Introduction

'Sharenet', 'Sharenet LABS', 'Sharenet Securities', 'Sharenet Wealth' or 'we' refers to one or more of the companies in the Sharenet group that operate in South Africa.

'You', 'your' or 'yourself' refers to the user of the Sharenet website ('site'), and as the context requires, may be a reference to any client or potential client of Sharenet, or any financial adviser, representative, juristic representative and or introducing broker, who act on behalf of such client.

These Terms & Conditions ('Terms') become effective when you access this site for the first time and constitute a valid and binding agreement between Sharenet and yourself. The current version of these Terms governs our respective rights and obligations each time you access this site. If you do not agree to these Terms, please do not make use of this site.

By using the Services, you are confirming your consent to be bound by the terms of this Agreement. If you do not agree, Sharenet is not willing to provide you with access to the Services and you should immediately discontinue your use of the Services. You agree that Sharenet may modify this Agreement at any time in its sole discretion and without prior notice to you. Such changes will be posted online and will be effective upon posting.

You should review this Agreement periodically to ensure familiarity with its then-current terms and conditions.

Your continued use of the Services shall constitute your acceptance of this Agreement and your continued use of the Services following any modification of this Agreement shall constitute your acceptance to the Agreement, as amended. If you do not agree to the changes, you must notify Sharenet in writing or by telephone of your refusal and discontinue your use of the Services.

Sharenet is fully committed to safeguarding your privacy online or otherwise and the success of our business depends upon our ability to maintain the trust of our clients. As part of our day-to-day business operations we collect certain personal information about our clients. This privacy and cookie policy aims to provide a summary of the type of information we collect and how the information is used. The policy does not cover any external third party websites that may be accessed through the links provided on our website.

This Privacy Notice describes how Sharenet collects, uses, discloses, retains and protects your personal information, in accordance with the Protection of Personal Information Act (POPIA)and other relevant laws.

The Privacy Notice applies to any website, application, form, document, product or service which references this Privacy Notice. It also supplements any other privacy policies which may apply in respect of Sharenet entities' processing of personal information.

POPIA defines personal information as "information which relates to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person". This includes, but is not limited to, your name, sex, gender, address, contact details, identity number and medical or health information.

WHO WE ARE

In this Privacy Policy, any reference to "Sharenet", "Sharenet Wealth", "Sharenet Securities", "Sharenet Labs" or "we" refers to one or more of the entities, affiliates or subsidiaries of the Sharenet Group operating in South Africa.

WHAT IS PERSONAL INFORMATION?

"Personal Information" has the definition set out in the Protection of Personal Information Act 4 of 2013, that is, information which relates to you as an identifiable natural person or juristic person, including, but not limited to:

• information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
• information relating to the education or the medical, financial, criminal or employment history of the person;
• any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
• the biometric information of the person; and
• the personal opinions, views or preferences of the person.

Personal Information excludes:

• information that has been made anonymous so that it does not identify a specific person;
• permanently de-identified information that does not relate or cannot be traced back to you specifically;
• non-personal statistical information collected and compiled by us; and
• information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this notice).

RESPONSIBLE PARTY

The legal entity in Sharenet that collected personal information from you or that determined the purpose for the processing of your personal information (alone or in conjunction with others) will be the responsible party for your personal information. We are responsible that your personal information is processed in compliance with the conditions for lawful processing set out in POPIA.

PROCESSING INFORMATION

"Processing" means any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including:

• the collection, receipt, recording, organization, collation, storage, updating or modification, retrieval, alteration, consultation or use.
• dissemination by means of transmission, distribution or making available in any ither form; or
• merging, linking, as well as restrictions, degradation, erasure, or destruction of information.

HOW WE COLLECT INFORMATION

We collect personal information about you and any other person whose details you provide to us in accordance with the relevant laws, either:

• Directly from you when you complete a product or service application form, electronically, telephonically or by way of a hard copy;
• Indirectly from you when you interact with us electronically by way of our website, apps, or social media channels, which may include the collection of metadata (data about data);
• From retirement funds, employers and other contracted entities in the context of medical schemes and group insurance policies; and
• Where relevant, from third-party sources, such as other entities within the Sharenet Group, financial intermediaries that are representatives of Sharenet Group entities or have intermediary agreements with Sharenet Group entities, public databases, data aggregators, other financial institutions, credit bureaus, and fraud prevention agencies.

We will also collect your information where you have only partially completed and/or abandoned any information which you began to apply to our website and/or other online forms. Given that we already consider you a customer at this stage, we may use this information to contact you in order to remind you to complete outstanding information.

Where we require personal information in order to provide you with our products and services, your failure to provide us with the necessary information, will result in Sharenet being unable to provide you with our products and services. Where such services include financial advice, the appropriateness of the advice may be compromised if you do not provide complete and accurate information. You are responsible for informing Sharenet if your information changes.

COLLECTION OF INFORMATION BY THIRD PARTIES

Owners or information system administrators of third-party websites that have links to the Sharenet website, may collect personal information about you when you use these links. Sharenet does not control the collection or use of personal information by third parties and this privacy statement does not apply to third parties. Sharenet does not accept any responsibility or liability for third-party policies or your use of a third-party app, platform or service.

Sharenet also uses certain social networking services such as Facebook, WhatsApp, Instagram, LinkedIn and Twitter to communicate with the public and Sharenet clients. When you communicate with Sharenet through these services, that social networking service may collect your personal information for its own purposes. These services may track your use of our digital channels on those pages where the links are displayed. If you are logged into those services (including any Google service) while using our digital channels, their tracking will be associated with your profile with those service providers. These services have their own privacy policies which are independent of Sharenet's privacy policies and practices. Please ensure that you fully acquaint yourself with the terms of any such third-party privacy policies and practices.

Sharenet will only provide data to third-party information exchange services, for example, the Financial Services Exchange (Pty) Ltd, trading as Astute, with your consent.

WHAT INFORMATION WE COLLECT

Your relationship with Sharenet determines the exact nature of the personal information Sharenet processes, and the purpose for which such personal information is collected and used. However, in many cases, if we are handling your personal information as part of our role as an insurer, the personal information we may process includes the following:

• Information about you - for example, your name, identity number, age, gender, date of birth, nationality, occupation, lifestyle, current status of health, medical history and any existing conditions of each person insured. In the event that you make a claim, we may also collect personal information from you about the claim and any relevant third parties. We acknowledge that information about your health is special personal information. Note that we will use that information strictly in accordance with applicable laws and for insurance purposes (including assessing the terms of the insurance contract, dealing with changes to the policy and/or dealing with claims).
• Contact information - in some cases, for example, we may receive your email, address, phone number and postal address.
• Online information - for example, cookies and IP address (your computer's internet address), if you use our websites, apps and/or social media channels.
• Financial information - we may process information related to payments you make or receive in the context of an insurance policy or claim. We may process information regarding your income, expenses, assets, liabilities, investments, retirement and other financial provisions in the context of providing financial advice and intermediary services.
• Contractual information - for example, details about the policies you hold and with whom you hold them.
• Health information such as smoker status or medical-related issues relevant to a policy or a claim you have made.

In certain instances, we may need consent to process your personal information. If you give us your consent for a specific context, you are free to withdraw this consent at any time. Please note that where you have withdrawn your consent, this will not affect the processing that took place prior to such withdrawal and it will not affect the processing of your personal information where consent is not required.

You may refuse to provide us with your personal information in which case we may not be able to provide you with a relevant service or would have to terminate our business relationship. The supply of certain items of personal information, especially those collected to comply with regulation, is legally mandatory.

HOW WE USE YOUR INFORMATION

We have regulatory obligations, including compliance with anti-money laundering legislation, to process your personal information. This includes verifying your identity or the identity of your beneficial owner and/or controlling persons. We are also required by various laws to maintain a record of our dealings with clients.

In order for us to provide clients with the financial products and services they have requested and to notify them of important changes to such products and services, we need to collect, use and disclose the personal information of clients, their representatives, controlling persons of entities, business contacts, staff of clients and service providers:

• To the extent permissible under applicable laws, Sharenet may use your information:
• To provide you with our financial products and services, and maintain our relationship with you;
• To provide you with financial advice and intermediary services;
• To conclude and administer your application, which may include underwriting;
• To execute a transaction in accordance with your request;
• To assess, check, and process claims;
• To meet our contractual obligations with you or take steps necessary for the conclusion of a contract with you;
• In relation to administering any securities you may hold in respect of a Sharenet Group entity (where relevant);
• To comply with legislative and regulatory requirements, including codes of conduct and requirements of our regulators (including the Financial Sector Conduct Authority and Prudential Authority);
• To undertake credit reference searches and/or verification;
• For the detection and prevention of unlawful activity, fraud, money-laundering and loss, including as part of party due diligence required under applicable laws and in terms of Sharenet Group policies;
• For debt recovery or debt tracing;
• For purposes of online login and authorisation;
• To execute Sharenet's strategic initiatives;
• To perform any risk analysis or for purposes of risk management to you or our business in general;
• To record and/or monitor and have access to your telephone calls (i.e. voice recordings), correspondence and electronic communications to/with us (or any of our employees, agents or contractors) in order to accurately carry out your instructions and requests, to use as evidence and in the interests of crime prevention;
• To maintain the security of our digital channels and systems;
• For statistical analysis and research purposes;
• For audit and record-keeping purposes;
• For purposes of proof and legal proceedings;
• To enhance your experience when interacting with Sharenet and to help us improve our offerings to you;
• To share with other entities in Sharenet, so that we can market our financial products and services which we deem similar, with the aim of offering you the opportunity to take up some of the financial products to fulfil your needs, provided that you have not objected to receiving such marketing;
• To conduct market research and provide you with information about our products and services from time to time via email, telephone or other means (for example, invite you to events);
• To process your marketing preferences (where you have unsubscribed from certain direct marketing communications, keeping a record of your information and request to ensure that we do not send such direct marketing to you again);
• To prevent or control the spread of any disease; and
• For any purpose related to and compatible with the above.

SHARING YOUR INFORMATION

Entities within Sharenet will only share your personal information with third parties if there is a legitimate reason to do so. We may disclose the personal information you provide to us to the following entities:

• Our third-party service providers and other Sharenet Group entities who are involved in the delivery and/or administration of financial advice products and services;
• Other third parties in relation to the purposes set out under the previous section (How we use your information);
• Other insurers, public bodies and law enforcement (either directly or through shared databases) for fraud detection and prevention; and
• Reinsurers who provide reinsurance services to Sharenet and for each other. Reinsurers will use your personal information to decide whether to provide reinsurance cover, assess and deal with reinsurance claims, and to meet legal obligations.

Sharenet will process and share your personal information with other companies within Sharenet for the purpose of facilitating your membership to a loyalty or rewards programme. Your personal information may also be shared with third-party suppliers from time to time for the purpose of facilitating and providing benefits to you by way of a loyalty or rewards programme or when needed to fulfil our contractual obligations to you.

Sharenet will not sell, rent, or trade your personal information to any third party. Sharenet will share information about you with financial advisers that are Sharenet representatives or have intermediary agreements with Sharenet. Sharenet may also share information within Sharenet where it is in Sharenet's legitimate interest to do so.

