Terms and Conditions

Prudential Portfolio Managers Unit Trusts Ltd (Registration number: 1999/0524/06) is an approved CISCA management company (#29). Assets are managed by Prudential Investment Managers (South Africa) (Pty) Ltd, which is an approved discretionary Financial Services  provider (#45199).

Online Terms and Conditions

Online Terms and Conditions are valid and effective as of 30 September 2013.

PPMSA (Pty) Ltd. is part of the same corporate group as the Prudential Assurance Company. The Prudential Assurance Company is a direct subsidiary of M&G plc, a company incorporated in the United Kingdom. The Prudential Assurance Company is not affiliated in any manner with Prudential Financial, Inc., a company whose principal place of business is in the United States of America or Prudential plc, an international group incorporated in the United Kingdom.

You can contact us at query@prudential.co.za or download the Online Terms and Conditions document for South African Investors and the Namibian Online Terms and Conditions for Namibian Investors.

Community Guidelines

Our social media community is a place to engage and interact with us and other members of our community. We ask that conversations follow the rules and that participants treat each other with respect. Please keep in mind that Prudential does not create, control, represent or endorse any opinions or statements expressed by others within its social media channel, including those that Follow/Like Prudential Investment Managers and that any content posted by anyone other than Prudential is the responsibility of the submitter and not Prudential. With this in mind, we ask that you follow our community guidelines:

Please don’t give out any personal information on our wall: If you post a question, we will do our best to respond as soon as possible, but avoid sharing any confidential information like phone numbers, email addresses or account details that might compromise your security.

Keep it clean: We will not tolerate any inappropriate, defamatory or offensive language or images, including user names, profiles, photographs, videos and wall posts that are crude, contain swear words, are racist, offensive, discriminatory, hateful, violent or promote violence. We reserve the right to un-tag Prudential and delete any posts or photos that we deem, in our sole discretion, inappropriate.

Do not post any spam: Advertising, spam, selling and links or comments that promote or oppose a non-Prudential product, service, organisation or individual will be removed immediately. This includes posts used to direct traffic to other sites, blogs or Facebook/ LinkedIn/ Twitter pages.

Let’s stay on topic: Please keep comments on-topic. Our wall is designed to keep you up to date on investing trends, useful tips, analyses and news pertaining to Prudential. Posts that are off-topic, unrelated, constitute gossip or personal disparagements/attacks will be removed.

Repeat or serious offenders: Please note that repeat or serious offenders may be reported to Facebook/ LinkedIn/ Twitter and blocked from our page for the sake of the community.

Copyright and Intellectual Property Policies: By submitting any content to our Facebook/ LinkedIn/ Twitter pages, you warrant and represent that you are the copyright owner of the content or that the copyright owner of the content has granted you permission to use such content consistent with the manner and purpose of your use. Please note that by posting comments, posts, tagged photos, videos, ideas, or any other content on our Facebook/ LinkedIn/ Twitter pages, you are granting Prudential nonexclusive, worldwide rights to republish, redistribute, or otherwise use this content in perpetuity in any way we see fit. This includes, but is not limited to, marketing and advertising materials. The content produced and posted by Prudential remains the sole property of Prudential Investment Managers and any repurposing of such content may only be done with prior written consent from Prudential Investment Managers. Enquiries may be sent to media@prudential.co.za

Our promise: We are monitoring our social media pages and will do our best to answer all queries posted to our Facebook/ LinkedIn/ Twitter walls in a timeous manner, usually weekdays from 09h00 to 17h00. If you post a query outside of the designated times, please be patient – we will assist you as soon as possible. For offline response, please contact our Customer Services team on 0860 105 775.

Privacy Policy and PAIA Manual

Set out below are details about the Prudential SA Privacy Policy (“Policy”) and PAIA Manual. The Policy applies to the collection, use, disclosure, and protection of personal information relating to clients of the Prudential group affiliates, and related entities; all vendors and suppliers of Prudential; and all users of this Website. The purpose of the PAIA Manual is to facilitate any requests for access to Prudential records in terms of the Promotion of Access to Information Act (PAIA). 

