Level 4 FAIS Conflict of Interest Policy Retail and … 4 FAIS Conflict of Interest Policy –...

Level 4 FAIS Conflict of Interest Policy – Retail and Business Banking

Next review date: March 2017

Document owner: Compliance and Governance – Retail and Business Banking

C:\Users\nb203003\Documents\FAIS Conflict of interest Web-NELS version- 20 July 2016.docx

Contents

1 Introduction and disclaimer

2 Objective of this policy

3 Scope of this policy

4 Definitions

5 Key principles

6 Roles and responsibilities

7 Exemption

8 Contravention of this policy

9 Effective date

10 Links to other group policies

11 Annexures


1 Introduction

In terms of the Financial Advisory and Intermediary Services (FAIS) Act, 37 of 2002, Nedbank Limited ('the bank') is an authorised financial services provider (FSP). The bank must ensure that its employees (FAIS

representatives) comply with the FAIS Code of Conduct as well as other applicable laws and regulations. This policy aims to highlight our obligations with respect to the conflict of interests provisions in the FAIS Code of Conduct. All employees in Retail and Business Banking ('the RBB') must therefore be acquainted with the FAIS

Code of Conduct, the contents of this policy and any other applicable laws and regulations. Disclaimer: This document is primarily based on the group's level 3 FAIS Conflict of Interest Policy (available on

the Nedbank web page), FAIS Code of Conduct and Board Notice 58 of 2010. This document does not replace the level 3 Conflict of Interest Policy and the FAIS Code of Conduct, but must be used and read in conjunction with them. 2 Objective of this policy

The main objective of this policy is to ensure that employees within the RBB cluster (FAIS-affected staffmembers) are aware of what constitutes a conflict of interest and, through this awareness, ensure that employees do not find themselves in situations where there may be clashes between own interest and that of the company or a client. 3 Purpose and scope of this policy

The purpose of this policy is to ensure that all FAIS-affected staffmembers within Nedbank RBB disclose to their clients the existence of an actual or a potential conflict of interest. This policy only applies to Nedbank as an FSP and employees within the RBB cluster. 4 Definitions

The following definitions are based on the FAIS Conflict of Interests Management Board Notice 58 of 2010: The word 'associate' means

(a) in relation to a natural person (i) a person who is recognised in law or the tenets of religion as the spouse, life partner or civil-union

partner of that person; (ii) a child of that person, including a stepchild, adopted child and a child born from an unmarried

spouse; (iii) a parent or stepparent of that person; (iv) a person who is recognised in law or appointed by a court as the person legally responsible for

managing the affairs or meeting the daily care needs of the first-mentioned person; (v) a person who is the spouse, life partner or civil-union partner of a person referred to in

subparagraphs (ii) to (iv); and (vi) a person who is in a commercial partnership with that person.

(b) in relation to a juristic person [eg where Nedbank RBB or its representatives sells a product on behalf of another FSP (entity or company)]

(i) a company, any subsidiary or holding company of that company, any other subsidiary of that holding company and any other company of which that company is a subsidiary.

(c) in relation to any other person (i) any juristic person of which the board of directors or the governing body, as the case may be, is

accustomed to act in accordance with the directions or instruction of the person first-mentioned in this paragraph; and

(ii) including any trust controlled or administered by that person. The word 'client' means a specific person or group of persons, excluding the general public, who is or may

become the subject to whom a financial service is rendered intentionally, or is the successor in title of such person or the beneficiary of such service. The word 'code' means the General Code of Conduct for Authorised Financial Services Providers and

Representatives, 2003, as amended.


The phrase 'conflict of interest' means any situation in which the provider or representative has an actual or a

potential interest that, in rendering a financial service to a client, may (a) influence the objective performance of his, her or its obligations to that client; or (b) prevent the provider or representative from rendering an unbiased and a fair financial service to that client,

or from acting in the interest of that client, including (i) a financial interest; (ii) an ownership interest; and (iii) any relationship with a third party.