Sharenet will disclose information when lawfully required to do so:

• To comply with any relevant legislation;
• To comply with any legal process; and
• By any regulatory authority (for example, the Financial Sector Conduct Authority or Prudential Authority).

On occasion, Sharenet may - for legitimate purposes - share aggregated information with its stakeholders and business partners (for example, demographic data) in a manner that does not identify the persons to whom the information applies. However, Sharenet will not disclose your personal information to third parties unless there is valid processing ground as set out in section 11 of POPIA.

TRANSFER ACROSS BORDERS

Some of the persons to whom we disclose your personal information may be situated outside of the Republic of South Africa (RSA) in jurisdictions that may not have similar data protection laws to the RSA. In this regard, we may send your personal information to service providers outside of the RSA for storage or processing on Sharenet's behalf. However, we will not send your information to a country that does not have information protection legislation similar to that of the RSA, unless we have ensured that the recipient agrees to effectively adhere to the principles for processing of information in accordance with POPIA.

SECURITY AND STORAGE OF INFORMATION

Sharenet intends to protect the integrity and confidentiality of your personal information. Sharenet has implemented appropriate technical and organisational information security measures to keep your information secure, accurate, current, and complete. However, we cannot guarantee the security of any information you transmit to us online and you do so at your own risk.

Where third parties are required to process your personal information in relation to the purposes set out in this notice and for other lawful requirements, we ensure that they are contractually bound to apply the appropriate security practices.

Your personal information will be held and used for as long as permitted for legal,regulatory, fraud prevention and legitimate business purposes.

RIGHT OF ACCESS TO INFORMATION

The Promotion of Access to Information Act (PAIA) coupled with POPIA offer an individual the right to access information held by a public or private body in certain instances. This right can be exercised in accordance with the Sharenet PAIA manual.

CORRECTION OF YOUR INFORMATION

In accordance with POPIA, you have a right to correct any of your personal information held by Sharenet. This right should be exercised in accordance with the procedure outlined in the Sharenet PAIA manual.

OBJECTION TO PROCESSING OF YOUR INFORMATION

In accordance with POPIA, you may object to our processing of your personal information on reasonable grounds relating to your particular situation, unless legislation provides for such processing.

MARKETING

Where you provide your personal information to a Sharenet Group entity in the context of a sale of one of our products or services, you agree to such Sharenet Group entity sending you information on news, trends, services, events and promotions for our own similar products and or services, always subject to your right to opt out of receiving such marketing at the time your information is collected and on each subsequent marketing communication thereafter. You may object to receiving direct marketing from Sharenet at any time by contacting the Sharenet Client Support Centre on 021 700 4800.

Where you choose to exercise your right to opt out of direct marketing, please allow up to 21 days for Sharenet to effect that change.

CLICKSTREAM DATA

In the interests of better customer service, Sharenet may collect anonymous information from visitors to its websites. For example, Sharenet keeps track of the domains from which people visit its website and also measures visitor activity on its website. In the process, Sharenet ensures the information cannot be used to identify you. This information is sometimes known as "clickstream data". Sharenet or its analytics vendors(including Google Analytics) may use this data to analyse trends and statistics and to provide better customer service.

The information, referred to as traffic data, which may be collected includes:

• Your IP address;
• The search terms you have used;
• The pages accessed on the website and the links you've clicked on;
• The date and time you visited the website;
• The referring website (if any) through which you clicked through to our website; and
• The type of website browser you use.

As mentioned, the traffic data is aggregated and not personally identifiable and our website analysis will also respect any ‘do not track' setting you might have on your web browser.

COOKIES

A cookie is a small text file that is downloaded onto ‘terminal equipment' (for example, a computer or smartphone) when you access a website. It allows the website to recognise your device and store some information about your preferences or past actions.

What cookies do we use?

Some cookies which we use are essential to the functioning of our website. Some cookies help us with the performance and design of our website. This allows us to measure how many times a page has been visited, whether a page has been visited on the website through an advertisement or by other means. Other cookies help us to remember your settings which you may have selected or assist with other functionality when you browse and use our website. This helps us to remember what you have selected, so on your return visit - we remember your preferences. On certain pages of the website we use cookies to help us understand your interests as you browse the internet, so we can tailor and render to you more personalised content and services in the future. This assists us in delivering relevant advertising to you during various advertising campaigns we may run from time to time through participating third-party sites.

In addition, we also use cookies on certain pages of our website to communicate with third-party data suppliers in order to extrapolate your digital behaviour. This helps us to understand and target more relevant advertising in the future. The information we receive is all aggregate and anonymous, but will include statistics such as demographics, online behaviour, product interests and lifestyle.

How do I disable cookies?

If you do not want to receive a cookie from the website, you have the option of setting your browser to notify you when you receive a cookie, so that you may determine whether to accept it or not. However, please be aware that if you do turn off 'cookies' in your browser, you will not be able to fully experience some of the features of the website. For example, you will not be able to benefit from automatic log-on and other personalisation features.

CHILDREN

While few, if any, of Sharenet's websites are directed towards children, Sharenet is committed to complying with all applicable laws aimed at the protection of children and in particular the protection of their personal information.

ACCEPTANCE

You must accept all the terms of this notice when you request our services. If you do not agree with anything in this notice, then you may not request our services.

You may not access our Websites or request our services if you are a minor or do not have legal capacity to conclude legally binding contracts. By accepting this notice, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

You may only send us your own Personal Information or the information of another data subject where you have their permission to do so.

UPDATES

This privacy statement was last updated on 1 June 2021. A notice will be posted on the Sharenet website home page whenever the Privacy Notice is materially changed.

Please check the website regularly to ensure that you are aware of the latest version of this Privacy Notice.

QUESTIONS REGARDING THIS STATEMENT

Questions, comments and requests regarding this statement may be directed to support@sharenet.co.za for clarification.

PARTICULARS OF SHARENET

Should you have a complaint or concern regarding the processing of your personal information, your complaint may be submitted to support@sharenet.co.za.

Our head office's registered address is:
Office 301 Imperial Terraces | Tyger Waterfront | Carl Cronje Drive | Bellville | Western Cape | South Africa | 7530.

For more information on Sharenet, please visit our website.

THE INFORMATION REGULATOR

Whereas we would appreciate the opportunity to first address any complaints regarding our processing of your personal information, you have the right to complain to the Information Regulator, whose contact details are:

The Information Regulator (South Africa)

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

P.O. Box 31533, Braamfontein, Johannesburg, 2017

Complaints email: complaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za

PAIA (Promotion of Access to Information Act) was passed into law to give effect to the constitutional right of access to information that is held by a private or public body and that is required for the exercise or protection of any rights. The Sharenet Group Limited (Sharenet) is a private body as defined in PAIA. Sharenet is bound by PAIA and will process any request made in terms thereof.

Any person who wishes to be given access to information that belongs to Sharenet or another customer/supplier of Standard Bank must follow the procedure set out below.

1. INTRODUCTION TO THE COMPANY (PTY) LTD

The Company conducts business as Sharenet (Pty) Ltd. We are an authorised financial services provider in terms of the Financial Advisory & Intermediary Service Act.

Our FSP license numbers for are as follows:

Sharenet Securities (Pty) Ltd : FSP number: 28430
Sharenet Wealth (Pty) Ltd : FSP number: 41688

2. COMPANY CONTACT DETAILS

3. THE ACT

3.1 The ACT grants a requester access to records of the Company, if the record is required for the exercise or protection of any rights. If a public body lodges a request, the public body must be acting in the public interest.

3.2 Requests in terms of the ACT shall be made in accordance with the prescribed procedures, at the rates provided. The forms and tariff are dealt with in paragraphs 6 and 7.

3.3 Requesters are referred to the Guide in terms of Section 10, which has been compiled by the South African Human Rights Commission, which will contain information for the purposes of exercising Constitutional Rights. The Guide is available from the SAHRC.

Division : PAIA UNIT
Physical Address : Braampark Forum 3
33 Hoofd Street, Braamfontein
Postal Address : Private Bag 2700, Houghton, 2041
Phone Number : 011 877 3600
Fax Number : 011 403 0668
Email : paia@sahrc.org.za
Website : www.sahrc.org.za

4. APPLICABLE LEGISLATION

4.1 The Company keeps records in accordance with the following legislation, all of which are available, subject to such legislation and the Act:

• Basic Conditions of Employment Act, No. 75 of 1997
• Companies Act, No. 71 of 2008
• Electronic Communications and Transactions Act, No. 25 of 2002
• Employment Equity Act, No. 55 of 1998
• Income Tax Act, No. 95 of 1967
• Labour Relations Act, No. 66 of 1995
• Promotion of Access to Information Act, No. 2 of 2000
• Unemployment Contributions Act, No. 4 of 2002
• Unemployment Insurance Act, No. 63 of 2001
• Value Added Tax Act, No. 89 of 1991

5. CATEGORIES OF RECORDS HELD

The following are the subject and categories of records held:

6. DETAILS ON HOW TO MAKE REQUESTS FOR ACCESS TO RECORDS HELD BY THE COMPANY

6.1 A requester requiring access to information held by the Company must complete the prescribed form available from SAHRC website (www.sahrc.org.za) or the Department of Justice and Constitutional Development (www.doj.gov.za) and submit it to the Public Officer at the address, or electronic mail address provided for above, and also make the payment of the prescribed fees. The request will not be processed until proof of payment is received. The account details are available upon request at the below contact details.

6.2 The prescribed form must be completed with enough particularity to enable the Public Officer to identify:

• 6.2.1 the record(s) requested;
• 6.2.2 the identity of the requester;
• 6.2.3 indicate which form of access is required, if the request is granted;
• 6.2.4 specify the postal address or fax number of the request in the Republic.

6.3 The requester must state which right she or he is seeking to exercise or protect and provide an explanation of why the requested record is required for the exercise or protection of such right.

6.4 The requester will be informed in writing whether access has been granted or denied. If, in addition, the requester requires the reasons for the decision in any manner, he/she must state the manner and the particulars if so required.

6.5 If a request is made on behalf of another person, then the requester must submit proof of the capacity in which the requester is making the request to the reasonable satisfaction of the Public Officer.

6.6 If an individual is unable to complete the prescribed form because of illiteracy or disability, such a person may make the request orally.

6.7 The Company will process the request within 30 days, unless the requester has stated special reasons which would satisfy the Public Officer that circumstances dictate that the above time periods not be complied with.