Furthermore, both the Policy and PAIA Manual form part of and should be read together with the product and online terms and conditions of this website.

You can contact us at query@prudential.co.za or download the Privacy Policy and PAIA Manual documents.

Client Complaints Policy

Compliance Department

Prudential Investment Managers Compliance Officer is Kerry Horsley [CO number 5686].
Email: 
compliance@prudential.co.za Tel: 021 670 5100 Address: PO Box 44813 Claremont 773

Complaints

Prudential SA invites any client who is dissatisfied with the services provided to address their concerns directly with the Head of Institutional Business or with any one of our Executive Directors. We take our client concerns and queries very seriously and undertake to engage directly, timeously and meaningfully with you. In the event that you would prefer to pursue a formal route and wish to lodge a written complaint regarding Prudential Investment Managers compliance with the FAIS Act, the nature of services rendered or the fair treatment of you, such complaint should be addressed to The Compliance Officer.
Email: compliance@prudential.co.za Address: PO Box 44813 Claremont 7735

If we fail to revert to you within six weeks or if you are dissatisfied with our response, you’re entitled to address the issue with the FAIS Ombud.
Web: www.faisombud.co.za Tel: 012 470 9080 Address: PO Box 74571 Lynnwood Ridge 0040

Cookies Policy

Prudential may collect personal information through the use of “cookies” in order to provide you with a better client experience while online. A cookie is a piece of information that is stored on your computer by your web browser for record-keeping purposes. It allows us to securely collect data about your online behaviour to better understand your interests and to provide you with a personalised online experience.

When you visit our website we will allocate cookies for our services. These cookies will hold information collected during your usage of the website and allow us to recognise you when you revisit our website. We further make use of third party service providers who utilise cookies as a means to serve you Prudential advertising banners and other online communications. The information gathered by these third parties are based on your prior visits to our website and cannot be linked directly back to you.

Most browsers are set by default to automatically accept cookies, however your browser settings can usually be altered to either prevent automatic acceptance (and prompt you every time a cookie is sent to you) or to no longer receive cookies at all. While turning off cookies will not prohibit you from using our website, it may however limit the extent to which we can personalise your overall online experience.

Events

The event email is subject to the Prudential (SA) electronic communication legal notice, available here. The information contained in the communication from the sender is confidential, and should you wish to forward on to a friend, PIMSA will accept no responsibility for the information disclosed. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. Prudential regularly engages with clients and their representatives, either at our premises or external venues. We appreciate the opportunity to offer investment thought leadership at client conferences & events and enjoy occasional informal interactions. We consistently seek to be moderate and conservative regarding entertainment, offering modest refreshments but not sponsorship of ancillary costs. We have a zero tolerance for any form of corruption, untenable conflicts of interest or leveraging relationships in favour of profit.  We believe our engagements are in line with both the letter and spirit of regulations dealing with “gifts and benefits”. However the FAIS and Pension Funds Act directives are not fully consistent and we recognise that protocols can be interpreted differently. Should this invitation in any way conflict with your understanding of the regulations or breach any of your internal policies, do let us know so we can adjust our approach accordingly and accommodate you in future.

Prudential Investment Managers (South Africa) (Pty) Ltd and its affiliates often invite clients to events. For the purpose of the event, personal information is collected and processed by Prudential. By providing us with your personal information, you acknowledge and agree to the use of the information for the purpose of the event. Prudential will at all times handle the personal information with care and process it in accordance with the Protection of Personal Information Act, 2013. Further, you hereby consent to Prudential passing on such personal information in order to facilitate the allocation of continuous professional development (CPD) points and to our employees or agents who require such information as necessary or for legitimate business purposes.

Advertising and Email Disclaimers

Sources: Prudential Investment Managers, Bloomberg, M&G Investments.

