1. Introduction and Purpose

Qalo Ya Afrika (Pty) Ltd ("Qalo," "we," "our," or "the Platform") is committed to acting with integrity, fairness, and transparency in all our operations. As an authorised Financial Services Provider (FSP 53364) operating a facilitation platform, we recognise that certain situations may give rise to actual or potential conflicts of interest between Qalo, our employees, our shareholders, and our clients (Cooperatives, their Members, and listed SMEs).

The purpose of this Policy is to:

• Identify circumstances that may give rise to a conflict of interest.
• Establish procedures to manage and mitigate such conflicts.
• Ensure that all Platform activities are conducted in a manner that prioritises the fair treatment of all users and maintains the integrity of the facilitation process.
• Comply with the Financial Advisory and Intermediary Services Act (FAIS) and its General Code of Conduct.

2. Definition of a Conflict of Interest

A conflict of interest arises when Qalo or any person associated with Qalo has an interest, relationship, or incentive that may:

• Compromise our ability to act impartially and fairly in the execution of our services as a facilitator.
• Influence, or be perceived to influence, our objective facilitation between Cooperatives and SMEs.
• Result in a material advantage or detriment to any party using the Platform.

3. Identification of Potential Conflicts

Based on our business model, the following are key areas where potential conflicts may arise:

• Fee Structure: Our revenue is derived from fees paid by both Cooperatives (member fees) and SMEs (capital raise fees). There is a potential incentive to favour the interests of one party over another to secure or increase fee income.
• Platform Curation & Visibility: The ability to feature, order, or promote certain SME listings on the Platform could be perceived as an endorsement or could influence Cooperative engagement.
• Access to Information: Qalo has access to non-public information from both Cooperatives and SMEs.
• Related Parties: Directors, employees, or close family members having a financial interest in listed SMEs or Cooperatives.
• Inducements: Gifts, hospital