The phrase 'distribution channel' means

(a) any arrangement between a product supplier or any of its associates and one or more providers or any of its associates in terms of which arrangement any support or service is provided to the provider or providers in rendering a financial service to a client;

(b) any arrangement between two or more providers or any of their associates, which arrangement facilitates, supports or enhances a relationship between the provider or providers and a product supplier; and

(c) any arrangement between two or more product suppliers or any of their associates, which arrangement facilitates, supports or enhances a relationship between a provider or providers and a product supplier.

The phrase 'financial interest' means any cash, cash equivalent, voucher, gift, service, advantage, benefit,

discount, domestic or foreign travel, hospitality, accommodation, sponsorship, other incentives or valuable consideration.

The phrase 'immaterial financial interest' means any financial interest with a determinable monetary value of

not more than R1 000 in total in any calendar year, from the same third party, and which is received by (a) a provider who is a sole proprietor; or (b) a representative for that representative's direct benefit; or (c) a provider, who for its benefit or that of some or all its representatives, aggregates the immaterial financial

interest paid to its representatives. This means that the maximum amount of benefits that a representative or sole provider may receive from any specific product supplier or other third party is R1 000 a year. A provider with more than one representative may aggregate the amount received.

The phrase 'key individual' means a person who is responsible for managing or overseeing, either alone or with

other responsible people, the activities relating to the FSP.

'Nedbank Retail and Business Banking' means a cluster within Nedbank Limited, a financial services provider

as envisaged in the FAIS Act.

The phrase 'ownership interest' means

(a) any equity or proprietary interest, for which the owner paid fair value at the time of acquisition, and not equity or a proprietary interest held as an approved nominee on behalf of another person; and

(b) includes any dividend, profit share or similar benefit derived from that equity or ownership interest;

The phrase 'product supplier' means any person, as defined in the FAIS Act, who provides a financial product

by virtue of an authority, an approval or a right granted to such person under any law, including the Companies Act, 71 of 2008 ('the Companies Act').

The word 'representative' means any person who renders a financial service to a client for or on behalf of an

FSP. This may include (a) rendering an intermediary service; and (b) giving advice regarding financial products.

The phrase 'signon bonus' means any financial interest offered or received directly or indirectly, upfront or

deferred, and with or without conditions, as an incentive to become a provider.

The phrase 'third party' means

(a) a product supplier; (b) another provider; (c) an associate of a product supplier or provider; (d) a distribution channel; and (e) any person who in terms of an agreement or arrangement with a person referred to in paragraphs (a) to (d)

above provides a financial interest to a provider or its representatives.


5 Key principles

The general rule is that a conflict of interest between the client, the FSP and representative must be avoided. However, where a conflict of interest is unavoidable, the FSP and its representatives must take steps to mitigate the effect that the conflict of interest has on the client. Nedbank RBB or a representative must disclose all conflicts of interest to a client in respect of that client as soon as possible and in writing. 5.1 FAIS General Code of Conduct

In terms of the code Nedbank RBB and its representatives must:

avoid, and where this is not possible, mitigate any conflict of interest between Nedbank RBB and a client or the representative and a client;

prepare and adopt a conflict of interest management policy to manage all conflicts of interest between the provider and a client or the representative and a client;

in writing, at the earliest reasonable opportunity, inform a client of the conflict of interest management policy and how it may be accessed;

in writing, at the earliest reasonable opportunity, disclose to a client any conflict of interest in respect of that client;

in writing, at the earliest reasonable opportunity, disclose to a client the measures taken in accordance with the conflict of interest management policy to avoid or mitigate the conflict;

in writing, at the earliest reasonable opportunity, disclose to a client any ownership interest or financial interest, other than an immaterial financial interest, that the provider or representative may be or become eligible for; and

in writing, at the earliest reasonable opportunity, disclose to a client the nature of any relationship or arrangement with a third party that gives rise to a conflict of interest, in sufficient detail so that a client can understand the exact nature of the relationship or arrangement and the conflict of interest.

5.2 Circumstances where a conflict of interest could occur

A conflict of interest will arise in the following instances:

Where Nedbank RBB or its representative has an actual or a potential interest in a product supplier and this interest influences the objective performance of its/his/her obligations to that client.

Where the abovementioned interest prevents Nedbank RBB or its representative from rendering an unbiased and fair financial service to that client, or from acting in the interest of that client. Nedbank RBB or its representative must disclose all conflicts of interest to a client in respect of that client as soon as possible and in writing.

