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CONFLICT OF INTEREST MANAGEMENT POLICY (SUMMARY)

1. Introduction and Purpose

Rihlat Muzdahira (Pty) Ltd (the "Company") is an authorised Financial Services Provider (FSP: 54971), regulated by the FSCA. As a provider of Shariah-compliant alternative investments, we uphold the highest standards of ethics, faith-based integrity, and professionalism.

The purpose of this policy is to ensure that all actual, potential, or perceived conflicts of interest are identified, disclosed, and managed to protect the interests of our clients and investors. We are committed to ensuring that every transaction and decision embodies accountability and transparency.

2. Regulatory Basis

This policy is issued in accordance with:

  • • The Financial Advisory and Intermediary Services (FAIS) Act 37 of 2002.
  • • The General Code of Conduct for Authorised Financial Services Providers, specifically Section 3A (Conflict of Interest Management).
  • • Treating Customers Fairly (TCF) principles and FSCA Conduct Standards.

3. Key Definitions

  • • Conflict of Interest: Any situation in which a personal, financial, or other interest may influence—or appear to influence—the objective performance of duties or the fair treatment of clients.
  • • Financial Interest: Includes cash, gifts, rewards, fees, commissions, or any other consideration of value.

4. Policy Statement

The Company is committed to conducting business with integrity, independence, and transparency. All employees and representatives must avoid situations where their personal interests’ conflict with those of the Company or its clients. In all instances, the interests of our clients take precedence over any personal or third-party interests.

5. Management and Mitigation

To maintain a culture of trust and regulatory compliance, the Company employs several measures:

  • • Identification: All actual or potential conflicts must be declared in writing to the Compliance Department as soon as they arise.
  • • Avoidance and Mitigation: Where possible, conflicts are avoided entirely. If avoidance is not possible, we mitigate risks through the segregation of duties, independent reviews, and recusal from decision-making processes.
  • • Disclosure: All material conflicts are clearly disclosed to affected parties and clients in plain, understandable language.

6. Gifts, Hospitality, and Benefits

We maintain a strict stance on inducements. Gifts or hospitality must be reasonable, modest, and infrequent. No benefit may be accepted that could influence—or be perceived to influence—objective decision-making. All such items are recorded in a central Conflict of Interest and Gifts Register.

7. Governance and Training

Our Compliance Officer maintains a central register to track and resolve conflicts. Furthermore, all staff members undergo regular training to ensure they understand and embody these ethical standards. Failure to comply with this policy may result in disciplinary action or regulatory reporting .

8. Contact Information

For further information regarding our Conflict of Interest Management Policy, please contact our Compliance Department.

  • • Physical Address: First Floor, Fussel House, 48 Athol Oaklands, Melrose Arch, Gauteng 2076.
  • • Company Registration: 2024/186243/07.
  • • FSP Number: 54971.