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Zororo Phumulani
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TRANSPARENCY. ACCOUNTABILITY. CARE.

Legal and Compliance

Our policies explain how we work, how we protect your rights and how to raise a concern.

Zororo Phumulani Investments (Pty) Ltd maintains a compliance framework guided by the Financial Sector Conduct Authority (FSCA), the Financial Advisory and Intermediary Services Act (FAIS) and applicable regulatory requirements.

The framework supports lawful, ethical and transparent conduct across our products, services and client interactions. It defines the responsibilities of management, employees and compliance oversight in identifying and managing regulatory and conduct risks.

Policies, procedures and internal controls support compliance in day-to-day operations. Monitoring, training and regular review help maintain accountability, professional conduct and client trust.

01

PAIA Manual

Access to information and protection of personal information.

In compliance with the Promotion of Access to Information Act, 2 of 2000 (PAIA), as amended by the Protection of Personal Information Act (POPIA), Zororo Phumulani Investments (Pty) Ltd has compiled a PAIA Manual.

This manual explains:

What information our company holds.

How clients, stakeholders, or the public can request access to this information.

The process, applicable fees, and the rights of requesters under PAIA and POPIA.

We are committed to transparency, accountability, and the protection of personal information.

02

Complaints Policy

How complaints are received, reviewed and resolved.

In compliance with Section 17 of the General Code of Conduct for Authorised Financial Services Providers and Representatives, Zororo Phumulani Investments (Pty) Ltd has developed this Complaints Policy.

This policy outlines the company’s commitment to fair, transparent, and effective complaint resolution, ensuring clients are treated with dignity, respect, and fairness at all times. It explains how complaints are defined, managed, and escalated, and details the responsibilities of all parties involved in the complaints process.

The policy also establishes the internal framework for managing, categorising, and reviewing complaints, in alignment with regulatory standards and the principles of responsible decision-making.

Zororo Phumulani remains dedicated to maintaining client trust through accountability, impartiality, and continuous improvement of its complaints-handling processes.

03

Treating Customers Fairly

Fair treatment throughout the client journey.

In line with the Financial Sector Conduct Authority (FSCA) framework and the General Code of Conduct for Authorised Financial Services Providers, Zororo Phumulani Investments (Pty) Ltd has adopted this Treating Clients Fairly (TCF) Policy.

This policy outlines our organisation’s commitment to placing the fair treatment of clients at the heart of our culture and daily operations. It explains how we ensure that all products, services, and advice are designed, marketed, and delivered to meet client needs and expectations, in accordance with the six TCF outcomes.

It further details the responsibilities of management and staff, the role of the TCF Champion, and the processes implemented to monitor fairness throughout the client journey — from product design and sales to after-sales service and complaints handling.

Zororo Phumulani is dedicated to transparency, ethical conduct, and continuous improvement, ensuring that every client experience reflects fairness, integrity, and accountability.

04

Conflict of Interest Management

Identifying, managing and disclosing conflicts of interest.

In compliance with the General Code of Conduct for Authorised Financial Services Providers and Representatives, Zororo Phumulani Investments (Pty) Ltd has developed this Conflict of Interest Management Policy.

This policy outlines how the organisation identifies, avoids, mitigates, and discloses any actual or potential conflicts of interest that may arise in the course of providing financial services. It explains the internal controls, procedures, and responsibilities in place to ensure that all employees and representatives act with integrity, impartiality, and in the best interests of clients.

The policy also details how conflicts are monitored, recorded, and reported, including disclosure requirements, staff declarations, and compliance oversight. It reinforces that non-compliance will be treated as serious misconduct and subject to disciplinary action.

Zororo Phumulani remains committed to maintaining transparency, accountability, and ethical conduct in all business relationships, ensuring that client interests are always placed above personal or corporate gain.