Where Nedbank RBB or its representative recommends to a client a financial product from a product supplier from whom Nedbank RBB or the representative received or still receives cash, cash equivalents, vouchers, gifts, services, advantages, benefits, discounts, domestic or foreign trips, hospitality, accommodation, sponsorship or other incentive or valuable consideration other than that permissible in terms of this policy.

Where Nedbank RBB or its representative recommends to a client a financial product from a product supplier in which Nedbank RBB or the representative that makes the recommendation owns equity or a proprietary interest for which fair value was paid at the time of acquisition. An equity or a proprietary interest includes dividends, profit sharing or a similar benefit derived from that equity or proprietary interest.

Where Nedbank RBB or its representative renders a financial service to a client that involves a product supplier, a provider or their respective associates, or a distribution channel through which Nedbank RBB or the representative receives a financial interest other than that permissible in terms of this policy.

Where a sales manager within Nedbank RBB has a focus day to increase the volume in sales for a specific product. A typical scenario is where the sales manager encourages the representatives to focus on this specific product when rendering financial service, despite there being other products that are similar in

nature, but differing in features and benefits. The representatives who generate the most sales in relation to

this product receive an all-expenses paid weekend away. 5.3 Permitted financial interest

Nedbank RBB or its representative is entitled to receive:

or offer commission authorised under the Long-term Insurance Act, 52 of 1998, or the Short-term Insurance Act, 53 of 1998;

fees authorised under the Long-term Insurance Act, 52 of 1998, the Short-term Insurance Act, 53 of 1998, or the Medical Schemes Act, 131 of 1998, if those fees are reasonably proportionate to a service being rendered;


fees for rendering a financial service, even if those fees are not authorised under the abovementioned acts, provided that those fees are specifically agreed to by a client in writing and may be stopped at the discretion of that client;

fees or remuneration for rendering a service to a third party, if such fees or remuneration is reasonably proportionate to the service being rendered;

an immaterial financial interest, subject to any other law and the provisions of this policy; and

a financial interest, not referred to above, for which a consideration, fair value or remuneration that is reasonably commensurate to the value of the financial interest is paid by Nedbank RBB or its representative at the time of receipt thereof.

5.4 Prohibited financial interest

Nedbank RBB may not offer any financial interest to its representatives for giving preference:

to the quantity of business secured for it to the exclusion of the quality of the service rendered to clients;

to a specific product supplier, where the representative may recommend more than one product supplier to a client; and

to a specific product of a product supplier, where a representative may recommend more than one product of that product supplier to a client.

The managing directors of the business units in Nedbank RBB must sign an annual declaration confirming that Nedbank RBB does not offer prohibited financial interests as envisaged in this clause.

5.5 Acceptance of immaterial financial interest

Nedbank RBB and any of its representatives can receive an immaterial financial interest (not more than R1 000 a year, per third party and/or vendor, and it must be limited to two gifts every six months from the same third party or vendor.

5.6 Disclosure of the group and third-party ownership interests and associates to clients

Nedbank RBB and any of its representatives must disclose to the client any third-party ownership interests and Nedbank's ownership interest, as well as its associates, when rendering financial services. In so doing the client will be able to make an informed decision.

This policy includes a list of any third-party ownership interests, the group's ownership interest, as well as its associates (where applicable). Refer to annexures A and B at the end of the document.

5.7 Signon bonuses

The law prohibits offering a signon bonus to any person other than a new entrant (a person who has never been authorised as an FSP or appointed as a representative by any FSP). This policy, however, provides that Nedbank will not engage in the practice of offering signon bonuses as part of its recruitment strategies or as an incentive to become its representative or provider. 6 Roles and responsibilities 6.1 Enterprise Governance and Compliance

Enterprise Governance and Compliance (EGC) is the policyowner and is responsible for:

reviewing and maintaining this policy;

providing training with regard to this policy and the Code of Conduct; and

reviewing and approving cluster/divisional level 4 policies. 6.2 Retail Governance and Compliance

Retail Governance and Compliance (RGC) is responsible for:

monitoring the adequacy and effectiveness of controls implemented by business to ensure compliance with this policy, and/or any level 3 policies as determined by the group, cluster, business unit or division;

training on this policy; and

reviewing this policy annually.