7. PRESCRIBED FEES

The following applies to requests (other than personal requests):

7.1 A requestor is required to pay the prescribed fees (R50.00) before a request will be processed;

7.2 If the preparation of the record requested requires more than the prescribed hours (six), a deposit shall be paid (of not more than one third of the access fee which would be payable if the request were granted);

7.3 A requestor may lodge an application with a court against the tender/payment of the request fee and/or deposit;

7.4 Records may be withheld until the fees have been paid.

7.5 The fee structure is available on the website of the SOUTH AFRICAN HUMAN RIGHTS COMMISSION at www.sahrc.org.za, or the website of THE DEPARTMENT OF JUSTICE AND CONSTITUTIONAL DEVELOPMENT (under regulations) at http://www.doj.gov.za/

7.6 Refer to Annexure 2.

8. GROUNDS FOR REFUSAL OF ACCESS TO RECORDS

The main reason(s) why the Company may refuse a request for information relates to the:

8.1 mandatory protection of the privacy of a third party who is a natural person, which would involve the unreasonable disclosure of personal information of that natural person (section 63);

8.2 mandatory protection of the commercial information of a third party, if the record contains:-

• 8.2.1 trade secrets of that third party;
• 8.2.2 financial, commercial, scientific or technical information which disclosure could likely cause harm to the financial or commercial interests of that third party;
• 8.2.3 information disclosed in confidence by a third party to the Company if the disclosure could put that third party at a disadvantage in negotiations or commercial competition (section 64);

8.3 mandatory protection of the safety of individuals and the protection of property (section 66);

8.4 mandatory protection of confidential information of third parties if it is protected in terms of any agreement (section 67);

8.5 mandatory protection of records which would be regarded as privileged in legal proceedings (section 67);

8.6 the commercial activities of the Company, which may include:-

• 8.6.1 trade secrets of the Company;
• 8.6.2 financial, commercial, scientific or technical information which disclosure of could likely cause harm to the financial or commercial interests of the Company;
• 8.6.3 information which, if disclosed could put the Company at a disadvantage in negotiations or commercial competition;
• 8.6.4 a computer program which is owned by the Company, and which is protected by copyright (section 68);

8.7 Requests for information that is clearly frivolous or vexatious, or which involve an unreasonable diversion of resources shall be refused.

9. REMEDIES AVAILABLE WHEN THE COMPANY (PTY) LTD REFUSES A REQUEST FOR INFORMATION

9.1 Internal Remedies

The Company does not have an internal appeal procedure. As such, the decision made by the Public Officer is final, and requesters will have to exercise such external remedies at their disposal if the request for information is refused, and the requester is not satisfied with the answer supplied by the Public Officer.

9.2 External Remedies

A requester that is dissatisfied with a Public Officer's refusal to disclose information, may within 30 days of notification of the decision, apply to a relevant Court for relief. Likewise, a third party dissatisfied with a Public Officer's decision to grant a request for information, may within 30 days of notification of the decision, apply to a Court for relief. For purposes of the Act, the Courts that have jurisdiction over these applications are the Constitutional Court, the High Court or another court of similar status.

9.3 Availability of this Manual

• 9.3.1 This manual is available for inspection by the general public upon request, during office hours and free of charge at the physical address of the Company.
• 9.3.2 Copies may also be requested from the SAHRC.

ANNEXURE 1 SCHEDULE OF FEES

The Promotion of Access to Information Act 2 of 2000 provides for two types of fees:

• 1. Request fee, a standard administration fee paid by all requestors except personal requestors. This is not refundable. See Part 4.
• 2. Access fee paid by all requestors intended to reimburse the institution for costs involved in searching for a record and preparing it for delivery to the requestor. This fee is calculated by taking into account reproduction costs, search and preparation time and cost, as well as postal costs.

Please note:

• The only charge that may be levied for obtaining records is a fee for reproduction of the record in question.
• An access fee is payable in all instances where a request for access to information is granted, except in those instances where payment of an access fee is specially excluded in terms of the Act or an exclusion is determined by the Minister in terms of Section 54(8).
• In terms of Regulation 8, Value Added Tax (VAT) must be added to all fees prescribed in terms of the Regulations.
• When the Information Officer receives the request, he/she shall notify the requester to pay the prescribed request fee (if any), before further processing of the request.
• The Information Officer may withhold a record until the requester has paid the fees.
• If a deposit has been paid in respect of a request for access, which is refused, then the information officer concerned must repay the deposit to the requester.

The Applicable Fees are as follows:

Sharenet takes every precaution to ensure that its systems are safe. This includes the use of firewalls on the network perimeter and on servers, virus protection systems, restricted access to our server environments and network monitoring. Where appropriate we also make use of secure connections to web browsers by means of 128 bit SSL encryption built into web browsers.

SITE PASSWORDS

When initially signing up with us we generate a totally random password for your use. You may change this password and if you do so please ensure it is difficult for anyone else to guess it, preferably by choosing a combination of letters and numbers and not using any words that can be found in a dictionary. We recommend that you never use the same password on any other site and that if you need to write it down or store it electronically that you ensure it is kept very safe.

TRADING PASSWORD

When signing up for any online trading facilities, you specify a password that is used when placing orders. This is a totally separate password to the one used for logging into the web site. You may change this password and if you do so please ensure it is difficult for anyone else to guess it, preferably by choosing a combination of letters and numbers and not using any words that can be found in a dictionary. We recommend that you never use the same password on any other site and that if you need to write it down or store it electronically that you ensure it is kept very safe. We also suggest that this password not be the same as your site password.

WHAT TO DO IF YOU SUSPECT A PROBLEM

If you suspect someone is using your login, immediately change you password(s) and contact us.

FUNDS TRANSFERS

As an added precaution, any requests to withdraw money from your online trading account will only be paid into the bank account you specified when you signed up for online trading.

Sharenet has been authorised to render financial services in respect of the following categories of financial products:

SHARENET WEALTH - FSP #41688

SHARENET SECURITIES - FSP #28430

OPENING AN INDIVIDUAL CLIENT ACCOUNT

Opening an individual investment account requires the following documentation:

1. Sharenet Mandate
2. Application Form (Completed and signed by the client)
3. Power of Attorney (Signed by the client).

Supporting Documentation (Original hardcopies are not required. If the client is not a South African resident, you must provide certified copies of your documentation. Sharenet may require further documentation at its discretion)

1. South African Barcoded Identity Document/card (Primary Identification); both pages/sides - All non-South African clients, copy of valid passport
2. Municipal Utility Bill as proof of residence (dated within 3 months of application to Sharenet)
3. Proof of Banking Details in the name of the Applicant i.e. Bank Statement, Cancelled Cheque or Letter from the Bank
4. W8BEN if the client is opening an offshore investment account

PLEASE NOTE:
Where ID is not available: Passport or Temporary ID document can be used together with a valid written explanation as to why SA ID is not available as they are Secondary Identification documents

Where utility bill is not available:

• Bank/ mortgage bond statement (dated within 3 months of application to Sharenet)
• Letter from Bank confirming residential address (dated within 3 months of application to Sharenet)
• Property Title Deed or Lease Agreement
• A telephone account (dated within 3 months of application to Sharenet)
• A valid television license document (applicable to SA Res only)
• An official document issued by Tax Authority (dated within 3 months of application to Sharenet)
• An account statement or invoice issued from an Accountable Institution obliged by law to identify and verify it's clients/customers (dated within 3 months of application to Sharenet)

OPENING A JOINT CLIENT ACCOUNT

Opening a joint investment account requires the following documentation:

1. Sharenet Mandate
2. Joint application form (Completed and signed by the clients)
3. Power of Attorney for each individual (Signed by the clients)

Supporting Documentation for each individual (Original hardcopies are not required. If the client is not a South African resident, you must provide certified copies of your documentation. Sharenet may require further documentation at its discretion)

1. South African Barcoded Identity Document/card (Primary Identification); both pages/sides - All non-South African clients, copy of valid passport
2. Municipal Utility Bill as proof of residence (dated within 3 months of application to Sharenet)
3. Proof of Banking Details in the name of the Applicant i.e. Bank Statement, Cancelled Cheque or Letter from the Bank
4. W8BEN if the client is opening an offshore investment account

PLEASE NOTE:
Where ID is not available: Passport or Temporary ID document can be used together with a valid written explanation as to why SA ID is not available as they are Secondary Identification documents

Where utility bill is not available:

• Bank/ mortgage bond statement (dated within 3 months of application to Sharenet)
• Letter from Bank confirming residential address (dated within 3 months of application to Sharenet)
• Property Title Deed or Lease Agreement
• A telephone account (dated within 3 months of application to Sharenet)
• A valid television license document (applicable to SA Res only)
• An official document issued by Tax Authority (dated within 3 months of application to Sharenet)
• An account statement or invoice issued from an Accountable Institution obliged by law to identify and verify it's clients/customers (dated within 3 months of application to Sharenet)

OPENING A CORPORATE ACCOUNT

Opening a corporate requires the following documentation:

1. Sharenet Mandate
2. Corporate application form (Completed and signed by the authorised individual).
3. Power of Attorney (Signed by the authorised individual).

Supporting Documentation (Original hardcopies are not required. Documentation for Corporates established outside of South Africa must be certified; Documentation for South African Corporates, South African directors and South African shareholders need not be certified. Sharenet may require further documentation at its discretion and is obliged to identify the entity down to ultimate beneficial owner)

1. Certificate of Incorporation
2. Change of name documentation (if applicable)
3. Memorandum of Incorporation / Memorandum & Articles of Association / Constitution (if applicable)
4. Register of Directors
5. Register of Shareholders (reflecting all shareholders with 20% or more of the voting rights at a general meeting of the entity)
6. Entity organogram for complex structures
7. Resolution/ Signatory Rules identifying those individual persons authorised to act on behalf of the entity ("Authorised Persons")
8. South African Barcoded Identity Document/card (Primary Identification; both pages/sides) for all Directors, Shareholders, Authorised Persons - All non-South African Directors and Shareholders, copy of passport
9. Utility bill as proof of residence for all Directors, Shareholders, Authorised Persons (dated in the last three months)
10. Utility bill Proof of registered address/operating address if not specified in the company documents already listed
11. Proof of Banking Details in the name of the Applicant i.e. Bank Statement, Cancelled Cheque or Letter from the Bank.

PLEASE NOTE:
Where ID is not available: Passport or Temporary ID document can be used together with a valid written explanation as to why SA ID is not available as they are Secondary Identification documents

Where utility bill is not available:

• Bank/ mortgage bond statement (dated within 3 months of application to Sharenet) Letter from Bank confirming residential address (dated within 3 months of application to Sharenet)
• Property Title Deed or Lease Agreement
• A telephone account (dated within 3 months of application to Sharenet)
• A valid television license document (applicable to SA Res only)
• An official document issued by Tax Authority (dated within 3 months of application to Sharenet)
• An account statement or invoice issued from an Accountable Institution obliged by law to identify and verify it's clients/customers (dated within 3 months of application to Sharenet)

Applicants that are unable to provide one of the above should contact Sharenet for further guidance.

Where a Director or Shareholder is an entity, please see FICA requirements dependant on entity type (Corporate/Trust) for that particular Director/Shareholder.

OPENING A TRUST ACCOUNT

Opening a trust account under requires the following documentation:

1. Sharenet Mandate
2. Trust application form (Completed and signed by the authorised individual).
3. Power of Attorney (Signed by the authorised individual).

