1. Introduction

The overriding principle central to Geddes Capital’s culture and ethos is that clients come first. Geddes Capital is committed to the fair treatment of all clients, irrespective of size or vehicle through which they access our products and services. Geddes Capital recognises that client satisfaction is the foundation on which to build a Business which is sustainable over the long term. Delivering optimal customer outcomes is an enterprise-wide responsibility and requires participation from all parts of the business. Apart from any legislative or regulatory obligations, treating customers fairly is a business imperative. Without clients we have no business.

2. Client Charter and Values

Our client centric business model is reflected in our “Client Charter” and “Values”:

Client Charter:

We strive to always put the interests of clients first;

We have an unwavering commitment to the building of long–term sustainable client relationships;

We focus on producing investment performance over meaningful periods that meets our clients’ investment objectives and expectations;

We are uncompromising about applying ethics and good governance across all areas of our business.

Values:

Ownership

Always put clients first

Long-term thinking

Team-based organisation

Always act with integrity

Strong performance culture

Our Client Charter and Values, established since the start of our business are key drivers of our strategy as well as our day-to-day dealings with clients.

3.  Treating Customers Fairly: The Financial Services Conduct Authority (FSCA)

The FSCA published its “Treating Customers Fairly (“TCF”) Roadmap” in March 2011 as a first step towards achieving TCF fairness outcomes and culture framework requirements. In particular, the FSBCA requires firms to measure their activities against six TCF fairness outcomes (the “Outcomes”) that aim to reduce market conduct risks and protect consumers of financial products:

Outcome 1 (“Culture”): customers are confident that they are dealing with a financial services provider where the fair treatment of customers is central to its culture;

Outcome 2 (“Products and Services”): products and services marketed and sold in the retail market are designed to meet the needs of identified customer groups and are targeted accordingly;

Outcome 3 (“Clear and Appropriate Information”): customers are given clear information and are kept appropriately informed before, during and after the time of contracting;

Outcome 4 (“Customer Advice”): where customers receive advice, the advice is suitable and takes account of their circumstances;

Outcome 5 (“Product Performance Expectations”): customers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect;

Outcome 6 (“Post Sale Barriers”): customers do not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint.

Geddes Capital fully supports the FSCA’s TCF Outcomes, to the extent relevant to our business and our role in the investment product value chain. Most of the principles that support the Outcomes are expressed in our Client Charter and Values, referenced above.

We have a process in place whereby we periodically evaluate ourselves against the Outcomes and we always strive to improve the manner in which we live and/or evidence our adherence to the TCF principles. The TCF principles are a business imperative, embedded in our strategy, governance and daily processes, as more fully described below:

Clients

Service excellence: consistent with our Client Charter and Values, which encapsulates the culture that guides our behaviour, putting clients’ needs at the forefront of what we do is a key priority.

Engagement with our institutional clients takes place on an ongoing basis through frequent interaction at client meetings, investment report-backs and operational due diligences, as well as via the monthly and quarterly reporting process. Dedicated client relationship managers and fund managers ensure that client requests for information are attended to timeously.

Within the retail business, a team of client service professionals respond to all client queries in accordance with strictly monitored turnaround times. We aim to provide excellent levels of service to all our clients, measured through ongoing client experience surveys with our direct retail investors and annual qualitative research within the independent financial advisor market. The key principles of our retail client service philosophy are accessibility, accuracy and simplicity. We have therefore set demanding client service benchmarks to ensure that our client service team remains focused on delivering on these principles.

Client Data: Geddes Capital recognises that technology, although playing a vital role in enabling channels of business, also presents a risk of exposing confidential client and company data. Geddes Capital is dedicated to the protection of clients’ personal information, and therefore ensures that business processes are protected by appropriate governance and controls. Geddes Capital uses external providers to assess its customer security framework to ensure that appropriate information security considerations, process architecture frameworks and standards are properly identified, managed, understood and embedded throughout all transactional interactions with clients.

Product Information and Communication: Geddes Capital assesses, in aggregate, not in isolation, the cumulative impact of all client communications, for consistency of messaging and its impact on clients. To ensure consistency of messaging, all formal communication to clients goes through a rigorous review and sign-off process.

Clients receive regular communication covering a range of topics. We host comprehensive meetings and presentations throughout the course of the year and conduct focused research at multiple customer touch points.

Post-sale barriers: Geddes Capital is committed to ensuring the clients do not face unreasonable post-sale barriers to changing products, switching providers or making complaints. Geddes Capital does not impose any exit penalties, surrender fee or other charges to discourage clients to withdraw from products, where the aim is to balance the interests of short-term liquidity seeking and long-term investors. All product related features are disclosed during the purchase process. The only access constraints applied are those required by law.

Client criticism, both positive and negative, is a crucial feedback mechanism in prioritising our focus and resources. Geddes Capital has a formal “Complaints Procedures: Guidelines for Clients” that is available to clients on our website. Geddes Capital is committed to handling client complaints in a timely and fair manner and has implemented systems and procedures to satisfy this commitment (see the Complaints Policy for more detail). Geddes Capital provides a number of avenues for clients to provide feedback and/or log a complaint, namely: walk-in facility; email; post, and/or through their relationship consultant (if applicable). Geddes Capital also conducts surveys at the point of client interaction to assess the quality of the interaction and an annual “Financial Advisor Survey” to analyse longitudinal trends with respect to service levels, product performance and opinion. Clients are kept updated throughout any complaints process to ensure that their expectations are managed throughout.

Other example of where the TCF principles evidenced in our approach to daily business:

Geddes Capital has a consistent fee methodology that is reviewed across all product vehicles and mandate spectrums.

Governance

Geddes Capital maintains a robust corporate governance framework, effected through a unitary board, various subcommittees, management forums, the appointment of an independent Compliance officer and other independent assurance providers. The regulatory environment continues to evolve, both in South Africa and internationally. We are proactive in shaping a safer financial sector as contemplated in National Treasury’s “A safer financial sector to serve South Africa better, and direct engagement with our regulators.

Geddes Capital continues to place a high priority on ensuring it complies with all regulatory and statutory obligations, as well as industry best practice. The principles supporting the TCF Outcomes are at the centre of the board’s decision-making processes.

Staff

At the heart of the Geddes Capital DNA are our people.

Staff enjoy an open-door policy, providing for ongoing dialogue with management on any aspect of the business.

Staff compensation is directly linked to the strength, performance and service delivery to clients. Variable compensation is utilised to reward staff for their contribution towards the success of the company, including acknowledgment of exceptional performance. We rate and reward our people on their ability to add value to our clients and the business.

Regulators and Industry Bodies

We undertake to always engage in an open and transparent manner with our regulators. We engage with the following regulatory bodies in the various jurisdictions in which we operate:

Financial Services Board (South Africa)/ (FSCA)

Through our membership of industry bodies, we are able to lobby our views on proposed legislation and potentially influence legislation, with the aim of ensuring that the interests of investors and the industry are taken into consideration.

Shareholders

All key focus areas of our business combine in the execution of our strategy to create shareholder value. The sustainability of our business lies in our ability to produce consistent superior long-term investment performance, provide client service excellence, ensure client retention and the integrity of our business.

Developments

The TCF framework designed by the FSCA is a set of principles/norms that will find their way into law via existing legislation, regulation and guidelines. There are many examples of the TCF Outcomes already incorporated into the existing regulatory framework, however the FSCA is considering a “Conduct of Business Act” with specific “Codes of Conduct” to give further legislative effect to their stated goals.

On the basis that regulation around TCF is yet to be fully defined, this Policy will be subject to routine review as the regulatory environment becomes clearer.

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