6.3 Business compliance functions

Business compliance functions are responsible for:

monitoring the adequacy and effectiveness of controls implemented by business to ensure compliance with this policy, and/or any level 3 policies as determined by the group, cluster, business unit or division; and

training on this policy; and subsequent policies that will be developed in line with EGC and/or RGC policies. 6.4 Business

Business is responsible for:

establishing and implementing processes, procedures and controls to ensure compliance with this policy and/or policies on any other level, as determined within that cluster, business unit or division;

ongoing monitoring of the effectiveness of processes, procedure and controls to ensure compliance with this policy and/or any level 4 policies as implemented by a cluster, business unit or division; and

ensuring that the lists for Nedbank RBB/Nedbank Group third-party ownership interests, the ownership interest, as well as its associates (where applicable), are updated accordingly. Any changes thereto must be communicated to the cluster governance and compliance function – refer to annexures A and B.

6.5 Key individuals

Key individuals are responsible for:

monitoring the activities and/or interactions between clients and FAIS-affected staff, thereby ensuring compliance to this policy; and

reporting any instances of non-compliance to management and the governance and compliance officers of that cluster.

7 Exemption

An FSP and its representative are exempted from section 3A (1) (a) of the code, to the extent that the FSP or representative may offer or receive training in respect of the first-level regulatory examination, provided the training:

is not available exclusively to a selected group of FSPs or representatives;

is not subject to giving preference to the quantity of business secured for the FSP to the exclusion of the quality of service rendered to clients;

is not subject to giving preference to a specific product supplier, where an FSP or a representative may recommend more than one product supplier to a client; and

is not subject to giving preference to a specific product of a product supplier, where an FSP or a representative may recommend more than one product of the product supplier to a client.

8 Contravention of this policy

Every employee of the group is required to know, understand and comply with the standards outlined in this policy, the Code of Business Ethics and the Code of Conduct. Anyone who violates this policy and/or the Code of Conduct will be subject to Nedbank's disciplinary and grievance policy and procedure.

Non-compliance with this policy and the Code of Conduct and the procedures described in it may be considered to be misconduct and employees may be subject to disciplinary action that could lead to dismissal.

9 Effective date

This policy becomes effective on the first day of publication on the official Nedbank website. 10 Links to other group policies

These policy rules are not independent of the following:

Enterprisewide Risk Management Policy and the Enterprise Risk Management Framework

Market Abuse and Personal Account Trading Policy (MAPATP)


Confidentiality Policy

Code of Conduct

Prevention and Combating of Corrupt Activities Act, 12 of 2004

Level 3 FAIS Conflict of Interests Policy


Annexure A – List of subsidiaries, associates and third parties in which Nedbank Group Ltd holds an

ownership interest

Company Shareholding percentage (%)