Prudential Portfolio Managers Unit Trusts Ltd is an approved CISCA management company (#29). Collective Investment Schemes (unit trusts) are generally medium to long-term investments. The value of participatory interest (units) may go down as well as up. Past performance is not necessarily a guide to the future and the manager provides no capital or return guarantees. Unit trusts are traded at ruling prices. All of the unit trusts may be capped at any time in order for them to be managed in accordance with their mandates. A Unit trust fee schedule summary with all fees and maximum initial and ongoing adviser fees and additional information on our unit trusts is available on our website. This information is not intended to constitute the basis for any specific investment decision. Investors are advised to familiarise themselves with the unique risks pertaining to their investment choices and should seek the advice of a properly qualified financial consultant or adviser before investing.

PPMSA (Pty) Ltd. is part of the same corporate group as the Prudential Assurance Company. The Prudential Assurance Company is a direct subsidiary of M&G plc, a company incorporated in the United Kingdom. The Prudential Assurance Company is not affiliated in any manner with Prudential Financial, Inc., a company whose principal place of business is in the United States of America or Prudential plc, an international group incorporated in the United Kingdom.

Prudential Investment Managers (SA) (Pty) Ltd is a licensed financial services provider. This email is subject to the Prudential (SA) electronic communication legal notice, available here. If you are unable to access the disclaimer, send an email request to query@prudential.co.za and we will send you a copy of the disclaimer. The information contained in this communication from the sender is confidential, and should you wish to forward on to a friend, PIMSA will accept no responsibility for the information disclosed. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. Prudential regularly engages with clients and their representatives, either at our premises or external venues. We appreciate the opportunity to offer investment thought leadership at client conferences & events and enjoy occasional informal interactions. We consistently seek to be moderate and conservative regarding entertainment, offering modest refreshments but not sponsorship of ancillary costs. We have a zero tolerance for any form of corruption, untenable conflicts of interest or leveraging relationships in favour of profit. We believe our engagements are in line with both the letter and spirit of regulations dealing with “gifts and benefits”. However the FAIS and Pension Funds Act directives are not fully consistent and we recognise that protocols can be interpreted differently. Should this email in any way conflict with your understanding of the regulations or breach any of your internal policies, do let us know so we can adjust our approach accordingly and accommodate you in future. Click here (POPI | Events) to see how we safeguard your personal information.

CIS and Performance

Collective Investment Schemes (unit trusts) are generally medium-to long-term investments. Past performance is not necessarily a guide to future investment performance. Unit trust prices are calculated on a net asset value basis. This means the price is the total net market value of all assets of the unit trust fund divided by the total number of units of the fund. Any market movements – for example in share prices, bond prices, money market prices or currency fluctuations - relevant to the underlying assets of the fund may cause the value of the underlying assets to go up or down. As a result, the price of your units may go up or down. Unit trusts are traded at the ruling forward price of the day, meaning that transactions are processed during the day before you or the Manager know what the price at the end of the day will be. The price and therefore the number of units involved in the transaction are only known on the following day. The unit trust fund may borrow up to 10% of the fund value, and it may also lend any scrip (proof of ownership of an investment instrument) that it holds to earn additional income. A Prudential unit trust fund may consist of different fund classes that are subject to different fees and charges. Where applicable, the Manager will pay your financial adviser an agreed standard ongoing adviser fee, which is included in the overall costs of the fund. A Collective Investment Schemes (CIS) summary with all fees and maximum initial and ongoing adviser fees is available on our website. One can also obtain additional information on Prudential products on the Prudential website. The Fund may hold foreign securities including foreign CIS funds. As a result, the fund may face material risks. The volatility of the fund may be higher and the liquidity of the underlying securities may be restricted due to relative market sizes and market conditions. The fund’s ability to settle securities and to repatriate investment income, capital or the proceeds of sales of securities may be adversely affected for multiple reasons including market conditions, macro-economic and political circumstances. Further, the return on the security may be affected (positively or negatively) by the difference in tax regimes between the domestic and foreign tax jurisdictions. The availability of market information and information on any underlying sub-funds may be delayed. The Manager may, at its discretion, close your chosen unit trust fund to new investors and to additional investments by existing investors to make sure that it is managed in accordance with its mandate. It may also stop your existing debit order investment. The Manager makes no guarantees as to the capital invested in the fund or the returns of the fund. Excessive withdrawals from the fund may place the fund under liquidity pressure and, in certain circumstances; a process of ring fencing withdrawal instructions may be followed. Fund prices are published daily on the Prudential website. These are also available upon request. The performance is calculated for the portfolio. Individual investor performance may differ as a result of initial fees, the actual investment date, the date of reinvestment and dividend withholding tax. Purchase and repurchase requests must be received by the Manager by 13h30 (11h30 for the Money Market Fund) SA time each business day. All online purchase and repurchase transactions must be received by the Manager by 10h30 (for all Funds) SA time each business day.

