Prime legal information
Prime compliance policy
IMPORTANT: The information on this website does not take into account the personal, financial or other circumstances, needs, objectives or requirements of its visitors. All information provided is of a factual and general nature only and cannot be construed as the provision of advice in terms of the Financial Advisory and Intermediary Services Act, 2002 (‘FAIS’).
Prime Meridian Direct (PMD) t/a Prime South Africa (Pty) Ltd (“Prime”) is a company incorporated in terms of the laws of South Africa under registration number: 2004/032998/07.
Prime is registered as a Financial Services Provider with the Financial Services Board under FSP number 41040. is a category 1 FSP and is authorized to conduct services relating to the supply of short-term insurance (personal lines) products
Complaints Policy
As a registered Financial Services Provider, Prime is committed to providing its clients with a service of the highest professional and ethical standards. Prime subscribes to the following complaints policy and procedure to ensure the prompt handling of clients’ complaints in a fair, efficient and effective manner.
What is set out below constitutes the official complaints policy and internal complaint resolution system and procedures for Prime Meridian Direct t/a Prime South Africa (Pty) Ltd (“Prime”) as required by the Financial Advisory and Intermediary Services (“FAIS”) Act 37 of 2002.
Prime is committed to an internal complaint resolution system and procedure based on the following underlying principles:
DEFINITION OF “COMPLAINT”
“Complaint” means an expression of dissatisfaction by a person to an insurer or, to the knowledge of the insurer, to the insurer’s service provider relating to a policy or service provided or offered by that insurer which indicates or alleges, regardless of whether such an expression of dissatisfaction is submitted together with or in relation to a policyholder query, that –
Procedure For Lodging A Complaint
INTERNAL PROCEDURE
Prime’s complaints procedure is in line with the provisions of the FAIS General Code of Conduct as contained in the Financial Advisory and Intermediary Services Act 37 of 2002 and the Policyholder Protection Rules, 2004 (Short Term Insurance Act 53 of 1998). The way in which a client can lodge a complaint and the time frames attached thereto are set out in the statutory disclosure documents forming part of the client’s claim outcome documentation and this information is also made available to the client whenever a claim is rejected or a complaint is not resolved to the satisfaction of the client.
Any client who wishes to lodge a complaint against Prime or any of its employees must lodge the complaint in writing.
The complaint must provide full details of the circumstances and events related to the complaint and it be accompanied by relevant supporting documentation
All complaints will be entered into a formal complaints register.
Non-routine serious complaints will be handled by appropriately senior staff with adequate expertise, training and experience to resolve the matter expeditiously.
The client will be kept informed of the progress of the complaint on a regular basis and at least every 14 days.
The client is entitled to make a written complaint related representations within 90 days of notification of a claim rejection decision.
All complaints will be entered into a formal complaints register.
Non-routine serious complaints will be handled by appropriately senior staff with adequate expertise, training and experience to resolve the matter expeditiously.
The client will be kept informed of the progress of the complaint on a regular basis and at least every 14 days.
Where the complaint is resolved in the favour of the client, a full and appropriate level of redress will be offered to the client without delay.
If an outcome is not favourable to the complainant, full written reasons will be furnished and the client will be given the opportunity to rectify any incorrect information. Where a client wishes to have a decision regarding a complaint reviewed, the client’s request will be dealt with on the same basis as a newly lodged complaint.
All complaints must be addressed directly to the Insurer and its Intermediary:
Products underwritten by Santam Structured Insurance Limited: Comprehensive, Customised and 3rd Party
FSP name: Santam Structured Insurance Limited FSP no: FSP1027
Postal address: PO Box 652659 Benmore 2010
Physical address: 7th Floor, Alice Lane Building 3 Corner Alice Lane and 5th Street Sandton 2196
Tel: +27 11 685 7600
Email: ssi.complaints@santam.co.za
For the attention of: Complaints Department
Administrator & non-Mandated Intermediary:
FSP name: Primary Asset Administrative Services (Pty) Ltd
Postal address: Postnet Suite 430 Private Bag X51 Bryanston JHB, 2021
Fax: 011 367 7251
Tel: 011 745 7820
Email: legal@primaryasset.co.za
For the attention of: Complaints Department
EXTERNAL PROCEDURE: LEGAL ACTION OR REFERRAL TO FAIS AND NATIONAL FINANCIAL OMBUD:
For rejected claims, contact the National Financial Ombud Scheme at
Telephone: 0860 800 900
Email: info@nfosa.co.za
Physical Address: 110 Oxford Road, Houghton Estate,
Johannesburg, 2198
Postal Address: P.O. Box 74571 Lynnwood Ridge, 0040
For rejected claims, contact the FAIS Ombud on one of the following:
Telephone: 012 470 9080
Email:info@faisombud.co.za
Physical Address: 110 Oxford Road, Houghton Estate,
Johannesburg, 2198
Postal Address: P.O. Box 74571 Lynnwood Ridge, 0040
The FAIS ombud will generally decline to investigate a complaint:
Prime will arrange for its Compliance Officer to inspect the complaints register from time to time and monitor effective complaint resolution and compliance with the above complaints process. All complaints will be followed-up at an operational level to ensure avoidance of similar occurrences that might give rise to complaints and to improve services, systems and procedures where necessary. Complaints records will be maintained for a minimum period of 5 years together with an indication of whether or not such complaint was resolved and all cases of non-compliance with the legislation and the reasons for such non-compliance.
