Conflict of Interest Policy

This document summarises Investec’s conflict of interests policy. This policy sets out the mechanisms in place at Investec to identify, mitigate and manage the conflict of interests to which Investec is a party.

Investec is committed to ensuring that all business is conducted in accordance with good business practice. To this end Investec conducts business in an ethical and equitable manner and in a way that safeguards the interests of all stakeholders to minimise and manage all real or potential conflict of interests.

As an international, specialist banking group that provides a diverse range of financial products and services to a select client base, conflicts of interest are inherent to the Investec business. This inherence of conflicts is apparent given the nature of Investec’s business, and that it simultaneously conducts the activities of investment research and advice, proprietary trading, portfolio management and corporate finance business (including advising on mergers and acquisitions and underwriting and selling an offering of securities).

To adequately manage conflict of interests Investec must identify all relevant conflicts timeously. Investec employs two different mechanisms to ensure that all conflicts are identified: 

• Group Compliance maintains a Matrix Index of potential conflict risks at Investec, taking into consideration all business areas and income streams. The Index is a matrix of conflicts classified by conflict type, business area and conflicting business area with documented controls. The index is updated with all new conflicts identified, and to ensure completeness is reviewed on an annual basis;   
• All employees, including compliance officers and management, are responsible for identifying specific instances of conflict and are required to notify their business unit compliance officer (or Group Compliance) of any conflicts they become aware of. Business unit compliance officers will escalate the conflict to Group Compliance to assess the implications of the conflict and how the conflict should be managed.

Once a conflict of interest has been identified it needs to be appropriately and adequately managed.

Group Compliance assess each conflict, including whether the conflict is actual or perceived, what the value of the conflict or exposure is and the potential reputational risk. Compliance and management then agree on the controls that need to be put in place to manage the conflict. Investec has various internal controls to manage and mitigate Conflicts of Interests, including: 

• Group business practices - Confidentiality and Representation within the Group   
• Information barriers - Restrictive access control to certain areas; separate IT systems and IT folders, IT access control policy and “Clean Desk” policy    
• Disclosure - Clear and concise disclosure to enable the recipient to fully understand its relevance.

Specific instances of conflict may require management intervention in addition to the documented controls already in place. These can include escalation to a management forum, like the Executive Risk Review Forum (ERRF) Executive Risk Committee (“ERC”) and/or other relevant forums, for a decision on how the conflict should be managed, for example, disclose to the client or decline to act.

Investec additionally has various internal policies to manage and mitigate Conflicts of Interests, including: 

• Wall Crossing Policy;
• PA Dealing Policy;
• Gifts and Entertainment (G&E) Policy;
• OBI and EP Policy; and
• Investec Limited and Investec plc Board Conflict of Interests Policy.

Compliance maintains records of all conflicts of interests identified and their resolution, including the persons involved and the controls used. This information is included in reports to management.

Further information on our Conflict of Interest Policy can be provided upon request. Alternatively, please address any questions to your usual Investec contact.