Version: 1.0
Effective Date: January 2026
Approved By: Managing Member
Applies To: All key individuals, representatives, employees, and service providers of Impande
Funeral Benefits

1. Introduction
Impande Funeral Benefits (“IFB”) is committed to full compliance with the Financial Advisory and
Intermediary Services Act (FAIS), the General Code of Conduct, and all directives issued by the
Financial Sector Conduct Authority (FSCA).
The purpose of this FAIS Policy is to ensure that IFB:
• Provides financial services honestly, fairly, with due skill and diligence
• Protects the interests of clients at all times
• Ensures representatives meet competency, fit-and-proper, and ethical standards
• Maintains accurate records and compliance structures
• Prevents conflicts of interest, misrepresentation, and poor advice
Compliance with the FAIS Act is compulsory and central to IFB’s operating model.

2. Purpose of the Policy
This FAIS Policy is designed to:
• Establish procedures for ensuring FAIS compliance across the business
• Provide clear guidance to representatives and key individuals
• Protect customers and promote ethical financial services
• Ensure consistent application of FSCA regulations
• Prevent regulatory risk, reputational damage, and consumer harm

3. Scope
This policy applies to:
• All Key Individuals
• All Representatives
• All administrative and operational staff involved in financial services
• All outsourced service providers performing functions subject to FAIS
• All products and services offered by Impande Funeral Benefits

4. Regulatory Framework
Impande Funeral Benefits complies with:
• FAIS Act (Act 37 of 2002)
• FAIS General Code of Conduct
• Fit and Proper Requirements (Board Notice 194 of 2017)
• FSCA Conduct Standards
• POPIA (for client data protection)
• TCF (Treating Customers Fairly) outcomes
• Financial Intelligence Centre Act (where applicable)

5. Roles and Responsibilities
5.1 Key Individual (KI)
The Key Individual is responsible for:
• Overseeing FAIS compliance
• Ensuring representatives are competent and supervised
• Monitoring advice and intermediary processes
• Approving operational policies affecting customer outcomes
• Reporting material irregularities to the FSCA

5.2 Representatives
Representatives must:
• Act with honesty, fairness, due skill, care, and diligence
• Provide accurate, balanced, suitable information to clients
• Meet fit-and-proper requirements (competency, experience, ethics)
• Follow the Impande sales and advice process
• Disclose conflicts of interest
• Avoid misrepresentation or pressure selling
• Maintain records of advice and disclosures

5.3 Compliance Officer (Internal or Appointed)
If applicable, must:
• Monitor adherence to FAIS and relevant subordinate legislation
• Conduct periodic compliance audits
• Provide reports to the Key Individual
• Identify and escalate non-compliance risks

6. Fit and Proper Requirements
Impande ensures that all representatives meet FSCA’s fit and proper criteria:
6.1 Honesty and Integrity
• No criminal record for fraud or dishonesty
• No misconduct findings by regulatory bodies
• Signed declarations filed
6.2 Competence
• Adequate product training
• Ongoing competency training and assessments
• Continuous Professional Development (CPD) compliance
6.3 Operational Ability
• Adherence to company’s systems and processes
• Ability to handle customer information responsibly
6.4 Financial Soundness
• Representatives may not be insolvent or under debt review
• Any financial impairment must be reported immediately

7. Advice and Intermediary Services
Impande ensures the following principles govern all advisory interactions:
7.1 Needs Analysis
Representatives must conduct a proper analysis to ensure product suitability, including:
• Affordability assessment
• Family needs assessment
• Understanding of member’s obligations
7.2 Clear Disclosure
Clients must receive:
• Premiums and cost structure
• Benefits and waiting periods
• Exclusions and limitations
• Claims processes
• Cancellation terms
• Conflict of interest disclosures
7.3 Record of Advice (ROA)
Every interaction where advice is given must include:
• Customer needs analysis summary
• Product recommendation
• Disclosure confirmation
• Signature or electronic acceptance
7.4 No Misrepresentations
Representatives are prohibited from:
• Exaggerating benefits
• Making false or misleading statements
• Claiming additional services that do not exist

8. Conflict of Interest Management
Impande adopts a zero-tolerance approach to conflicts that may harm clients.
We ensure:
• Full disclosure of any potential conflict
• Prohibition of inappropriate incentives
• Monitoring of all remuneration structures
• No representative may receive undisclosed commissions
A separate Conflict of Interest Policy supports this section.

9. Complaints Management
IFB follows FSCA complaint-handling rules:
• All complaints must be logged, acknowledged, and resolved
• Complaints must be handled fairly, transparently, and promptly
• Serious complaints must be escalated to the Key Individual
• Customers must be informed of their rights to escalate to the Ombud for Financial Services
Providers
Contact for FAIS Ombud:
Email: info@faisombud.co.za
Tel: 012 762 5000

10. Marketing, Advertising & Promotions
All marketing activities must:
• Be accurate, factual, and not misleading
• Clearly state benefits and limitations
• Avoid creating unrealistic expectations
• Be approved internally before publication
No representative may distribute unapproved marketing materials.

11. Records Management
Impande maintains records of:
• Applications
• Advice and disclosures
• Claims
• Complaints
• Training and competency documentation
Retention period: minimum of five (5) years, unless legislation requires longer.
Records must be:
• Accurate
• Accessible
• Stored securely
• Protected under POPIA

12. Supervision of Representatives
Representatives under supervision must:
• Work under direct oversight of an experienced supervisor
• Receive structured training
• Be evaluated regularly on performance and competency
Supervision periods follow FSCA rules and internal requirements.

13. Remuneration and Commission
Impande ensures remuneration:
• Complies with allowable commissions under insurance and FAIS regulations
• Is structured to avoid conflicts
• Does not incentivise mis-selling
• Is transparent to clients where applicable

14. Regulatory Reporting
The Key Individual ensures:
• Compliance reports are prepared when required
• Regulatory requests from FSCA are answered promptly
• Any material non-compliance is reported without delay

15. POPIA and Confidentiality
All personal information must be processed according to:
• POPIA
• IFB’s Privacy Policy
• Internal data security procedures
Representatives must:
• Keep client data confidential
• Not store personal information outside approved systems
• Report any data breach immediately

16. Treating Customers Fairly (TCF) Integration
IFB aligns FAIS processes with TCF outcomes:
• Clear and transparent information
• Fair product design
• No unfair barriers to claims
• Prompt payouts
• Ethical sales and advice
• Fair complaint handling
TCF is monitored as part of FAIS compliance.

17. Disciplinary Action for Non-Compliance
Failure to comply with this FAIS Policy may result in:
• Retraining
• Written warnings
• Removal from representation
• Dismissal
• Reporting to the FSCA

18. Policy Review
This policy is reviewed annually or earlier if:
• Legislation changes
• FSCA directives require amendments
• Operational changes affect FAIS compliance

19. Approval
This FAIS Compliance Policy is approved by the Managing Member