Supporting Documentation (Original hardcopies are not required. Documentation for trusts established outside of South Africa must be certified; Documentation for South African trusts, South African trustees and South African beneficiaries need not be certified. Sharenet may require further documentation at its discretion and is obliged to identify the entity down to ultimate beneficial owner)

1. Trust Deed
2. Letter of Authority from Master of the High Court or other relevant authority (if applicable)
3. South African Barcoded Identity Document/card (Primary Identification; both pages/sides) for all Trustees, Named Beneficiaries as well as the Founder/Donor ^ - All non-South African Trustees/Beneficiaries/Founders/Donors, copy of passport
4. Utility bill as proof of residence for all Trustees, Named Beneficiaries, as well as the Founder/Donor (dated in the last three months) ^^
5. Proof of Banking Details in the name of the Applicant i.e. Bank Statement, Cancelled Cheque or Letter from the Bank
6. W8BENE (if this is an offshore investment)

PLEASE NOTE:
Where ID is not available: Passport or Temporary ID document can be used together with a valid written explanation as to why SA ID is not available as they are Secondary Identification documents

Where utility bill is not available:

• Bank/ mortgage bond statement (dated within 3 months of application to Sharenet)
• Letter from Bank confirming residential address (dated within 3 months of application to Sharenet)
• Property Title Deed or Lease Agreement
• A telephone account (dated within 3 months of application to Sharenet)
• A valid television license document (applicable to SA Res only)
• An official document issued by Tax Authority (dated within 3 months of application to Sharenet)
• An account statement or invoice issued from an Accountable Institution obliged by law to identify and verify it's clients/customers (dated within 3 months of application to Sharenet)
• Applicants that are unable to provide one of the above should contact Sharenet for further guidance.
• Where a Trustee or Beneficiary is an entity, please see FICA requirements for a Corporate for that particular Trustee/Beneficiary.

1.Introduction

1.1 The General Code of Conduct for Financial Services Providers and Representatives (the “Code”) published in terms of the Financial Advisory and Intermediary Services Act, No. 37 of 2002 (“FAIS”), requires every Financial Services Provider (“FSP”) to adopt, implement and maintain a Conflict of Interest Management Policy.

1.2 All Employees and Associates of Sharenet Investments (Pty) Ltd. as FAIS registered FSPs, (together “Sharenet”), must perform their duties independently and act in the best interests of Sharenet's existing and potential clients (“Clients”).

1.3 Sharenet has introduced reasonable mechanisms to identify Conflicts of Interest between:  

• itself, Employees and Clients; and
• between different Clients.

1.4 In considering potential Conflicts of Interest, Sharenet considers: (i) the structure and business activities of Sharenet; and (ii) any proposed new business activities of Sharenet.

1.5 Sharenet is obliged to render unbiased and fair financial services to Clients. Accordingly, we must take all reasonable steps to avoid any business activities and/or practices that may create Conflicts of Interest between Sharenet and Employee interests, and the interests of Clients. In the event that it is not possible to avoid a Conflict of Interest, Sharenet will take all reasonable steps to mitigate the impact as well as appropriately disclosing any such Conflict of Interest to Clients.

1.6 Defined terms not otherwise defined herein are listed in the Appendix.

2. Purpose of this Policy

The purpose of this Conflicts of Interest Management Policy is primarily to provide mechanisms for the identification and management of Conflicts of Interest that may arise in the rendering of financial services to Clients.

3. Application of this Policy

This Conflicts of Interest Management Policy applies to all Employees and must be read together with the related policies listed below, some of which reflect specific categories of Conflicts of Interest: 

• Gifts and Inducements;
• Outside Interests and Personal Account Investing;
• Insider Trading;
• Code of Ethics;
• Order Execution;
• Transaction Costs Disclosure;
• Counterparty and Credit Risk;
• Proprietary Trading (note: while Sharenet has a policy in place, it does not engage in any proprietary trading);

Mechanisms through which Sharenet identifies and manages actual or potential Conflicts of Interest

4.1 All Employees are required to report any potential or actual Conflicts of Interest to the Compliance Department. The onus is on every Employee to comply with this Policy. Should any individual be uncertain as to whether they are in a conflicted situation e.g.: whether the offer they wish to make or the offer which has been made to him/her, or whether a particular action or omission amounts to a Conflict of Interest, then he/she should contact the Compliance Department immediately. 

4.2 Every Department Head must, on an ongoing basis, identify any actual or potential Conflicts of Interest which may arise within his or her area. These must be reported to the Compliance Department. The Compliance Department maintains a Conflicts of Interest Register which is reviewed periodically with senior management to determine whether conflicts already identified are still valid, whether the mitigation strategies in place operate effectively and whether there are any new or potential conflicts that may have arisen since the last review.

4.3 The Compliance Department will investigate any potential or actual Conflicts of Interest to determine whether such conflicts are conflicts as contemplated in FAIS or any other applicable legislation. The Compliance Department, in conjunction with senior management, will determine whether such Conflicts of Interest are avoidable or unavoidable conflicts.

4.4 If a Conflict of Interest is identified as being avoidable, then Sharenet will adopt the necessary internal procedures to ensure that the activity that gives rise to the avoidable conflict, is avoided.

4.5 If a Conflict of Interest is identified as being unavoidable, the Compliance Department, in conjunction with senior management, will establish a strategy to mitigate the risk of such Conflict of Interest impacting negatively on Sharenet's ability to render fair and unbiased services to affected Clients.

4.6 Sharenet will disclose any specific Conflict of Interest impacting a Client to such impacted Client, together with the mitigation strategy employed.

4.7 Employees are encouraged to make use of the anonymous “whistleblowing hotline” which is available to all Employees, details of which appear in the Whistleblowing Policy and on the Compliance Home Page.

5. Guidelines in relation to Financial or Ownership Interests

No Employee may accept/give a Financial Interest or Ownership Interest from/to a Third Party, other than an Immaterial Financial Interest (refer to the Gifts and Inducements Policy).

Sharenet may not offer any Financial Interest to an Employee which incentivizes such Employee to:

• Give preference to the quantity of business over quality of service rendered to Clients;
• Give preference to a specific product supplier in the event that it is possible to recommend more than   one supplier to a Client; and/or
• Give preference to a specific product in the event that it is possible to recommend more than one  product to a Client.

No Employee may directly or indirectly refer any actual or potential item of designated investment business to another person on their own initiative or on instruction from Sharenet, if it is likely to conflict with any duty that Sharenet owes to its Clients or any duty which such recipient firm owes to its Clients.

6. Representative's entitlement to Financial Interest

As consideration for providing services to Clients, Representatives are entitled to remuneration by salary and other benefits in terms of their contracts of employments. No Employee may receive a Financial Interest that leads to a potential Conflict of Interest between the Employee and any Clients; 

No Employee may be remunerated in such a way that encourages that Employee to contravene this Policy.

7. Management of Conflicts of Interest

7.1  Once an actual or potential Conflict of Interest has been identified, it must be reported to the Compliance Department in the prescribed manner.

7.2 The Compliance Department will keep a record of all actual or potential Conflicts of Interest in the Conflicts of Interest Register.

7.3 The Compliance Department is responsible for monitoring Sharenet's adherence to the Conflicts of Interests Management Policy (as well as adherence to the policies relating to the identified categories of potential Conflicts of Interests).

7.4 All Employees are required to declare on an annual basis that they have complied with the Conflicts of Interests Management Policy and related policies.

7.5 The Conflicts of Interests Management Policy and related policies are reviewed annually, and where necessary, updated to ensure that the provisions remain sufficient to identify, assess, evaluate and mitigate Conflicts of Interest.

8. Consequences for non-compliance

If any Employee fails to comply with the contents of this Policy or avoids same through any means, it will be regarded as a breach of his/her employment contract. This will potentially render the individual liable to sanction under both the FAIS Act and Sharenet's disciplinary procedures.

9. Training of relevant Policies

All Employees must know and understand the Conflicts of Interest Management Policy as well as the policies relating to the identified categories of potential Conflicts of Interests. Appropriate training will be provided to all Employees on a periodic basis.

10. Acceptance and Publication of the Conflicts of Interest

The Board has adopted this Conflicts of Interest Management Policy as well as the policies relating to the identified categories of potential Conflicts of Interest. The Conflicts of Interest Management Policy is available to all Employees in the CFM Compliance Manual on the Compliance Home Page.

Appendix

Associate means in the case of a company, any subsidiary or holding company of that company, any other subsidiary of that holding company and any other company of which that holding company is a subsidiary.

Conflict of Interest means any situation in which Sharenet or an Employee has an actual or potential Interest that may, in rendering a financial service to a Client:

• Influence the objective performance of Sharenet's obligations to that Client; or
• Prevent Sharenet or an Employee from rendering an unbiased and fair financial service to that Client, or from acting in the interests of that Client.

Employee includes:

• A director
• An employee of any Sharenet group company, including a temporary employee and an employee employed on a fixed-term contract basis;
• Any investment vehicle (including a trust) in which an employee has an interest;

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:

• Training, that is not exclusively available to a selected group of providers or representatives, on products and legal matters relating to those products; but excluding travel and accommodation associated with that training;
• General financial and industry information; and
• Technological systems of a third party necessary for the rendering of a financial service 

Immaterial Financial Interest: means any financial interest with a determinable monetary value, the aggregate of which does not exceed ZAR1 000 in any calendar year in relation to the same Third Party in such calendar year.

Representative means any natural person who renders a financial service to a client for and on behalf of an FSP in terms of conditions of employment or any other mandate.

Ownership Interest means:

• Any equity or proprietary interest, other than equity or an proprietary interest held as an approved nominee on behalf of another person; and
• Includes any dividend, profit share or similar benefit derived from that equity or ownership interest.

Third Party means:

• A product supplier within the financial services industry
• A financial services provider (FSP)
• Any other service provider which provides or may potentially provide services
• All clients or potential clients for whom Sharenet renders a permitted financial service
• Securities issuers
• An associate of any of the above

This consent applies to clients registering and transacting directly on the Sharenet trading and investment platform (which includes Sharenet Securities (PTY) Ltd and Sharenet Wealth (PTY) Ltd)

1. Applying electronically
   
   

   If you decide to apply for a username or register for a product with SHARENET trading and investment platform, you agree to receive all account information and statements electronically.

2. Electronic communications
   
   

   All account documentation and statements and any notices, instructions, agreements, or any other communications regarding transactions and your account (all of which are referred to herein as the "Communications") may be presented, delivered, stored, retrieved, and transmitted electronically.

3. Executing transactions electronically
   
   

   The Agreement and Transactions will be executed using electronic records and electronic signatures.

4. Consenting to do business electronically
   
   

   The decision whether to do business electronically is yours, and you should consider whether you have the necessary hardware and software capabilities. Your consent to do business electronically, and our agreement to do so, only applies to the establishment and maintenance of your Account and the execution of transactions in connection with your Account.

5. Withdrawal of consent
   
   

   You have the right to withdraw your consent to doing business electronically at any time. However, if you withdraw such consent, any Communications or Transactions between us during the period after your consent to doing business electronically, and before your withdrawal of such consent, will be valid and binding on all parties.

6. Changes to your contact information
   
   

   You should keep us informed of any change in your electronic or mailing address or other contact information.

7. Printing
   
   

   You may print this document by selecting Print from the File menu.

8. Your ability to access communications
   
   

   When accepting our terms and conditions, you acknowledge that you have the capability to access the Communications.

9. Consent to electronic communications
   
   

   When accepting our terms and conditions, you consent to having all Communications provided or made available to you in electronic form.

10. Consent to executing transactions electronically
    
    

    When accepting our terms and conditions, you consent to executing the Agreement and Transactions by electronic record and/or electronic signature.

The web portal Sharenet has developed contains certain online programs, designed as 'self-help' tools for people who choose to personally and in the comfort of their own home or office, determine their investment and trading strategies and objectives.

As the nature of investing and trading involves certain elements of risk, we urge you to take the time to read, study and understand this disclaimer.