Aard Mining Equipment (Pty) Ltd 48,90%

Amber Mountain Investment 3 (Pty) Ltd 100,00%

Aquarella Investments 509 (Pty) Ltd 28,00%

Banco Único 38,688%

Bara Mall (Pty) Ltd 35,00%

Bea Ned (Pty) Ltd 50,00%

Bene Inventa (Pty) Ltd 100,00%

Bloemfontein Board of Executors and Trust Company Ltd 100,00%

BNS Nominees (Pty) Ltd 100,00%

BoE 187 Investments (Pty) Ltd 100,00%

BoE Developments (Pty) Ltd 100,00%

BoE Holdings (Pty) Ltd 100,00%

BoE Investment Holdings Ltd 100,00%

BoE Management Ltd 100,00%

BoE Private Client and Trust Company (Pty) Ltd 100,00%

BoE Private Client Investment Holdings Ltd 100,00%

BoE Private Equity Investments (Pty) Ltd 100,00%

Bond Choice (Pty) Ltd 28,50%

Boness Development Phase 3 (Pty) Ltd 100,00%

BPCC Security Company (Pty) Ltd 100,00%

Campuskey (Pty) Ltd 20,00%


Cape Commodities Traders and Investors 9 (Pty) Ltd 35,00%

Capegate Crescent Development (Pty) Ltd 100,00%

Capricorn Business and Technology Park (Pty) Ltd 33,33%

CBN Nominees (Pty) Ltd 100,00%

Consep Developments (Pty) Ltd 30,80%

Consumer Credit (Namibia) (Pty) Ltd 100,00%

Consumer Credit (Swaziland) (Pty) Ltd 100,00%

CRD Management Company (Pty) Ltd 40,00%

Crossroads Distribution (Pty) Ltd 40,00%

Datacraft Mexico SA de CV 100,00%

Depfin Investments (Pty) Ltd 100,00%

Ecobank Transnational Incorporated 21,80%

Eighty One Main Street Nominees Ltd 100,00%

Elderberry Investments 110 (Pty) Ltd 49,00%

Embeca Properties (Private) Ltd 100,00%

Equibond (Pty) Ltd 100,00%

Erf 7 Sandown (Pty) Ltd 100,00%

ESF Finance (Pty) Ltd 100,00%

Esimio Trading 101 Ltd 100,00%

Eveready (Pty) Ltd 20,00%

Farm Bothasfontein (Kyalami) (Pty) Ltd 30,00%

Farm Rietfontein 31 (Pty) Ltd 30,00%

Fidelity Nominees (RF) (Pty) Ltd 100,00%

Finansfin (Pty) Ltd 100,00%


Finishing Touch Trading 55 (Pty) Ltd 20,00%

Finlac Trust (Pty) Ltd 100,00%

Firefly Investments 74 (Pty) Ltd 35,00%

Friedshelf 1514 (Pty) Ltd 40,00%

GEOC Nominees Ltd 100,00%

Gateway Central Park (Pty) Ltd 30,00%

Gateway Park Avenue (Pty) Ltd 45,00%

Golddurb Investments (Pty) Ltd 25,00%

Golddunn Property Developments (Pty) Ltd 100,00%

Golden Pond Trading 350 (Pty) Ltd 20,00%

Hazeldean Retreat (Pty) Ltd 20,00%

IBL Asset Finance and Services Ltd 100,00%

Ideal Infinity Services (Pty) Ltd 20,00%

Ideas Nedbank AIIF Investors Trust 60,00%

Iliza Elitsha JV Co (Pty) Ltd 33,33%

Investage 91 (Pty) Ltd 100,00%

Isegen South Africa (Pty) Ltd 45,00%

Ixia Trading 630 (Pty) Ltd 35,00%

Kingsmead Properties (Pty) Ltd 100,00%

Klein Steenberg (Pty) Ltd 33,33%

Liberty Lane 329 (Pty) Ltd 33,33%

Lighthouse Development (Pty) Ltd 100,00%

Linton Projects (Pty) Ltd 100,00%

Little Green Beverages (Pty) Ltd 30,00%


Manappu Investments (Pty) Ltd 20,00%

Masingita Property Investment Holdings (Pty) Ltd 35,00%

MBCA Bank Limited 100,00%

MBCA Holdings Ltd 65,28%

MBCA Nominees (Private) Ltd 100,00%

Melbek Holding (Private) Ltd 100,00%

Mercury Securities (Pty) Ltd 100,00%

MHF Properties Ltd 100,00%

Morened (Pty) Ltd 100,00%

Mortgage Investment Corporation (Pty) Ltd 100,00%

NBSA Limited 100,00%

NHS Properties (Pty) Ltd 100,00%

NamClear (Pty) Ltd 25,00%