Broker House: Terms and Conditions

DOWNLOAD PDF: BROKER HOUSE TERMS AND CONDITIONS

Once you have received confirmation that Manager has accepted your application and recognises you as a financial adviser, you will be able to market the Manager’s products listed in the financial adviser declaration of this agreement, subject to the terms and conditions of this agreement.

Advertising restrictions

Once the Manager recognises you as a financial adviser, you may only advertise its products or use the Manager’s brand after obtaining written approval from the Manager. You may only use the Manager’s marketing material for its intended purposes. Current information about the Manager can be obtained from www.prudential.co.za. The Manager is only responsible for the information relating to the Manager that it gives you, or that you obtain directly from its website. You will keep all agreements between you and the Manager that relate to the nature and frequency of the advertising and promotion of its products. You will follow all advertising and promotion guidelines that the Manager sets in writing. You will not use the Manager’s brand, logos or trademarks without the Manager’s written consent.

Representative limitations

This agreement does not mean you are an agent of Prudential or the Manager. You are solely your client’s agent to facilitate his/her investment in the Manager’s products. You have no authority to accept any client application on behalf of the Manager or to bind the Manager in any way in respect of any transaction. You will notify each of your clients of this clause. You will not at any time buy or sell or act as the agent, broker or any other type of representative to buy or sell units in the products, except in terms of this agreement. You will not claim to represent the Manager or make promises on behalf of the Manager, unless the Manager, specifically authorises you to do so. Any employee of yours who wants to place any new business with the Manager, will first apply to act as a financial adviser for the Manager, and only place new business once the application has been approved.

Only the financial advisers listed in the financial adviser declaration above, may market and sell the products of the Manager, and may only do so for the products listed in the declaration above. You indemnify the Manager, against all claims relating to losses suffered because of the actions and/or omissions of your representatives that are not listed above. 

Advisory indemnity

In the event that clients have appointed you or your representatives as their agent and or financial adviser, you hereby indemnify the Manager and Prudential SA against:

1. any loss or damage suffered by the Manager or Prudential SA; and

2. all direct or indirect claims (including claims for consequential damages) which may be made against the Manager or Prudential SA relating to any loss or damage suffered by any person, as a result of the advice given by you or your representatives or any instructions submitted by you or your representatives to the Manager on the client’s behalf.

Further, you confirm that:

3. You or your representatives have concluded a valid written legal mandate with the client wherein you or your representatives are appointed by the client as their Financial Adviser, which mandate remains in force.

4. You or your representatives are authorised in terms of the mandate concluded with with clients to submit instructions to the Manager for and on behalf of your clients, either via forms , in writing or via the Manager’s secure online platform.

5. You or your representatives acknowledge and agree that you will only act on your client’s instruction when submitting any instructions to the Manager (whether in writing or via the Manager’s secure online platform)

6. The Manager and Prudential SA will not be held liable for loss or  damage which may result from the Manager acting on any instructions submitted by you or your representatives for the client, and you hereby indemnify the Manager and Prudential SA against all direct or indirect claims (including claims for consequential damages) which may be made against the Manager or Prudential SA in this regard. This indemnity does not extend to claims in respect of loss or damage which results from any negligent or wilful errors or omissions committed by the Manager or Prudential SA.