Should you make use of the Online tools on this site and make any investment decision based on the outcome of the tool, you choose not to make use of an expert adviser and accordingly accept full responsibility and assume all risk for any loss, harm or damage caused by your use and reliance on the information so provided by the online financial planning tools on this site.

You furthermore understand and accept that the acceptance of risk cover and underwriting is dependent on the accuracy and complete disclosure of the information required to be so disclosed by the site and/or telephone consultant tasked with activating your policies.

Obtaining expert advice is always recommended and we encourage all users, whether existing clients or not, to consult with their financial planner/adviser before making any decisions based on the outcomes or information generated by the tools or programs available on this website and its links.

As no advice is given for insurance or investment purposes and as the programs and tools are only designed to reflect potential outcomes based on the information you are responsible for accurately and honestly providing, Sharenet, its affiliates or holding company, including its directors, employees and contractors from time to time, do not accept any form of liability whatsoever, for any loss, liability or damage suffered, whether direct or consequential, resulting or ensuing from the use of or reliance on the programs, tools, online quote tools and information contained in this site or any links from this site.

Sharenet trading and investment platform always strives to stay abreast of the latest legislative and financial industry updates. We furthermore strive to correctly and accurately reflect all information. However, financial information is constantly changing and quickly becomes outdated. Accordingly, all information on this site is provided 'as is' and no warranties, either expressly or implied can be given that any information is up to date or accurate. We caution and urge any users of this site, to verify the information contained and obtained on this site. Any harm caused or loss suffered, whether direct or consequential, as a result of a reliance on the information or programs available on this site is disclaimed.

Should you not fully understand the nature, effect or any provisions of the above disclaimer, you are cautioned not to proceed until such time as you have had your financial adviser or legal adviser explain the effect and consequences of this disclaimer.

This publication has been issued by Sharenet trading and investment platform. It is confidential and issued for the information of clients only. It shall not be reproduced in whole or in part without our permission. The information contained herein has been obtained from sources which and persons whom we believe to be reliable but is not guaranteed for accuracy, completeness or otherwise. Opinions and estimates constitute our judgement as of the date of this material and are subject to change without notice. Past performance is not indicative of future results. This report is provided for informational purposes only. No information contained herein, no opinion expressed and no recommendation made constitutes a representation by us or a solicitation for the purchase of any of the securities mentioned herein and we have no responsibility whatsoever arising here from or in consequence hereof. Securities, financial instruments or strategies mention herein may not be suitable for all investors and investors must make their own investment decisions using their own advisers as they believe necessary and based upon their specific financial situations and investment objectives. The employees of Sharenet trading and investment platform may from time to time own securities mentioned herein. Analyst Certification The research analyst who prepared this report certifies that the view expressed herein accurately reflect the research analyst's personal views about the subject security and issuer and that no part of his compensation was, is or will be directly or indirectly related to specific recommendations or views contained in this report.

This publication has been issued by Sharenet trading and investment platform. It is confidential and issued for the information of clients only. It shall not be reproduced in whole or in part without our permission. The information contained herein has been obtained from sources which and persons whom we believe to be reliable but is not guaranteed for accuracy, completeness or otherwise. Opinions and estimates constitute our judgement as of the date of this material and are subject to change without notice. Past performance is not indicative of future results. This report is provided for informational purposes only. No information contained herein, no opinion expressed, and no recommendation made constitutes a representation by us or a solicitation for the purchase of any of the securities mentioned herein and we have no responsibility whatsoever arising here from or in consequence hereof. Securities, financial instruments or strategies mention herein may not be suitable for all investors and investors must make their own investment decisions using their own advisers as they believe necessary and based upon their specific financial situations and investment objectives. The employees of Sharenet may from time to time own securities mentioned herein. Analyst Certification The research analyst who prepared this report certifies that the view expressed herein accurately reflect the research analyst's personal views about the subject security and issuer and that no part of his compensation was, is or will be directly or indirectly related to specific recommendations or views contained in this report.

Sharenet trading and investment platform terms and conditions

By your acceptance of the Sharenet Securities (PTY) Ltd and Sharenet Wealth (PTY) Ltd Terms and Conditions, you hereby accept the conditions of this agreement and the standard conditions of www.sharenet.co.za (-the Site-) and agree as follows:

1. By utilising any services on this Site, you the user, agree that you have reviewed the Site in its entirety, that you have accepted the terms and conditions applicable to the services, including all legal and regulatory terms and are conversant with and understand such terms and conditions and the applicable local legislation and regulations. Details of the terms of use of the Site can be found on the Site.

Should you have a complaint against a representative of Sharenet, which you can't settle with us, please address your grievance in writing to the FAIS Ombud, which is there to provide redress-mechanisms regarding inappropriate and inadequate financial services and related issues.

FAIS OMBUD
PO Box 74571
Lynnwood Ridge
0040
Tel +27 (12) 470 9080
Fax +27 (12) 348 3447

Compliance with the FAIS Act is monitored by an FSCA authorised Compliance Officer, Etude Compliance Services who is contactable on Tel: +27 (21) 852 6667 or email: info@etude.co.za.

SHARENET GROUP ORDER EXECUTION POLICY (the Policy)

About best execution Introduction

This Policy applies to SHARENET’s execution of orders on behalf of retail clients and professional clients according to the Rules, as defined below.

Upon acceptance of a client order and when there is no specific client instruction regarding the execution method, SHARENET will execute an order in accordance with this Policy.

This Policy is subject to SHARENET’s General Business Terms and other business terms from time to time, governing the relationship between the client and SHARENET.

When dealing with clients, SHARENET has a general duty to act honestly, fairly, professionally and in the best interest of the client.

In relation to order execution, SHARENET is required to take all reasonable steps to obtain the best possible result when executing client orders or when placing orders with, or transmitting orders to, other entities to execute.

Your agreement to this Policy

This Policy has been provided to help clients understand how SHARENET executes client orders so that they can make an informed choice on whether to use SHARENET’s services. You should ensure that you have read and understood its contents.

If you proceed to place an order with us, we will take that as your consent to SHARENET executing that order in accordance with this Policy.

What does SHARENET mean by ‘best execution’?

Best Execution is the process by which SHARENET’s prime broker seeks to obtain the best possible result when executing client orders. The definition of best possible result will vary as SHARENET’s prime broker must take into account a range of execution factors and determine their relative importance based on the characteristics of its clients, the orders that it receives and the markets in which it operates. These factors are further described in this Policy.

Execution factors

SHARENET has considered a number of criteria that might be important to clients. These are called the Execution Factors:

• Price – the market price at which the order is executed
• Costs – any additional charges that may be incurred in executing the order in a particular way, over and above SHARENET’s normal charges
• Speed of execution – this can be particularly important in fast moving mark
• Size and Nature of the transaction – the way that SHARENET’s prime broker executes an unusual order (for example, one that is larger than the normal market size or has unusual features such as an extended or shortened settlement period) may differ from the way it executes a standard order
• Market Impact – the effect that executing a client’s order, or showing it to other market participants, might have upon the market
• Other factors relevant to particular order types – as applicable.

When SHARENET’s prime broker executes orders on behalf of clients, Best Execution is determined on the basis of the total consideration paid to or by the client, unless the objective of execution of the order dictates otherwise. Total consideration is the price of the financial instrument and the costs related to execution, including all expenses incurred by the client which are directly related to the execution of the order such as venue execution fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order. When assessing whether best execution has been achieved, SHARENET does not take account of its standard charges that will be paid by the client irrespective of how the order is executed.

Execution criteria

The relative importance that SHARENET’s prime broker attaches to the Execution Factors in any particular case may be affected by the circumstances of the order.

These are called the Execution Criteria.

• Client Characteristics – professional customers may have different needs to retail customers
• Transaction Characteristics – such as the potential for it to have an impact on the market
• Financial Instrument Characteristics – such as liquidity and whether there is a recognised centralised market
• Venue Characteristics – particular features of the liquidity sources available to SHARENET
• Other relevant circumstances – as applicable.

Execution venues

Based on its assessment of the Execution Factors and the Execution Criteria, SHARENET’s prime broker will select one or more venue(s) for the execution of the client’s order. Venues used might include:

• Regulated Markets
• Multilateral Trading Facilities
• Order Crossing Networks and other electronic platforms
• Liquidity provided from SHARENET’s prime brokers internal flow aggregation book
• Other brokers, dealers and market makers

SHARENET’s prime broker will take reasonable care not to discriminate between execution venues other than on the basis of the Execution Factors relevant to the order concerned.

Where executing orders against liquidity provided by its own internal flow aggregation book, SHARENET’s prime broker will aggregate the risk from client transactions with risks arising on other clients’ orders and will undertake hedging activities at other dealing venues in the manner that it considers to be most efficient.

The prices that SHARENET’s prime broker makes available to clients under this model will be based upon the prices available to it from its selected hedging venues.

SHARENET’s prime broker has access to a number of exchanges and other execution venues through its order routing vendors.

When does best execution apply?

Best execution applies when SHARENET’s prime broker executes a transaction on behalf of a client in financial instruments and products as defined by the Rules including:

• Bonds
• Cash Equities
• CFD Equities
• CFD Indices
• CFD Commodities
• Futures
• Listed Options
• Rolling Foreign Exchange Spot
• Foreign Exchange Forward
• Foreign Exchange Options

When does best execution NOT apply?

Best execution does not apply to:

• Spot foreign exchange transactions undertaken with the intention of converting money from one currency to another – including transactions undertaken to facilitate settlement of other transactions
• Transactions arising from the exercise of an option. SHARENET’s prime broker will treat an instruction to exercise an option as a specific instruction from the client to exercise their rights under the option contract and will not take account of the state of the underlying market at the time.

Risks of dealing in volatile markets

Clients should be aware of the following risks associated with volatile markets, especially at or near the open or close of the standard trading session:

• Execution at a substantially different price from the quoted bid or offer or the last reported price at the time of order entry, as well as partial executions or execution of large orders in several transactions at different prices
• Delays in executing orders for financial instruments that SHARENET’s prime broker must send to external market makers and manually routed or manually executed orders
• Opening prices that may differ substantially from the previous day’s close
• Locked (the bid equals the offer) and crossed (the bid is higher than the offer) markets, which may prevent the execution of client orders.
• Price volatility is one factor that can affect order execution. When there is a high volume of orders in the market, order imbalances and back logs can occur. This implies that more time is needed to execute the pending orders. Such delays are usually caused by the occurrence of different factors:

(i) the number and size of orders to be processed,

(ii) the speed at which current quotations (or last-sale information) are provided to SHARENET and/or SHARENET’s prime broker and other brokerage firms; and,

(iii) the system capacity constraints applicable to the given exchange, as well as to SHARENET and other firms.

SHARENET is obligated to take necessary steps to keep an orderly market; therefore, SHARENET’s prime broker operates with “Compliance” order filters. Such Compliance order filters are also present at exchanges and other brokers that might be used by SHARENET to route the order to the designated market. The filters might result in orders with a large expected market impact to be paused or traded using an algorithm potentially causing slippage from the expected arrival price. Stop orders are also at SHARENET’s prime brokers discretion grouped into larger orders and then traded as an algorithm to prevent cascading market impact or large market impact in general. SHARENET and/or SHARENET’s prime broker cannot be held liable for price slippage caused by acting to keep an orderly market.