Conflict of Interest Management Policy
FSP name: Prime Meridian Direct t/a Prime South Africa (Pty) Ltd
FSP number: 41040
Introduction
The General Code of Conduct of the Financial Advisory and Intermediary Services Act, 2002, sets out requirements for the management of conflict of interests. Prime Meridian Direct (Pty) Ltd (“Prime”) is required to take all reasonable steps to identify, monitor and manage conflicts of interest. Prime has put in place a policy to safeguard its clients’ interests and ensure fair treatment of clients. The key information is summarised below. Detailed information can be obtained on request from the provider, compliance officer or key individual who is responsible to monitor and manage conflict of interest on behalf of Prime.
Definition
The following terms are defined for ease of reference thereto and in terms of the meaning afforded to the said terms by the Financial Advisory and Intermediary Services Act 37 of 2002 as follows:-
“conflict of interest”- Any situation in which Prime or any of our employees and representatives may have an actual or potential interest that may, in rendering a financial service to a client –
“interest” – Includes but is not limited to a financial interest, ownership interest or 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
“immaterial financial interest” – Means any financial interest with a determinable monetary value, the aggregate of which does not exceed R1000.00 in any calendar year from the same third party in that calendar year received by –
“ ownership interest” – Means any equity or proprietary interest for which the fair value was paid by the owner at the time of acquisition, other than equity or a proprietary interest held as an approved nominee on behalf of another person. Includes: any dividend, profit share or other benefit derived from that equity or ownership interest.
“associate” –
“third party” – Includes: product suppliers, another provider, associates of product suppliers and providers and distribution channels.
Our Objectives
Prime is an authorised financial services provider. Like any financial services provider, Prime is potentially exposed to conflicts of interest in relation to various activities. However, the protection of our clients’ interests is our primary concern and so our policy sets out how:
Conflict of interest
Prime strives towards ensuring we are able to appropriately and effectively identify and manage potential conflicts. It may manage potential conflicts through avoidance, establishing confidentiality barriers and by providing appropriate disclosure of the conflict to affected clients.
In determining whether there is or may be a conflict of interest to which the policy applies, Prime considers whether there is a material risk of damage to the client, taking into account whether Prime or a Prime representative, associate or employee –
Our policy defines possible conflicts of interest as, inter alia:
Management
Specific monetary measures Prime focuses on include:
- giving preference to the quantity of business secured for the provider to the exclusion of quality service;
- giving preference to a specific product supplier where more than one supplier can be recommended to a client;
- giving preference to a specific product of a supplier where more than one product of that supplier can be recommended
The measures we have adopted to manage identified conflicts are further summarized below. We consider them appropriate to our efforts to take reasonable care that, in relation to each identified potential conflict of interest, we act impartially to avoid a material risk of harming clients’ interests.
Particular Management Measures
- where relevant and appropriate, create awareness and knowledge of applicable stipulations of the General Code of Conduct and relevant legislation relating to conflict of interest, through training and educational material;
- ensure understanding and adoption of conflict of interest policy and management measures by all employees, representatives and associates;
- do regular inspections on all commissions, remuneration, fees and financial interests proposed or received to avoid non-compliance;
- keep a register of conflict of interest – at present none have been identified.
CONSEQUENCES OF NON-COMPLIANCE WITH THE POLICY BY US AS PROVIDER, EMPLOYEES AND REPRESENTATIVES
In the event of non-compliance with the abovementioned terms of the Policy, in addition to any civil or criminal consequences, employees and representatives will be subject to appropriate disciplinary action. To date there have been no non-compliance events.
A List of All Prime Associates
The following entities are associates of Prime:
