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Previously Prime Meridian Direct (PMD) Prime Meridian Direct

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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:

  • Icon_LegalTick fairness by ensuring that resolution of a complaint will be effected in a manner which is fair to both the client and Prime;
  • Icon_LegalTick transparency and visibility ensuring that clients have full knowledge of the procedures for resolution of their complaints;
  • Icon_LegalTick adequate training of all relevant staff including imparting and ensuring full knowledge of the provisions of the legislation with regard to the resolution of complaints;
  • Icon_LegalTick ease of accessibility tto complaints mechanisms through the provision of multiple mechanisms at Prime’s business premises, and through and any of our social media platforms;
  • Icon_LegalTick appropriate maintenance of and commitment to an efficient internal complaint resolution system with sufficient resources and an adequately maintained register of complaints.

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 –

  • Icon_LegalTick the insurer or its service provider has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on the insurer or to which it subscribes;
  • Icon_LegalTick the insurer or its service provider’s maladministration or willful or negligent action or failure to act, has caused the person harm, prejudice, distress or substantial inconvenience; or
  • Icon_LegalTick the insurer or its service provider has treated the person unfairly.

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.

 

  • Icon_LegalTick Prime will acknowledge receipt of the complaint in writing within 48 hours of receipt of the complaint.
  • Icon_LegalTick We investigate and respond promptly to any complaint.
  • Icon_LegalTick Prime will notify the complainant in writing of the outcome of the resolution of the complaint within 42 days of receipt of the complaint. Where the complaint is not finalised within 21 days of receipt thereof and in cases where further information, assessments or investigations are required, a reasonable timeframe, not exceeding 30 days, will be agreed with the client.

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  

0860 762 745 

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:

  • Icon_LegalTick If a period of more than 3 years has passed since the act, omission or event which resulted in the complaint
  • Icon_LegalTick If proceedings have been instituted by the complainant in any court relating to the complaint.
  • Icon_LegalTick If there are reasonable grounds to believe that a more appropriate dispute resolution process is available.

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 –

  • Icon_LegalTick Influence the objective exercise of Prime’s obligations to a client, or
  • Icon_LegalTick Prevent Prime from rendering an unbiased and fair financial service, or from acting in the interest of the 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

  • Icon_LegalTick An ownership interest
  • Icon_LegalTick Training, that is not exclusively available to a selected group of providers 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 R1000.00 in any calendar year from the same third party in that calendar year received by –

  • Icon_LegalTick A provider who is a sole proprietor
  • Icon_LegalTick A representative for that representative’s direct benefit; or
  • Icon_LegalTick A provider, who for its benefit or that of some or all of its representatives, aggregates the immaterial financial interest paid to its representatives.

“ 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” –

  • Icon_LegalTick A natural person (spouse, life partner or civil union partner, a child (including a step child, child born out of wedlock and a adopted child), a parent or stepparent and any person legally responsible for that person);
  • Icon_LegalTick Juristic persons –if a company, all subsidiaries, holding companies and group subsidiaries and other juristic persons and group holding companies and group subsidiaries
  • Icon_LegalTick Persons directing or instructing any type of juristic person; and
  • Icon_LegalTick Trusts controlled and administered by the person.

“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:

  • Icon_LegalTick We identify the circumstances which may give rise to actual or potential conflicts of interest entailing a material risk of damage to our clients’ interests;
  • Icon_LegalTick We have established appropriate structures and systems of control to manage those conflicts; and how
  • Icon_LegalTick We will maintain systems to prevent damage to our clients’ interests through identified conflicts of interest.