Regular review

SHARENET’s prime broker will review this Policy annually and whenever a material change occurs that affects SHARENET’s ability to obtain the best possible result for the execution of client orders.

SHARENET’s prime broker regularly reviews the overall quality of its order executions and its order routing practices, including its order routing vendors and the available exchanges. SHARENET’s prime broker will amend this Policy on the basis of such reviews if it considers it to be necessary. Any new policy will be made available on SHARENET’s websites and will be in force as from publication.

About SHARENET’s charges

SHARENET charges for its services. These may vary depending on factors such as the service it is providing to the client; the manner in which they are used; and the pricing plan that the client has agreed to. Details of SHARENET’s charges are available on its website. Where SHARENET’s prime broker provides liquidity from its internal flow aggregation book, SHARENET’s prime broker will provide the client with a two-way dealing price. In normal circumstances, the difference between the bid price (at which SHARENET’s prime broker is willing to buy) and the ask price (at which it is willing to sell) will constitute part of its charges for the service SHARENET provides. For the purpose of assessing whether it has achieved Best Execution, SHARENET will not take its standard charges that apply to a client’s transactions irrespective of the venue at which they are executed into account. SHARENET will, however, take account of any charges levied by a third party or incorporated into its prices to reflect cost differentials of dealing at different execution venues.

Specific instructions

Clients may ask SHARENET to execute their orders in accordance with specific instructions – either generally or on a case-by-case basis. To the extent that SHARENET is able to accommodate such requests, it will do so. However:

• Where the specific instructions will result in higher costs, SHARENET may reflect those additional costs in its charges to the client. In this case, SHARENET will notify the client of its revised charges before accepting the order(s)
• Where the specific instructions conflict with its normal processes, SHARENET will give the specific instructions precedence. This may result in a different outcome for the transaction
• Where there is no conflict, SHARENET will continue to follow its normal execution Policy.

Direct market access

Clients may ask SHARENET to provide them with direct access to the market. SHARENET will treat this as a Specific Instruction from the client and will accordingly consider whether it is able to do this and on what terms.

Where SHARENET provides clients with direct market access, SHARENET’s prime broker will select one or more execution venues that it believes will provide the best outcomes for that client’s transactions. This may be a different selection of venues than it otherwise uses for execution of similar transactions or for its own hedging purposes. This may result in a different outcome for the client’s transactions.

Dealing on quotes

When trading OTC derivatives with SHARENET, clients are trading on SHARENET’s prime broker’s price. There are a number of factors that can be used to construct a derivative price, and these will vary depending on the asset class traded, the nature of the market and the characteristics and terms of the transaction and any special market or credit risks posed by it. SHARENET’s prime broker applies a standardised method of calculation for these types of derivatives to ensure that the price that it is offering at any given time is always considered the best price it can obtain on the client’s behalf. In monitoring best execution for these types of instruments, SHARENET’s prime broker will monitor the calculation method to ensure that it is applied consistently at all times.

About markets

The following schedules set out the specific details relating to the markets in which clients can trade with SHARENET:

Schedule 1: Bonds Products in scope:

Purchase and sale of global Bonds

Order types available

• Market order
• Limit Order

SHARENET’s prime broker selected venue

Bonds are normally traded on an inter-dealer basis. SHARENET’s prime broker may source liquidity from:

• Orders that it is working for other clients;
• Its own trading book;
• Other dealers in the market

OFFLINE TRADING:

SHARENET’s prime broker trades as a principal to bond trades with clients. In exceptional circumstances, for instance when working large orders in highly illiquid bonds, SHARENET’s prime broker may execute an order as agent.

Pricing and execution of Bonds is a manual process, with many orders still negotiated over the telephone. The market is characterised by indicative OTC prices. For bonds traded offline SHARENET’s prime broker splits all bonds into one of three baskets based on the relevant bond’s liquidity. For highly liquid bonds, SHARENET’s prime broker will offer a bid/offer price equal or better than that shown in any attainable firm market (this includes public exchanges to which SHARENET has access, as well as OTC counterparts). For bonds with lower liquidity, SHARENET’s prime broker will source a minimum of three separate indicative prices to gauge the best price based on the order size. For highly illiquid bonds, SHARENET’s prime broker seeks to derive a mid-price based on all indicative pricing information available to it, and then quotes a bid/offer spread to the client factoring in a predefined additional spread.

ONLINE TRADING:

SHARENET’s prime broker trades as a principal towards the client, however with the technology and connectivity available for the bonds traded online, the execution methodology is different from offline. Bonds traded via SHARENET’s prime broker’s online bond offering, are carefully selected based on sustainable liquidity, hence sufficient indicative prices and active dealers.

The Client can place a market order, where SHARENET’s indicative composite price will work as the upper (buy)/lower (Sell) limit. The indicative composite price is made up from several indicative price data points and remodelled to reflect the real firm market as much as possible. The pricing model strives towards a high execution ratio (90- 95%) but at the same time to appear as competitive as possible.

Each client order is automatically routed to a multi-dealer RFQ competition where a number of dealers are selected automatically, prioritized according to their indicative prices. Other parameters also decide the prioritization, based on historic data and the relevance of the dealers’ indicative price as well as speed of quoting a firm price. All parameters are changeable and optimized with the single aim of having the best price possible, within a given timeframe.

When receiving firm live pricing from the multi-dealer RFQ competition, the algorithm will take into consideration:

-      Number of firm quotes (at least 2 – up to 6)

-      Time to Fill the order (a maximum of between 30-45 seconds depending on market)

When at least 2 firm prices have been achieved within the timeframe of 30-45 seconds, the algorithm compares the prices to the maximum limit price (the indicative composite price) and executes on the best firm price if that is better than or equal to the limit price.

If no prices are better than or equal to the limit, or if only one quote comes up, the order is killed after 30- 45 seconds (depending on market). The order is hereafter cancelled automatically.

Clients are able to place limit orders on selected European exchanges, and such orders are automatically routed to Banca IMI Market HUB. The limit order function exists for certain bonds which are expected to have sufficient liquidity on the relevant exchanges. The benchmark for the order will reflect the price action seen on the exchange and Market Hub’s smart order exchange routing platform.

Clients may experience that their order is not done, despite placed on the most relevant exchange and indications in OTC prices that the order should be done. This is due to the fact that exchanges often lack liquidity and are not yet the preferred vehicle for bond trading.

When at least 2 firm prices have been achieved within the timeframe of 30-45 seconds, the algorithm compares the prices to the maximum limit price (the indicative composite price) and executes on the best firm price if that is better than or equal to the limit price.

If no prices are better than or equal to the limit, or if only one quote comes up, the order is killed after 30- 45 seconds (depending on market). The order is hereafter cancelled automatically.

Clients are able to place limit orders on selected European exchanges, and such orders are automatically routed to Banca IMI Market HUB. The limit order function exists for certain bonds which are expected to have sufficient liquidity on the relevant exchanges. The benchmark for the order will reflect the price action seen on the exchange and Market Hub’s smart order exchange routing platform.

Clients may experience that their order is not done, despite placed on the most relevant exchange and indications in OTC prices that the order should be done. This is due to the fact that exchanges often lack liquidity and are not yet the preferred vehicle for bond trading.

Relevant execution factors

The ranking of execution factors for bonds is:

1.      Price
2.      Expected impact of execution
3.      Likelihood of execution and settlement
4.      Order size & typet
5.      Costst
6.      Speed
7.      Other factors Schedule 2: Cash equities Products in scope:

Purchase and sale of cash equities and equity-like products.

Not in scope:

Transactions arising from the exercise of an option

Order types available

•      Market order

With a market order, the client instructs a financial institution or trading counterparty to execute a trade of a certain size as promptly as possible at the prevailing market price. Financial institutions are required to execute market orders without

regard to price changes. Therefore, if the market price moves significantly during the time it takes to fill a client’s order, the order will most likely be exposed to the risk of execution at a price substantially different from the price when the order was entered. Certain exchanges do not support market orders. If the client places a market order in these markets, SHARENET’s prime broker will automatically translate the order to an aggressive limit order within a certain percentage limit “in the money”. It is the client’s own responsibility to check if the order is traded in the market after order entry. If the client experiences or suspects any errors with his/her order the client should contact SHARENET immediately.

Orders may be traded using an algorithm, which has the potential to cause slippage from the expected arrival price. This is done by SHARENET’s prime broker in an attempt to prevent large market impact and live up to our obligations to keep an orderly market. SHARENET and/or its prime broker cannot be held responsible for missing fills when using such algorithms to minimize market impact.

•      Limit order

With a limit order, the client sets the maximum purchase price, or minimum sale price, at which the trade is to be executed. As a limit order may be entered away from the current market price, it may not be executed immediately. A client that leaves a limit order must be aware that he/she is giving up the certainty of immediate execution in exchange for the expectation of getting an improved price in the future. Limit orders may be routed to an exchange without human intervention.

Where a limit order is placed in a share admitted to trading on a regulated market, SHARENET’s prime broker shall not be obliged to publish that limit order if it cannot be immediately executed under prevailing market conditions.

•      Immediate or cancel (IOC)

An immediate or cancel order (IOC) is an order to buy or sell that must be executed immediately, and any portion of the order that cannot be immediately filled is cancelled. IOC order may fill completely or partially, or it may not fill at all.

•      Stop order

Different from a limit order, a stop order allows selling below the current market price or buying above the current market price if the stop price is reached or breached. A stop order is therefore a “sleeping” market order until the stop price is reached or breached.

•      Trailing stop order

The trailing stop order is a stop order as described above, but the trailing stop price moves according to parameters set by the client. This way the trailing stop can be used to sell if the price drops more than a specified distance from the highest price traded or to buy if the price trades above a set level from the lowest traded price.

•      Stop limit order

A stop limit order is a variation of a stop order as described above with a lower (higher) limit price to suspend trading if the price falls (rises) too far before the order is filled restricting trading to a predefined price range.

•      Algorithmic order

An Algorithmic Order is an order executed by an automated strategy according to specific parameters or conditions. Algorithmic Orders are intended to minimize the market impact created from placing larger orders or achieving a recognized trading benchmark such as VWAP etc. The orders can also be used to follow a volume participation or in general to achieve a better overall execution. SHARENET facilitates a number of different algorithmic order types..

Given the risks that arise when trading in volatile markets, the client may want to consider using different types of orders to limit risk and manage investme6nt strategies.

Relevant execution factors

SHARENET trades as agent with respect to cash equity trades with clients. SHARENET’s prime broker has access to a number of Smart Order Routers that are able to check multiple different execution venues when trying to execute a cash equity order. Not only does this allow SHARENET to potentially access better prices, it also gives access to additional liquidity, meaning that there is a greater likelihood of obtaining an execution. The ranking of execution factors for cash equities are:

1.      Price
2.      Expected impact of execution
3.      Likelihood of execution and settlement
4.      Costs
5.      Speeds
6.      Other factors

Price formation

Prices are determined on the different venues to which orders may be routed by SHARENET’s prime broker’s Smart Order Routers.

Schedule 3: CFD Equities Products in scope:

Purchase and sale of contracts for differences based on individual shares.