Nasionale Dorpsontwikkelingskorporasie Ltd 99,76%

National Board (PE) Ltd 100,00%

National Board of Executors Ltd 100,00%

NBG Capital Management (Pty) Ltd 100,00%

Ned Investment Trust 100,00%

Nedamericas Investments Ltd 74,90%

Nedbank (Lesotho) Ltd 100,00%

Nedbank (Swaziland) Ltd 65,08%

Nedbank Group Ltd N/A

Nedbank Group Insurance Company Ltd 100,00%

Nedbank Group Insurance Holdings Ltd 100,00%


Nedbank Ltd 100,00%

Nedbank (Malawi) Ltd 100,00%

Nedbank Namibia Ltd 100,00%

Nedbank Nominees (RF) (Pty) Ltd 100,00%

Nedbank Private Wealth Ltd 100,00%

Nedcap International Ltd 100,00%

Nedcapital Investment Holdings (Pty) Ltd 100,00%

NedCapital Namibia (Pty) Ltd 100,00%

Nedcor Bank Nominees (RF) (Pty Ltd 100,00%

Nedcor Investments Ltd 100,00%

Nedcor Trade Services (Asia) Ltd 100,00%

Nedcor Trade Services Ltd 100,00%

Nedeurope Ltd 100,00%

Nedglen Property Developments (Pty) Ltd 35,00%

Nedgroup Administrators (Pty) Ltd 100,00%

Nedgroup Beneficiary Solutions (Pty) Ltd 100,00%

Nedgroup Beta Solutions (Pty) Ltd 100,00%

Nedgroup Collective Investments Ltd 100,00%

Nedgroup Financial Services 104 Ltd 100,00%

Nedgroup Insurance Administrators Ltd 100,00%

Nedgroup Insurance Company Ltd 100,00%

Nedgroup International Holdings Ltd 100,00%

Nedgroup Investment 102 Ltd 100,00%

NedGroup Investments Africa 100,00%


Nedgroup Investment Advisors (UK) Ltd 100,00%

Nedgroup Investment Advisors Ltd 100,00%

Nedgroup Investments (IOM) Ltd 100,00%

Nedgroup Investments (Pty) Ltd 100,00%

Nedgroup Investments Alpha (Pty) Ltd 100,00%

Nedgroup Life Assurance Company Ltd 100,00%

Nedgroup Private Wealth (Pty) Ltd 100,00%

Nedgroup Private Wealth Corporate Services Ltd 100,00%

Nedgroup Private Wealth Directors Ltd 100,00%

Nedgroup Private Wealth Fiduciary Services Ltd 100,00%

Nedgroup Private Wealth Nominees (Jersey) Ltd 100,00%

Nedgroup Private Wealth Nominees (Pty) Ltd 100,00%

Nedgroup Private Wealth Nominees (IOM) Ltd 100,00%

Nedgroup Private Wealth Nominees (UK) Ltd 100,00%

Nedgroup Private Wealth Secretarial Ltd 100,00%

Nedgroup Private Wealth Stockbrokers (Pty) Ltd 100,00%

Nedgroup Secretariat Services (Pty) Ltd 100,00%

Nedgroup Securities (Pty) Ltd 100,00%

Nedgroup Structured Life Ltd 100,00%

Nedgroup Trust (IOM) Ltd 100,00%

Nedgroup Trust (Jersey) Ltd 100,00%

Nedgroup Trust (KZN) (Pty) Ltd 100,00%

Nedgroup Trust Limited 100,00%

Nedgroup Trust (Pty) Ltd 100,00%


Nedgroup Wealth Management (Pty) Ltd 100,00%

Nedinvest (Pty) Ltd 100,00%

Nedinvestments (Namibia) (Pty) Ltd 100,00%

NedLoans (Pty) Ltd 100,00%

NedNamibia Holdings Ltd 100,00%

NedNamibia Life Assurance Company Ltd 100,00%

NedPlan Insurance Brokers Namibia (Pty) Ltd 100,00%

Nedport Developments (Pty) Ltd 100,00%

NedProperties (Pty) Ltd 100,00%

Ned Settle Services (Pty) Ltd 100,00%

Newtown Leasing (Pty) Ltd 100,00%

NIB Blue Capital Investments (Pty) Ltd 100,00%

NIB Mining Finance (Pty) Ltd 100,00%

NIB Nominees (Pty) Ltd 100,00%

Northants Property Enterprises (Pty) Ltd 50,00%

Odyssey Developments (Pty) Ltd 49,00%

Off The Shelf Investments Forty One (Pty) Ltd 33,33%

Old Mutual US Dollar Money Market Fund 50,00%