7. In the event that you or your office or staff, are victims of a cybercrime (e.g. hacked, phished, pharmed, identity theft scams, malware, spoofed, keylogging, sniffing, invasion of privacy etc.) committed by a third party and an instruction is given to the Manager in your name or on behalf of your clients, whether or not authorised or known to by you, the Manager and Prudential SA will not be responsible for any loss or damage which may result from the Manager following such instruction and you hereby indemnify the Manager and Prudential SA against all direct or indirect claims (including claims for consequential damages) which may be made against the Manager in this regard. 

Your responsibilities during the application process

 In the case of a faxed investment instruction or product application, sent by you on behalf of your client, it is your responsibility to make sure that the Manager has received the instruction. A fax confirmation receipt or email read receipt will not be regarded as proof that a specific document was received by the Manager. You indemnify the Manager and Prudential SA against all claims relating to losses suffered because Prudential SA did not receive an application. 

You acknowledge that you have a thorough knowledge of and will at all times act according to all legislation that applies to financial advisers. You will provide the Manager, when signing this agreement, with proof of your registration or license, where legislation requires registration with or a license issued by the Financial Sector Conduct Authority or any other regulatory body.

You will make sure that the client has read and fully understood the application form, the terms and conditions of the investment, as well as any related marketing material, before he/she signs the application form. The Manager and Prudential SA will not accept any liability if you do not comply with this requirement.

Prudential SA has the relevant procedures in place to combat money laundering in any country in which it operates. To implement these procedures, you undertake full responsibility for the identification procedures necessary under all legislation, regulations, rules, industry guidelines, common law and case law in the Republic of South Africa relating to money laundering, and you will verify the authenticity of the client and his/her signature. The Manager reserves the right to refuse any product application at its discretion, without having to give a reason.

Your competence and accreditation

You declare that you are competent and accredited, as required by South African law and that of other jurisdictions, to give investment advice in respect of the product/s for which your clients will be applying.

Fee agreement

The Manager may, at its sole discretion, change the basis for adviser fees as applicable to its investment products from time to time. Other products may be introduced, in which case all fees applicable to the new products will be confirmed in writing and will be included as an amendment to this section of your agreement with the Manager.

Fee payments

The Manager will pay adviser fees to you on the basis agreed between you and your client and signed for in the relevant section of the applicable investment application form, once the application is accepted and the investment amount received. The Manager may reverse the adviser fee payment if an investment contract is cancelled after the date of investment and/or the Manager needs to refund the adviser fees paid to the investor.You will then be required to immediately refund to the Manager the adviser fees paid to you.

Initial and ongoing adviser fees will be paid monthly, in arrears, by means of electronic bank transfer into the bank account indicated by you on this application form. Adviser fees will only be paid once the amount concerned exceeds the minimum amount (determined by the Manager from time to time). Any amount less than the minimum amount will accrue towards the next calculation period. Payment will only be made on cleared investment amounts. The Manager will provide you with a statement when fees are payable to you. The accrual period for the unit trust business runs from the 26th to the 25th of the following month and may change from time to time. You will cease to be entitled to both initial and ongoing adviser fees in respect of any investment made by a client, should you no longer be the client’s appointed financial adviser.

You will not earn any adviser fees on a withdrawal or the switching of units between any of the products. In the case of a dispute relating to adviser fees, Prudential may at its sole discretion withhold payment until the dispute has been resolved.

VAT vendors

Financial advisers registered as VAT vendors are required to submit VAT registration certificates to the Manager as proof of registration. Your fee statements will show your registration number and payment amounts as specified below. Failure to provide the Manager with a VAT certificate will result in no VAT being paid nor will it be backdated. 

Termination of this agreement

The Manager reserves the right to terminate this agreement at its discretion on giving you 30 calendar days’ written notice. In addition, the Manager may terminate this agreement at its discretion with no notice if your registration, where legislation requires registration with the Financial Sector Conduct Authority or any other regulatory body, terminates for whatever reason. You will no longer be entitled to any adviser fees in respect of any investment placed by a client, whether by lump sum or debit order, affected at any time after the termination of this agreement with the Manager.

Address for business and legal purposes

You choose the physical address provided in this agreement as your address for delivery of documents and summons. We will assume that you received any document delivered to this address, without you signing for its receipt.