Order types available

•      Market order

With a market order the client instructs a financial institution or trading counterparty to execute a trade of a certain size as promptly as possible at the prevailing market price. Financial institutions are required to execute market orders without regard to price changes. Therefore, if the market price moves significantly during the time it takes to fill a client’s order, the order will most likely be exposed to the risk of execution at a price substantially different from the price when the order was entered. Certain exchanges do not support market orders. If the client places a market order in these markets, SHARENET’s prime broker will automatically translate the order to an aggressive limit order within a certain percentage limit “in the money”. It is the client’s own responsibility to check if the order is traded in the market after order entry. If the client experiences or suspects any errors with his/her order the client should contact SHARENET immediately.

Orders may be traded using an algorithm potentially causing slippage from the expected arrival price. This is done by SHARENET’s prime broker in an attempt to prevent large market impact and live up to our obligations to keep an orderly market. SHARENET and/or its prime broker cannot be held responsible for missing fills when using such algorithms to minimize market impact.

• Limit order

With a limit order, the client sets the maximum purchase price, or minimum sale price, at which the trade is to be executed. As a limit order may be entered away from the current market price, it may not be executed immediately. A client that leaves a limit order must be aware that he/she is giving up the certainty of immediate execution in exchange for the expectation of getting an improved price in the future. Limit orders may be routed to an exchange without human intervention.

Where a limit order is placed in a share admitted to trading on a regulated market, SHARENET’s prime broker shall not be obliged to publish that limit order if it cannot be immediately executed under prevailing market conditions.

•      Immediate or cancel (IOC)

An immediate or cancel order (IOC) is an order to buy or sell that must be executed immediately, and any portion of the order that cannot be immediately filled is cancelled. IOC order may fill completely or partially, or it may not fill at all.

•      Stop order

Different from a limit order, a stop order allows selling below the current market price or buying above the current market price if the stop price is reached or breached. A stop order is therefore a “sleeping” order until the stop price is reached or breached.

•      Trailing stop order

The trailing stop order is a stop order as described above but the trailing stop price moves according to parameters set by the client. This way the trailing stop can be used to sell if the price drops more than a specified distance from the highest price traded or to buy if the price trades above a set level from the lowest traded price.

•      Stop limit order

A stop limit order is a variation of a stop order as described above with a lower (higher) limit price to suspend trading if the price falls (rises) too far before the order is filled restricting trading to a predefined price range.

• Algorithmic order

An Algorithmic Order is an order executed by an automated strategy according to specific parameters or conditions. Algorithmic Orders are intended to minimize the market impact created from placing larger orders or achieving a recognized trading benchmark such as VWAP etc. The orders can also be used to follow a volume participation or in general to achieve a better overall execution.

Given the risks that arise when trading in volatile markets, the client may want to consider using different types of orders to limit risk and manage investment strategies.

Relevant execution factors

SHARENET’s prime broker trades as a principal to CFD equity trades with clients. CFD equity orders are handled in the same manner as cash equity orders because SHARENET’s prime broker will route its hedge trade against CFD equity orders directly to the market in the same way as it would route a client’s cash equity trade. As a result, the ranking of execution factors is the same.

1. Price
2. Expected impact of execution
3. Likelihood of execution and settlement
4. Costs
5. Speed
6. Other factors

SHARENET’s selected venue

In many cases, SHARENET’s prime broker hedges the CFDs that it enters into with clients using cash equities. SHARENET’s prime broker executes these hedges in the same way that it would execute a transaction for that client in the cash equity concerned.

Price formation

Where SHARENET’s prime broker executes a hedge in the underlying equity, the price the client receives will be the price at which it hedges plus or minus any pre-agreed charges.

Schedule 4: CFD Indices Products in scope:

CFDs based on stock indices.

Order types available

•      Market order

With a market order the client instructs a financial institution or trading counterparty to execute a trade of a certain size as promptly as possible at the prevailing market price. Financial institutions are required to execute market orders without

regard to price changes. Therefore, if the market price moves significantly during the time it takes to fill a client’s order, the order will most likely be exposed to the risk of execution at a price substantially different from the price when the order was entered.

•      Limit order

With a limit order, the client sets the maximum purchase price, or minimum sale price, at which the trade is to be executed. As a limit order may be entered away from the current market price, it may not be executed immediately. A client that leaves a limit order must be aware that he/she is giving up the certainty of immediate execution in exchange for the expectation of getting an improved price in the future. Limit orders may be routed to an exchange without human intervention.

•      Immediate or cancel (IOC)

An immediate or cancel order (IOC) is an order to buy or sell that must be executed immediately, and any portion of the order that cannot be immediately filled is cancelled. IOC order may fill completely or partially, or it may not fill at all.

•      Stop order

Different from a limit order, a stop order allows selling below the current market price or buying above the current market price if the stop price is reached or breached. A stop order is therefore a “sleeping” market order until the stop price is reached or breached.

•      Trailing stop order

The trailing stop order is a stop order as described above but the trailing stop price moves according to parameters set by the client. This way the trailing stop can be used to sell if the price drops more than a specified distance from the highest price traded or to buy if the price trades above a set level from the lowest traded price.

•      Stop limit order

A stop limit order is a variation of a stop order as described above with a lower (higher) limit price to suspend trading if the price falls (rises) too far before the order is filled, restricting trading to a predefined price range.

Given the risks that arise when trading in volatile markets, the client may want to consider using different types of orders to limit risk and manage investment strategies.

Spread filters

In order to ensure that the client’s Stop Orders are not filled at unreliable prices during short-termed periods with abnormally wide bid/ask spreads caused by for instance release of key economic figures SHARENET’s prime broker has implemented spread filters preventing order execution when spreads exceed certain levels. Having the spread filters in place will in general benefit the client, but can, in rare instances, be unfavourable for the client.

Relevant execution factors

SHARENET’s prime broker as a principal to CFD Index, trades with clients. CFD Index prices are derived from the relevant underlying index price, taking into account the cost of carry. SHARENET’s prime broker calculates its own cost of carry that factors in future expectations of dividends and interest rates, and this can include both internal and external inputs.

Please see the section on DEALING ON QUOTES in the main document for more information on trading OTC derivatives and best execution monitoring. For CFD indices the ranking of applicable execution factors is:

1.      Price
2.      Expected impact of execution
3.      Likelihood of execution and settlement
4.      Costs
5.      Speed
6.      Other factors

SHARENET’s prime broker’s selected venue

All orders in CFD Indices are executed against SHARENET’s prime broker’s own liquidity.

Price formation

CFD Index prices are SHARENET’s prime broker’s proprietary prices, which are derived from the relevant underlying Index price, taking into account, the cost of carry and liquidity. SHARENET’s prime broker calculates its own cost of carry that factors in future expectations of dividends and interest rates, and this can include both internal and external inputs.

Schedule 5: CFD Commodities Products in scope:

CFDs based on commodity futures

Order types available

•      Market order

With a market order, the client instructs a financial institution or trading counterparty to execute a trade of a certain size as promptly as possible at the prevailing market price. Financial institutions are required to execute market orders without

regard to price changes. Therefore, if the market price moves significantly during the time it takes to fill a client’s order, the order will most likely be exposed to the risk of execution at a price substantially different from the price when the order was entered. Certain exchanges do not support market orders. If the client places a market order in these markets, SHARENET’ prime broker will automatically translate the order to an aggressive limit order within a certain percentage limit “in the money”. It is the clients’ own responsibility to check if the order is traded in the market after order entry. If the client experiences or suspects any errors with his/her order the client should contact SHARENET immediately. Some of SHARENET’s prime broker’s third-party execution brokers may choose to translate market orders on various markets into aggressive limit orders. This is often a result of ex- change rules applied to protect clients from “bad fills”.

SHARENET and/or its prime broker cannot be held responsible for missing fills due to such translation performed by third party execution brokers:

•      Limit order

With a limit order, the client sets the maximum purchase price, or minimum sale price, at which the trade is to be executed. As a limit order may be entered away from the current market price, it may not be executed immediately. A client that leaves a limit order must be aware that he/she is giving up the certainty of immediate execution in exchange for the expectation of getting an improved price in the future. Limit orders may be routed to an exchange without human intervention.

•      Immediate or cancel (IOC)

An immediate or cancel order (IOC) is an order to buy or sell that must be executed immediately, and any portion of the or- der that cannot be immediately filled is cancelled. IOC order may fill completely or partially, or it may not fill at all.

•      Stop order

Different from a limit order, a stop order allows selling below the current market price or buying above the current market price if the stop price is reached or breached. A stop order is therefore a “sleeping” order until the stop price is reached or breached.

•      Trailing stop order

The trailing stop order is a stop order as described above but the trailing stop price moves according to parameters set by the client. This way the trailing stop can be used to sell if the price drops more than a specified distance from the highest price traded or to buy if the price trades above a set level from the lowest traded price.

•     Stop limit order

A stop limit order is a variation of a stop order as described above with a lower (higher) limit price to suspend trading if the price falls (rises) too far before the order is filled restricting trading to a predefined price range.

Given the risks that arise when trading in volatile markets, the client may want to consider using different types of orders to limit risk and manage investment strategies.

Spread filters

In order to ensure that the client’s Stop Orders are not filled at unreliable prices during short-termed periods with abnormally wide bid/ask spreads caused by for instance release of key economic figures, SHARENET’s prime broker has implemented spread filters preventing order execution when spreads exceed certain levels. Having the spread filters in place will in general benefit the client but can, in rare instances, be unfavourable for the client.

Relevant execution factors

SHARENET’s prime broker trades as principal to CFD commodity trades with clients. CFD Commodity prices are SHARENET’s prime broker’s proprietary prices, which are derived from the relevant underlying instrument price, taking into account the cost of carry and liquidity which is calculated by SHARENET’s prime broker and includes both internal and external input. Please see the section on DEALING ON QUOTES in the main document for more information on trading OTC derivatives and best execution monitoring.

For CFD Commodities, the ranking of execution factors is:

1.     Price
2.     Expected impact of execution
3.     Likelihood of execution and settlement
4.     Costs
5.     Speed
6.     Other factors

SHARENET’s prime broker’s selected venue

SHARENET’s prime broker acts as market maker for CFD commodity contracts.

Price formation

The mid-price of CFD Commodities is a proprietary price derived by SHARENET’s prime broker and will generally track that of the relevant underlying exchange traded market. Because there is only one exchange on which to trade the financial instrument that underlies these derivatives, SHARENET’s prime broker will consider its price ‘correct’ when it is in line with the underlying future. There is no opportunity to ‘shop around’ for price improvement in these markets, due to the fact that there is only a single execution venue.

Schedule 6: Futures Products in scope:

Purchase and sale of Futures for speculative and hedging purposes

Not in scope:

SHARENET and/or its prime broker do not support physical delivery of the underlying security on expiry of a futures.

Therefore, SHARENET advises clients to take note of the expiry and first notice dates (FND) of any futures in which they have positions and ensure they are closed before the appropriate day, as described below.

If the FND is before the expiry date, positions need to be closed the day before the FND. If the expiry date is before the FND positions need to be closed no later than on the expiry date.

If futures positions are not closed before the relevant date, SHARENET’s prime broker will close the position on the client’s behalf at the first available opportunity at the prevailing market rate. Any resulting costs, gains or losses will be passed on to the client.

