CK 1987/026261/23

Conflict of Interest Register
All employees of Sansure cc must declare any situation that they think might constitute an actual, perceived or potential conflict of interest in a Conflict of Interest Register. The register includes details of the staff member or ISP concerned, details of the matter under consideration and the decision regarding how best to manage the disclosed conflict.
Processes, procedures and internal controls to facilitate compliance with the policy are being audited by the Branch Manager.

 

Consequences of breaching this Policy

Non-compliance with this policy may negatively impact  Sansure's credibility and may expose Sansure to large penalties and/or legal claims by third parties. If a staff member breaches this policy, he or she may face disciplinary action. In extreme cases, the employee may also be found guilty of fraud, which may have both criminal and civil repercussions. The Conflict of Interest Management Policy forms part of the Sansure personnel Contract Addendum.

 

Financial Interest - Specific Areas
While it is impossible to describe every circumstance that may or may not gives rise to a conflict of interest, the following examples will serve as a guide to certain types of activity that will generally not give rise to a conflict of interest: Hospitality e.g. meals; Sporting events e.g. golf days; Marketing and advertising, provided a fair value for the service, as would have been charged elsewhere. Personal gifts of nominal value at special occasions e.g. at birthdays or anniversaries is allowed provided that the cost of such gift is included in the calculation of "immaterial financial interest". 

Sansure's Associates
The list is available and can be emailed on request.

Third Party Interests
Sansure cc holds no ownership interest in any Third Party.  No Third Party holds an ownership interest in Sansure cc.

Revision and Reporting
This Policy is reviewed on a regular basis and any changes are forwarded to all relevant persons. 

This policy was compiled on 5 July 2010.
1 st  Revision on 1 April 2012

2 nd Revision on 1 November 2015
3 rd Revision on  23 June 2017

4 th Revision on 01 March 2021