Protecting investor information

The Manager and Prudential SA may collect, verify, use, disclose or otherwise process your personal information for the purposes of providing the products and/or services which you have requested from the Manager and or Prudential SA. Your personal information may be collected directly from you, your agent, an authorised financial service provider, or where appropriate a regulator or state body. The Manager and Prudential SA may process your personal information for the purpose of administration, marketing, complying with legal and audit requirements, for record keeping purposes, to improve our service, products, and your experience. The Manager and or Prudential SA are required to process and keep investor and investor representative information to perform its obligations lawfully, fairly and competently. The Manager will only process your personal information for the purposes it was collected for, and any other legitimate purposes related to the original purpose. The Manager and or Prudential SA have controls and security measures in place to protect personal information from unauthorised use, for security and servicing purposes. The Manager and or Prudential SA may monitor, and record telephone calls and other instructions submitted by other means. We may share your personal information with our employees, agents, subcontractors, with our related entities, with your adviser and/or their duly appointed agent or service provider, where directed. Personal information may be transferred to offshore providers. In such instances the Manager and Prudential SA will ensure that sufficient legislation or agreements are in place for the information to remain adequately protected. You are entitled to request access to the information we have collected, processed and shared. All processing of personal information will be done in accordance with applicable laws and Prudential Group’s privacy policy, which can be obtained at www.prudential.co.za/prudential-online-privacy-policy.pdf.

Anti-bribery and corruption provision

1. As part of a global financial services group, the Manager and Prudential SA is committed to creating and delivering sustainable value for their investors and it conducts its business in an honest, ethical and professional manner and adheres to the highest standards of corporate governance.

2. The Manager and Prudential SA has always adopted a zero tolerance towards all corrupt activities.

3. The Manager and Prudential SA forbids and does not support any individuals or organisations that participate in any acts of fraud, bribery,corruption or in the practice of making use of facilitation payments, where facilitation payments is defined as “payments” made as a way to get or speed up a legitimate service that is offered by a government agent. Facilitation payments do not include legitimate fees that are payable for that service and the fees are applicable to anyone receiving the same or similar service. Facilitation payments also do not include the payment of a “fast track” fee as long as the faster service is available to anyone paying a similar fee. Nor do they include the provision of resources to assist the government agent to more efficiently provide the services that are supplied”. These acts are illegal and have the ability to cause damage to the reputation of the M&G PLC Group.

4. For the avoidance of doubt, bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage. An advantage includes money, gifts, loans (or the forgiveness of a debt), fees, hospitality, services, discounts, employment opportunities, the award of a contract or anything else of value. A person acts improperly if they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. Corruption is the abuse of entrusted power or position for private gain. 

5. You warrant that you have not participated in any acts of fraud, bribery or corruption, and that you have not paid any facilitation payments to any government agents, and that you have taken reasonable steps to ensure that none of your employees or agents have done so. You further warrant that you have not breached any applicable anti-bribery and anti-corruption laws and regulations, and that you have taken reasonable steps to ensure that none of your employees or agents have done so.

8. Further to the above, you undertake to:

a) Comply with all applicable anti-bribery and anti-corruption laws and regulations;

b) Not offer any bribe or facilitation payment to any public official or other person;

c) Not offer, pay, agree to accept or accept any bribe or corrupt payment in respect of any activity related or attributable to the Manager or Prudential SA; and

d) Not do anything that may cause the Manager or Prudential SA to breach the applicable anti-bribery and anti-corruption laws and regulations.

9. For the avoidance of doubt, you undertake to refrain from offering or paying any bribes to any clients to entice them to invest in any of Prudential’s Products and you undertake to refrain from accepting (or agreeing to accept) any bribe from any employee or agent of the Manager or Prudential SA in order to inappropriately influence your advice and or decision in respect of the investment of funds on behalf of any clients.

10. Should you become aware of any breach of the warranties or undertakings detailed above, you undertake to notify the Manager and Prudential SA in writing as soon as reasonably practicable.