Old Mutual Trust (Namibia) Ltd 50,00%

Old Mutual Trust (Pty) Ltd 100,00%

Olievenhout Plaza (Pty) Ltd 25,00%

Onrus Manor (Pty) Ltd 100,00%

Oukraal Developments (Pty) Ltd 30,00%

Pacific Eagle Properties 13 (Pty) Ltd 25,00%


Payments Association of Lesotho Ltd 20,00%

Pearldale Property Developers (Pty) Ltd 35,00%

Peoples Mortgage Ltd 100,00%

POD Property Fund (Pty) Ltd 32,00%

Polkadots Properties 117 (Pty) Ltd 49,90%

Proclare (Pty) Ltd 100,00%

Pyraned Ltd 100,00%

Quintado 126 (Pty) Ltd 50,00%

Raiden Investments (Pty) Ltd 40,00%

Robow Investments No 47 (Pty) Ltd 50,00%

RSPCE Devco (Pty) Ltd 30,00%

RZT Zelby 4558 (Pty) Ltd 35,00%

SA Axle Finance (Pty) Ltd 66,00%

SBV Services (Pty) Ltd 25,00%

Seaward Development (Pty) Ltd 100,00%

Seventy Five on Maude (Pty) Ltd 50,00%

Silver Meadow Trading 255 (Pty) Ltd 40,00%

Skynet South Africa (Pty) Ltd 40,00%

SMK Genomineerdes (Edms) Bpk 100,00%

South African Bankers Services Company Ltd 23,00%

South African Roll Company (Pty) Ltd 49,90%

Spectrum Nominees Ltd 100,00%

Stella SGS Investments (Pty) Ltd 33,33%

Syfrets Ltd 100,00%


Syfrets Mortgage Nominees (RF) (Pty) Ltd 100,00%

Syfrets Nominees Ltd 100,00%

Syfrets Participation Bond Managers (Pty) Ltd 100,00%

Syfrets Property Brokers (Pty) Ltd 100,00%

Syfrets Securities Ltd 100,00%

Syfrets Securities Nominees (Pty) Ltd 100,00%

Syfrets Trust and Executor (Eastern Cape) Ltd 100,00%

Syfrets Trust and Executor (Grahamstown) Co Ltd 100,00%

Telle Investments (Pty) Ltd 100,00%

Ten Kaiser Wilhelm Strasse (Pty) Ltd 50,00%

The Board of Executors 100,00%

The Board of Executors Mortgages (Pty) Ltd 100,00%

The COC Trust Company Ltd 100,00%

The Colonial Orphan Chamber and Trust Company 100,00%

The General Estate and Orphan Chamber 100,00%

The Heron Banks Development Trust 50,00%

The Motor Finance Corporation (Pty) Ltd 100,00%

The South African Association 100,00%

The Waterbuck Trust 40,00%

The Woodlands Property Trust 20,00%

Toontjiesrivier Landgoed (Edms) Bpk 100,00%

Villager Investments No 1 (Pty) Ltd 100,00%

Visigro Investments (Pty) Ltd 100,00%

Walvis Bay Land Syndicate (Pty) Ltd 50,00%


Whirlprops 33 (Pty) Ltd 49,00%

Woodland Investment Company (Pty) Ltd 49,00%

XDV Investments (Pty) Ltd 25,00%


Annexure B – List of subsidiaries, associates and third parties that hold an ownership interest in

Nedbank Group Ltd1

Major shareholders/managers Shareholding percentage (%)

Old Mutual Life Assurance Company (SA) Ltd and associates 55,43%

Nedbank Group treasury shares 3,73%

Coronation Fund Managers (SA) 7,96%

Public Investment Corporation (SA) 6,29%

Lazard Asset Management (US and UK) 2,72%

Dimensional Fund Advisors (US, UK and AU) 1,60%

BlackRock Inc (US and UK) 1,62%

Sanlam Investment Management (SA) 1,63%

Major beneficial shareholders

Old Mutual Life Assurance Company (SA) Ltd and associates (SA) 55,43%

Government Employees Pension Fund (SA) 7,42%

1 Source: Nedbank website “Ordinary shareholder's profile”

https://www.nedbank.co.za/content/nedbank/desktop/gt/en/aboutus/investor-center/equity-investor/ordinary-shareholder-s-profile.html



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