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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 (Pty) Ltd (‘PMD’) is a company incorporated in terms of the laws of South Africa under registration number: 2004/032998/07.

PMD is registered as a Financial Services Provider with the Financial Services Board under FSP number 41040. PAAS 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, PMD is committed to providing its clients with a service of the highest professional and ethical standards. As required by FAIS and in order to facilitate an efficient system by which our clients can communicate with us, PMD subscribes to the following complaints policy and procedure.

What is set out below constitutes the official complaints policy and internal complaint resolution system and procedures for Prime Meridian Direct (Pty) Ltd (“PMD”) as required by the Financial Advisory and Intermediary Services (“FAIS”) Act 37 of 2002.

PMD is committed to an internal complaint resolution system and procedure based on the following underlying principles:

fairness by ensuring that resolution of a complaint will be effected in a manner which is fair to both the client and PMD;

transparency and visibility ensuring that clients have full knowledge of the procedures for resolution of their complaints;

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;

ease of accessibility to complaints mechanisms through the provision of multiple mechanisms at PMD’s business premises, and through the postal system, fax, telephone and/or electronic means;

appropriate maintenance of and commitment to an efficient internal complaint resolution system with sufficient resources and an adequately maintained register of complaints.


Complaint” means a specific complaint relating to a financial service rendered by PMD to the complainant on or after the date of commencement of the FAIS Act and in which complaint it is alleged that PMD:

has contravened or failed to comply with a provision of the FAIS Act and that as a result thereof the complainant has suffered or is likely to suffer financial prejudice or damage;

has wilfully or negligently rendered a financial service to the complainant which has caused prejudice or damage to the complainant or which is likely to result in such prejudice or damage; or

has treated the complainant unfairly.

Procedure For Lodging A Complaint

PMD’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, the Policyholder Protection Rules, 2004 (Short Term Insurance Act 53 of 1998) and section 13 of the SAIA Code of Conduct. 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 policy 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 PMD or any of its employees must lodge such complaint in writing.

The complaint must provide full details of the circumstances and events to which the complaint relates and be accompanied by relevant supporting documentation.

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.

All complaints must be addressed directly to the Insurer and its Underwriting Manager:

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

Underwriting Manager:

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

PMD will acknowledge receipt of the complaint in writing within 48 hours of receipt of the complaint.

PMD will endeavor to investigate and respond promptly to any complaint.

PMD 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.

Should the complaint not be resolved to the complainant’s satisfaction within 45 days of lodging such complaint, at any time within 6 months following the 90 day period referred to above, the client may pursue the following avenues:

  • Consult with an Attorney to pursue the matter by way of legal action.
  • For complaints contact the National Financial Ombud at:

T: 0860 800 900 E: info@nfosa.co.za

Johannesburg Office: 110 Oxford Road, Houghton Estate, Johannesburg, 2198


If a period of more than 3 years has passed since the act, omission or event which resulted in the complaint

If proceedings have been instituted by the complainant in any court relating to the complaint.

If there are reasonable grounds to believe that a more appropriate dispute resolution process is available.

PMD 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 (Pty) Ltd FSP number: 41040


In terms of the Financial Advisory and Intermediary Services Act, 2002, Prime Meridian Direct (Pty) Ltd (“PMD”) is required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflict of interest PMD 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 PMD.


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 PMD or any of PMD’s employees and representatives may have an actual or potential interest that may, in rendering a financial service to a client –

Influence the objective exercise of PMD’s obligations to a client, or

Prevent PMD 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

An ownership interest

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 –

A provider who is a sole proprietor

A representative for that representative’s direct benefit; or

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” –

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);

Juristic persons –if a company, all subsidiaries, holding companies and group subsidiaries and other juristic persons and group holding companies and group subsidiaries

Persons directing or instructing any type of juristic person; and

Trusts controlled and administered by the person.

third party” – Includes: product suppliers, another provider, associates of product suppliers and providers and distribution channels.


PMD is an authorised financial services provider. Like any financial services provider, PMD 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:

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;

We have established appropriate structures and systems of control to manage those conflicts; and how

We will maintain systems in an effort to prevent damage to our clients’ interests through identified conflicts of interest.


PMD strives towards ensuring it is 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, PMD considers whether there is a material risk of damage to the client, taking into account whether PMD or a PMD representative, associate or employee –

is likely to make a financial gain, or avoid a financial loss, at the expense of the client;

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;

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;

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:

conflicts of interest between PMD and the client;

conflicts of interest between our clients if we are acting for different clients and the different interests conflict materially;

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;

holding confidential information on clients which, if we would disclose or use, would affect the advice or services provided to clients.


Specific monetary measures PMD focuses on include:

the fact that it only receives commissions authorised in terms of applicable legislation; and

PMD 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 PMD has 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.

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.

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.

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.

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.

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.

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.

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.


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;

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 in order to avoid non-compliance;
  • keep a register of conflict of interest – at present none have been identified.


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.


The following entities are associates of PMD:

PMD Holdings (Pty) Ltd

The types of financial interest which Prime Meridian Direct (Pty) may offer to its representatives

PMD does not offer any type of financial interest to its representatives.

PMD’s Tele Assistants may in addition to their basic salaries receive volume based commissions (all of which are substantially less than R1000 per policy purchased) and the occasional cash or other prize for good performance.

PMD is the sole distributor of the products developed by approved product suppliers and receives a regulated statutory commission in exchange for the distribution thereof.