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 –

  • Icon_LegalTick is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
  • Icon_LegalTick has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
  • Icon_LegalTick has a financial or other incentive to favour the interest of another client, group of clients or any other third party over the interests of the client;
  • Icon_LegalTick receives or will receive from a person other than the client, an inducement in relation to a service provided to the client in the form of monies, goods or services, other than the legislated commission or reasonable fee for that service

Our policy defines possible conflicts of interest as, inter alia:

  • Icon_LegalTick conflicts of interest between Prime and the client;
  • Icon_LegalTick conflicts of interest between our clients if we are acting for different clients and the different interests conflict materially;
  • Icon_LegalTick conflicts of interest where associates, product suppliers, distribution channels or any other third party is involved in the rendering of a financial service to a client;
  • Icon_LegalTick holding confidential information on clients which, if we would disclose or use, would affect the advice or services provided to clients.

Management

Specific monetary measures Prime focuses on include:

  • Icon_LegalTick the fact that it only receives commissions authorised in terms of applicable legislation; and
  • Icon_LegalTick Prime does not offer any financial interest to any representative or employee for –
  • 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.

  • Icon_LegalTick Procedures: We have adopted appropriate procedures throughout our business to manage potential conflicts of interest. Where considered necessary, our representatives, associates and employees receive guidance and training in these procedures and they are subject to monitoring and review processes. There are specific measures and consequences in place for non-compliance with our conflict of interest policy.
  • Icon_LegalTick Confidentiality Barriers: Our representatives, associates and employees respect the confidentiality of client information and disclose or use it with circumspect. No such information may be disclosed to a third party without the written consent of a client.
  • Icon_LegalTick Monitoring: The key individual or compliance officer in charge of supervision and monitoring of this policy will regularly provide feedback on all related matters. The policy will be reviewed annually.
  • Icon_LegalTick Disclosure: Where there is no other way of managing a conflict, or where the measures in place do not sufficiently protect clients’ interests, the conflict must be disclosed to allow clients to make an informed decision on whether to continue using our service in the situation concerned. In all cases, where appropriate and where determinable, the monetary value of non-cash inducements will be disclosed to clients. To date no such circumstances have arisen
  • Icon_LegalTick Publication: We will publish our conflict of interest management policy in appropriate media and ensure that it is easily accessible for public inspection at all reasonable times.
  • Icon_LegalTick Report: The provider, compliance officer or key individual will include a report on the conflict of interest management policy in the annual compliance report submitted to the Registrar.
  • Icon_LegalTick Declining to act: We may decline to act for a client in cases where we believe the conflict of interest cannot be managed in any other way.

Particular Management Measures

  • Icon_LegalTick Identification of conflict of interest:
  • 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;
  • Icon_LegalTick Avoidance of conflict of interest:
  • 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:

  • Icon_LegalTick Palaeo Financial Services
  • Icon_LegalTick PrimaryAsset Administrative Services
  • Icon_LegalTick PrimaryAsset Support Services
  • Icon_LegalTick PrimaryAsset Specialist Consulting

The types of financial interest which Prime Meridian Direct t/a Prime South Africa (Pty) Ltd may offer to its representatives

  • Icon_LegalTick Prime does not offer any type of financial interest to its representatives.
  • Icon_LegalTick Prime’s New Business Professional’s may in addition to their basic salaries receive volume-based commissions and other considerations all good performance (all of which are deemed reasonable compensation and adhere to strict guidelines).
  • Icon_LegalTick Prime is the sole distributor of the products developed by approved product suppliers and receives a regulated statutory commission in exchange for the distribution thereof.
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Prime Meridian House, Bryanston Gate Office Park, 170 Curzon Road (Cnr Main Road and Homestead Ave) Bryanston, Johannesburg, 2021

Prime SA is an Authorised Financial Services Provider, FSP 41040. Policy benefits underwritten by Santam Structured Insurance Limited, a Licenced Non-Life insurer
and Authorised Financial Services Provider, FSP 1027. Administered by PrimaryAsset Administrative Services (Pty) Ltd. Authorised Financial Services Provider. FSP 3920. Terms and Conditions apply.
Prime SA is a member of the Direct Marketing Association of South Africa. ©2024

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