11. You agree that the Manager and Prudential SA shall be entitled to immediately terminate this agreement for any breach of the above provisions that relate to anti-bribery and corruption. To the extent that you, your owners and/or your directors or senior managerial persons, are the subject of credible adverse media reporting or criminal prosecution involving allegations of bribery, corruption, fraud and/ or any criminal offence that is based on dishonesty and/or regulatory infractions or enforcement actions and/or allegations of an objectively adverse nature, and if this negatively impacts on the reputation of the Manager or Prudential SA or is likely to impact negatively the reputation, you confirm and acknowledge that the Manager or Prudential SA may, without any liability whatsoever, terminate this agreement. The Manager and Prudential SA will undertake to provide you with a reasonable opportunity to respond to the credible adverse media reporting or criminal prosecution before the Manager and Prudential SA terminates this agreement. In this regard, the Manger and Prudential SA will notify you in writing requesting your written response within 48 hours. Thereafter, it will be within the Manager and Prudential SA’s discretion to immediately terminate.

Sanctioned and Prominent Persons

You consent that the Manager and Prudential SA may

1. process your personal information to conduct sanctions screening against all mandatory and non-mandatory sanctions lists, including but not limited to the sanctions list of the United Nations Security Council; the United States Office of Foreign Assets Control; the United Kingdom Her Majesty Treasury; the European Union and South Africa (“sanctions lists”) and/or politically exposed person screening and to monitor your instructions and transactions;

2. share your personal information with local and international Regulatory Bodies as well as other entities in the M&G PLC Group if you are matched to one of these sanctions lists, if we are required to do so in terms of laws, internal and external policies and procedures, rules and requirements relating to international sanctions, prohibited business activities and the detection and prevention of money laundering and the financing of terrorism (“financial crime regulation”) or if we decide to do for internal business purposes;

3. terminate this agreement, any transaction or instruction, and/or our business relationship with you with immediate effect and without warning if you are found to be on a sanctions list or if your use of our products or services contravenes any applicable financial crime regulation.

You agree that the Manager and Prudential SA is not responsible for any losses or damages (whether direct or consequential) that you may suffer because of the processing of your personal information for purposes relating to financial crime regulation; delays or non-execution by the Manager and Prudential SA or any other member of the M&G PLC Group of obligations undertaken under these terms and conditions or other obligations, attributable in whole or in part to activities which the Manager and Prudential SA or any company in the M&G PLC Group, at its unfettered discretion, considers appropriate for its compliance with financial crime regulation, or the termination of this agreement, any transaction or instruction, and/or our business relationship with you.

Conflict of interest disclosure

The Manager and Prudential SA does not engage in any proprietary trading, i.e. it does not buy and sell assets with its own money to make a profit for itself. It only invests investors’ money. However, Prudential SA will seed (provide the start-up investment money for) unit trust funds where the law requires it. All service providers, such as stock brokers, are selected based on investors’ best interests and commercial terms. The Manager and Prudential SA manages and monitors the risks of personal and business conflicts of interest. Controls include awareness, disclosures, approval processes and enforcement. The Manager and Prudential SA and its staff will not be part of any activity prohibited by the Prevention and Combating of Corrupt Activities Act. All tangible gifts, benefits or hospitality, given and received, are limited to specific amounts. Staff members receive a mix of guaranteed and variable pay (the latter driven by business profits). New business consultants receive commission driven by new business targets, as well as by how well they service and support existing investors. Investment staff members are further incentivised based on personal performance.

Investment performance bonuses align the interests of the investment professionals and clients. If investment performance is poor, investment professionals receive less pay. The Prudential Employee Equity Trust, of which all employees are beneficiaries, is an indirect shareholder of 28.01%in the Managers holding company, Prudential Portfolio Managers (SA) (Pty) Ltd. Staff may trade financial instruments for their own profit. Personal trading is monitored by Prudential SA’s Risk and Compliance. No staff member may trade for their personal account while Prudential SA’s clients are in the market. Staff may invest in the financial products managed by Prudential SA, e.g. unit trust funds.