Legal & Compliance
Should there ever be an occasion where you feel that you are dissatisfied with the advice or service given, MRA will do everything possible to ensure that your complaint is dealt with in a fair, timely and efficient manner.
How to complain:
All complaints must be lodged in writing (with copies of relevant documentation attached) and delivered by hand, fax or email and must be addressed to the Complaints Department. Complaints must be e-mailed to email@example.com.
Within 48 hours we will acknowledge receipt of the complaint in writing.
We will further provide the contact detail of the person responsible for resolving the complaint. This will allow you to request an update of your complaint at any point in time.
All efforts will be made to resolve the complaint within 6 weeks of receipt of the written complaint.
If MRA is unable to resolve the complaint to your satisfaction, we will provide written reasons and advise you of your right to refer the complaint to the Office of the FAIS Ombud.
You have 6 months from receipt of the final notification of the unfavourable outcome to refer the complaint to the Ombud.
All documentation relating to your complaint will be kept for 5 years as required by legislation.
If the complaint is resolved to your satisfaction, MRA will ensure appropriate redress without any delay.
Contact detail to submit claims:
MRA Insurance Brokers (Pty) Ltd
PO Box 3544
1200Tel: 086 111 6642
Fax: 086 111 6642
The FAIS Ombud
PO Box 74571
0081Tel: 0860 324 766
Fax: 012 348 3447
- Statutory definitions of COI
“Conflict of interest” means any situation in which a provider or a representative has an actual or potential interest that may, in rendering a financial service to a client, –
influence the objective performance of his, her or its obligations to that client; or
prevent a provider or representative from rendering an unbiased and fair financial service to that client, or from acting in the best interests of that client,
Including, but not limited to –
a financial interest;
an ownership interest;
any relationship with a third party;
“financial interest” means any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, other incentive or valuable consideration, other than –
an ownership interest;
training, that is not exclusively available to a selected group of providers or representatives, on –
products and legal matters relating to those products;
general financial and industry information;
specialised technological systems of a third party necessary for the rendering of a financial service; but excluding travel and accommodation associated with that training;
“immaterial financial interest” means any financial interest with a determinable monetary value, the aggregate of which does not exceed R 1 000 in any calendar year from the same third party;
“third party” means a product supplier, another provider, an associate of a product supplier or a provider, a distribution channel and any other person who in terms of an agreement provides a financial interest to a provider or its representatives.
- Policy statement
MRA Insurance Brokers (Pty) Ltd is committed to complying with the regulatory requirements governing Conflict of Interest under the FAIS General Code of Conduct and ensuring that conflicts of interest are appropriately managed in the best interests of all stakeholders.
- The management of COI
3.1. Mechanisms for the identification of COI
Before new business arrangements are concluded, we shall consider whether the proposed arrangement will present any potential conflict of interest. Key Individuals will be accountable to ensure that the necessary reviews of all existing business arrangements are conducted at least annually to assess the ongoing conflict of interest in the light of changing circumstances, operational processes and procedures that may have been implemented since the commencement of the business.
3.2. Measures for the avoidance and mitigation of identified COI
Whenever any potential conflict of interest is identified, the representative responsible for the relationship will consider whether any practical means exist for avoiding such conflict of interest. Where this is not practical, the Key Individual will consult with the Compliance Officer to devise appropriate and adequate measures to mitigate and manage the identified conflict of interest.
The resulting mitigating and managing measures will be documented and communicated to all staff involved in managing the relationship to ensure that the risk of the identified conflict of interest is appropriately managed.
3.3. Measures for the disclosure of COI
Wherever potential conflict of interest is identified, MRA will ensure that appropriate communication regarding the conflict of interest is included in the disclosure information and documentation provided to clients.
3.4. Processes, procedures, training and internal controls to facilitate compliance
Key Individuals will be required to ensure that the policy is implemented.
Training for all affected staff will be provided annually by the Compliance Officer to ensure that the staff understands their responsibilities under this policy.
The Key Individual will review this policy annually to ensure that it remains relevant and appropriate to meet the statutory requirements.
- Financial interests offered to representatives
MRA may offer its representatives sales incentives, in addition to their basic salary, based upon a combination of:
The quantity of business introduced, and
The quality of the service rendered to customers
No sales incentives may be offered to representatives for preferring one product over another that may be offered to a customer.
- Binders Agreements
MRA Insurance Brokers (Pty) Ltd has entered into a binder agreement with Insurers to offer clients an intermediary service in return for commission and or fees. By holding a binder agreement with the Insures, MRA acts as an agent of the Insurer and may perform inter alia one or more of the following functions:
Entering into, varying or renewing policies on behalf of the Insurer.
Determining policy wordings
Determining policy benefits (eg. no claim bonuses)
Settling claims (only Insurer can repudiate a claim)
MRA may earn fees for such services which are commensurate with the binder-holder costs. For such intermediary services, MRA may receive binder holder fees, a policy fee and outsourcing fees. It needs to be noted that MRA does not partake in any profit sharing agreements nor do we receive a percentage of savings on claim settlements.
MRA have identified this as a conflict of interest and as such it is not possible to avoid such conflict. The reason for the conflict of interest is as follow:
It is the only efficient way that MRA can actively manage its clients risk on an on-going basis given:
The number of clients
The geographical spread of the clients
It is the only way of formally ensuring that clients have the benefit of greater transparency in the manner in which their insurance policies are managed.
The only way to have access to a specialized, dedicated insurance advisor’s expertise and experience on an on-going cost effective basis.
The only way to effectively implement the predetermined short term insurance risk process without the administration constraints of Insurers
- List of MRA Insurance Brokers (Pty) Ltd Associates
Hollard Insurance Company Ltd (Reg No 1952/003004/06) – Binders Agreement
Mutual & Federal Insurance Company Ltd (Reg No 1970/006619/06) – Outsourced Agreement
Zurich Insurance Company South Africa Ltd (Reg No 1965/006764/06) – Outsourced Agreement
ETANA Insurance Company Ltd (Reg No 2001/009647/06) – Outsourced Agreement
Hospitality Industrial & Commercial Underwriting Managers (Pty) Ltd (Reg No 1998/032655/07) – Outsourced Agreement
- Third parties in which MRA Insurance Brokers (Pty) Ltd holds an ownership interest
- Third parties who hold an ownership interest in MRA Insurance Brokers (Pty) Ltd
Mpumalanga Risk Acceptances (Pty) Ltd – 100% shareholding
- Consequence of non-compliance with this policy
Failure to comply with the provisions of this policy by any staff member or FAIS representative shall constitute serious misconduct and will result in disciplinary action being initiated against such staff member or representative.
Our Compliance Officer, Crux Compliance (Pty) Ltd (CO3485), will monitor the management of the Conflict of Interest Policy and training register on an annual basis.
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