiality.

• 4.2 Management of Conflicts of Interest
  Catalyx is committed to managing conflicts of interest through the following measures:
  • Disclosure: All staff must disclose to management any potential or actual conflicts of interest as soon as they arise. This includes personal relationships, financial interests, or outside business activities that may present a conflict.
  • Avoidance: Where possible, Catalyx will take steps to avoid situations where a conflict of interest may arise. If avoidance is not possible, the Catalyx will take appropriate action to mitigate the conflict.
  • Separation of duties: Where applicable, Catalyx will implement procedures to separate individuals or teams with conflicting roles and responsibilities to minimize the risk of a conflict influencing decisions.
  • Independent Oversight: For significant conflicts, Catalyx will appoint an independent compliance officer or senior management team to oversee and approve any decisions affected by a potential conflict.
  • Transparency: The Company will maintain transparency with clients, informing them of any potential conflicts of interest that may arise and how they are being managed.

• 4.3 Procedures for Disclosing and Managing Conflicts
  • Staff Disclosure: All staff members must disclose any potential conflicts of interest to the Compliance Officer or relevant supervisor. Disclosure should be made in writing or through an electronic system as designated by the Company.
  • Client Notification: If a conflict of interest is identified that may affect a client’s investment or financial decisions, the Company will provide written notification to the client and explain how the conflict is being managed.
  • Approval and Review: Where necessary, conflicts of interest will be subject to approval by senior management, and mitigation measures will be reviewed periodically to ensure they remain effective.

• 4.4 Record-Keeping
  Catalyx will maintain comprehensive records of any identified conflicts of interest, the measures taken to manage or mitigate them, and any disclosures made to clients. These records will be kept for a minimum of five years to comply with regulatory requirements and to support ongoing compliance monitoring.

 

5. Training and Awareness

Catalyx will provide regular training and awareness programs to all staff regarding the identification, management, and disclosure of conflicts of interest. Staff will be encouraged to raise concerns regarding any potential or perceived conflicts, and to seek guidance from the Compliance Officer or senior management when necessary.

 

6. Regulatory Compliance

Catalyx will ensure that it adheres to the applicable laws, regulations, and codes of practice related to conflict of interest management, including but not limited to:

• The Financial Advisory and Intermediary Services Act (FAIS) and associated regulations.
• The Financial Sector Conduct Authority (FSCA) guidance.
• The Companies Act of South Africa.

7. Breach of Policy

Any breach of this policy by an employee, director, or other associated person will be subject to disciplinary action. Actions may include, but are not limited to, reprimands, suspension, or termination of employment or business relationships, depending on the severity of the breach.

 

8. Review of the Policy

This policy will be reviewed annually or sooner if required by regulatory changes, business circumstances, or operational feedback. Any amendments to the policy will be communicated to all relevant staff and stakeholders.

 

9. List of all Catalyx associates:

Catalyx Capital is a Juristic Representative of Catalyx Investments. Hosiah Investments (Pty) Ltd registration number 2024/294709/07 and Catalyx Partners 2024/633931/07 are the shareholders for both entities. The Ultimate Beneficial owners are employed by the companies.

 

10. Names of any third parties in which Catalyx hold an ownership interest:

Nether entity holds an ownership in any other third party.

 

11. Names of any third parties that holds an ownership interest in Catalyx

Hosiah Investments (Pty) Ltd registration number 2024/294709/07 and Catalyx Partners 2024/633931/07 are the shareholders for both entities. The Ultimate Beneficial owners are employed by the companies.

 

12. Conclusion:

All representatives of Catalyx including key individuals and management are required to be dedicated to upholding the highest level of integrity and ethical conduct in all of their activities and relationships with all stakeholders.