Order types available

•     Market order

With a market order the client instructs a financial institution or trading counterparty to execute a trade of a certain size as promptly as possible at the prevailing market price. Financial institutions are required to execute market orders without

regard to price changes. Therefore, if the market price moves significantly during the time it takes to fill a client’s order, the order will most likely be exposed to the risk of execution at a price substantially different from the price when the order was entered. Orders may be traded using an algorithm potentially causing slippage from the expected arrival price. This is done by SHARENET’s prime broker in an attempt to prevent large market impact and live up to our obligations to keep an orderly market. SHARENET and/or its prime broker cannot be held responsible for missing fills when using such algorithms to minimize market impact.

•     Limit order

With a limit order, the client sets the maximum purchase price, or minimum sale price, at which the trade is to be executed. As a limit order may be entered away from the current market price, it may not be executed immediately. A client that leaves a limit order must be aware that he/she is giving up the certainty of immediate execution in exchange for the expectation of getting an improved price in the future. Limit orders may be routed to an exchange without human intervention.

Where a limit order is placed in a share admitted to trading on a regulated market, SHARENET’s prime broker shall not be obliged to publish that limit order if it cannot be immediately executed under prevailing market conditions.

•     Stop order

With a limit order, the client sets the maximum purchase price, or minimum sale price, at which the trade is to be executed. As a limit order may be entered away from the current market price, it may not be executed immediately. A client that leaves a limit order must be aware that he/she is giving up the certainty of immediate execution in exchange for the expectation of getting an improved price in the future. Limit orders may be routed to an exchange without human intervention.

Where a limit order is placed in a share admitted to trading on a regulated market, SHARENET’s prime broker shall not be obliged to publish that limit order if it cannot be immediately executed under prevailing market conditions.

•     Trailing stop order

The trailing stop order is a stop order as described above but the trailing stop price moves according to parameters set by the client. This way the trailing stop can be used to sell if the price drops more than a specified distance from the highest price traded or to buy if the price trades above a set level from the lowest traded price.

•     Stop limit order

A stop limit order is a variation of a stop order as described above with a lower (higher) limit price to suspend trading if the price falls (rises) too far before the order is filled restricting trading to a predefined price range.+

•     Algorithmic order

An Algorithmic Order is an order executed by an automated strategy according to specific parameters or conditions. Algorithmic Orders are intended to minimize the market impact created from placing larger orders or achieving a recognized trading benchmark such as VWAP etc. The orders can also be used to follow a volume participation or in general to achieve a better overall execution. SHARENET facilitates a number of different algorithmic order types.

Given the risks that arise when trading in volatile markets, the client may want to consider using different types of orders to limit risk and manage investment strategies.

Relevant execution factors

SHARENET’s prime broker trades as principal with respect to futures trades with clients. Exchange traded futures and other futures traded on a multilateral basis are traded on a centrally regulated venue so the opportunity to shop around is limited because of the consequential concentration of the liquidity on those venues. For futures, the ranking of the applicable execution factors is:

1.     Price
2.     Expected impact of execution
3.     Likelihood of execution and settlement
4.     Costs
5.     Speed
6.     Other factors

SHARENET’s prime broker’s selected venue

SHARENET’s prime broker offers Direct Market Access to the Futures Exchanges.

Where similar products are offered on multiple exchanges, SHARENET’s prime broker will normally provide access to the market offering the best liquidity because this is generally where the best prices will be found.

Other markets may be available on request.

Price formation

Client orders will be routed to the electronic order book of the relevant exchange. Price formation will be according to the rules of the exchange.

Schedule 7: Listed options Products in scope:

Purchase and sale of Exchange Traded Options for speculative and hedging purposes.

Order types available

•     Limit order

With a limit order, the client sets the maximum purchase price, or minimum sale price, at which the trade is to be executed. As a limit order may be entered away from the current market price, it may not be executed immediately. A client that leaves a limit order must be aware that he/she is giving up the certainty of immediate execution in exchange for the expectation of getting an improved price in the future. Limit orders may be routed to an exchange without human intervention.

Where a limit order is placed in a share admitted to trading on a regulated market, SHARENET’s prime broker shall not be obliged to publish that limit order if it cannot be immediately executed under prevailing market conditions.

Relevant execution factors

SHARENET’s prime broker trades as principal with respect to listed options trades with clients. Exchange traded options and other options traded on a multilateral basis are traded on a centrally regulated venue so the opportunity to shop around is limited because of the consequential concentration of the liquidity of those venues. For listed options, the ranking of the applicable execution factors is:

1.     Price
2.     Expected impact of execution
3.     Likelihood of execution and settlement
4.     Cost
5.     Speed
6.     Other factors

SHARENET’s prime broker’s selected venue

SHARENET’s prime broker offers Direct Market Access to the Exchange Traded Options

Price formation

Client orders will be routed to the electronic order book of the relevant exchange. Price formation will be according to the rules of the exchange.

Schedule 8: Rolling Foreign Exchange Spot Products in scope:

Purchase and sale of rolling foreign exchange spot contracts.

Not in scope:

•     Spot foreign exchange transactions undertaken with the intention of converting money from one currency to another, including transactions undertaken to facilitate settlement of other transactions.

•     Transactions undertaken to roll forward the value date of a client position which do not result in a change to the client’s FX market exposure.

Order types available

•     Immediate or Cancel (IOC) Market Order

An Immediate or Cancel (IOC) Market order is similar to a standard Market order (described below). It is an instruction to trade immediately on the best available terms. However, SHARENET’s prime broker will not continue to work the order if it is unable to fill it immediately within three seconds.

Although SHARENET’s prime broker will take all reasonable steps to obtain the best terms available at the time, in illiquid market conditions the best available terms may be substantially worse than the previous (or even the next) price. A Market IOC order is for immediate execution. SHARENET’s prime broker will not delay execution in the hope that market conditions will improve.

SHARENET’s prime broker monitors the prices available to it at its selected external venues. If SHARENET’s prime broker believes it is able to execute a Market IOC order immediately from its own liquidity then it will do so. Otherwise, it will route the order to a third party to attempt execution. Where an order has not been filled after three seconds then the order will be cancelled.

Clients should note that where their orders are routed externally, they cannot be cancelled until SHARENET’s prime broker receives confirmation from its chosen external venue that they have cancelled the order.

Some of the external venues to which SHARENET’s prime broker may route orders may not support market orders. In this case the client’s order may be converted to an aggressive limit order. This will give the client some protection from a bad fill. However, it also introduces a risk that the order will not be filled if the market moves sharply.

•     Market Order

A Market Order is a traditional ‘at best’ instruction to trade as much of the order as possible on the best available terms in the market. A Market order will normally be filled immediately (or failing that in a relatively short time). SHARENET’s prime broker will take all reasonable steps to identify the best terms immediately available for a transaction of that size and will transact on those terms. Financial institutions are required to execute Market orders as soon as reasonably possible without regard to price changes. Therefore, although SHARENET’s prime broker will seek to obtain the best terms immediately available, if the market price moves significantly during the time it takes to fill the client’s order or if only limited liquidity is available at the best price, the order will be exposed to the risk of execution at a price which could be substantially different from the price when the order was entered.

A Market Order will be treated as good for the day. If it cannot be filled in full immediately, SHARENET’s prime broker will continue to work the order until the official close of the relevant market. Some of the external venues to which SHARENET’s prime broker may route orders may not support Market orders. In this case the client’s order may be converted to an aggressive limit order. This will give the client some protection from a bad fill. However, it also introduces a risk that the order will not be filled if the market moves sharply.

•     Immediate or Cancel (IOC) Limit Order

A Limit IOC order is an order to trade at the price the client sees on his screen if it is still available subject to a defined tolerance (see below).

When SHARENET’s prime broker receives a Limit IOC order, it will treat it in a similar way to a Market IOC order (see above) except that it will only fill the order if it is possible at the client’s specified limit price, or better. For internally routed orders, if this is not immediately possible then the order (or any unexecuted part thereof) will be cancelled.

When placing a Limit IOC order, a client may specify a tolerance. Tolerance can be specified either as a fixed price increment or as a percentage of the current market price. If the client specifies a tolerance, SHARENET’s prime broker may fill the order at a worse price than the client had seen on the screen, provided the price difference does not exceed the client’s specified tolerance.

If a better price is available, SHARENET’s prime broker will give the client the full benefit of the available improvement by filling the client order at the better price no matter how much better it is.

As with a Market IOC order, if SHARENET’s prime broker is unable to supply sufficient liquidity from its own book, it may route the order externally. The order will be cancelled after three seconds, but clients should note that where their orders are routed externally, they can’t be cancelled until SHARENET’s prime broker receives confirmation from the external venue that they have cancelled the order.

•     Limit Order

A Limit order is an order to trade at a specified price or better if it is possible to do so within a specified time. The following order durations are available:

•     Day Order (DO): Valid until the official close of trading on the day the order is placed (or on the subsequent business day for orders accepted during the weekend).

•     Good Till Date (GTD): Valid until the official close of trading on a date of the client’s choice.

•     Good Till Cancelled (GTC): Valid indefinitely unless or until specifically cancelled by the client. Where an order is attached to an open position, it will automatically be cancelled if the position is closed.

A Limit order will be triggered when the market price reaches the limit price. At any time when there is not enough liquidity available to fill the order in full at the specified price or better, the remaining order will revert to a ‘resting order’.

When SHARENET’s prime broker executes a Limit order, the client will have specified the price at which he wishes to trade. SHARENET’s prime broker will seek to achieve execution at this price as soon as reasonably possible. SHARENET’s prime broker will not seek to improve upon the price that the client has specified if this may cause a delay to the execution of his order.

•     Stop Order

A Stop order is usually used to close a position when the market is going against it with a view to prevent further losses. It may also be used to open a position when the market moves through a chosen level.

A Stop order may have a duration similar to a Limit order. These are described in the section on Limit orders above. Where an order is attached to an open position, it will automatically be cancelled if the position is closed. A Stop order to sell will be triggered when the offer price at which the client could undertake a transaction of equivalent size reaches the specified price level. Once triggered, the order will be treated as a Market order.

A Stop order to buy will be triggered when the bid price at which the client could undertake a transaction of equivalent size reaches the specified price level. Once triggered, the order will be treated as a Market order.

This arrangement is designed to protect clients from the risk that their Stop order is executed as a result of spreads widening without the market actually moving. This can happen around the release of economic statistics or at times of reduced liquidity such as during a value date roll or during the close and opening of the market.

Clients should note, however, that this means a stop order will never be executed at their specified level but always at a price that is worse for the client (typically the spread away from the client’s stop level).

The trigger level for a Stop order can be specified to trail the market. In this case, when the market moves in the client’s favour, the trigger level for the order moves the same way.

The trigger level for a trailing stop moves in steps which are defined when the order is placed.

When a Stop order is triggered, it will be executed at the first possible opportunity on the best terms immediately available in the market. This means that the client is exposed to the risk of a worse fill in gapping or illiquid markets.

•     Stop Limit Order

A Stop Limit order rests in the same way as a Stop order. However, once triggered, rather than execute at the next available price it converts to a Limit order at a pre-agreed Limit price. From that point on, the order is treated as a Limit order.

This type of order gives the client some protection from a bad fill in a gapping or illiquid market. However, that protection comes at a cost. In some circumstances the order may not be executed at all. Trailing Stop Limit orders are not available.

Relevant execution factors

Except for Limit orders, SHARENET’s prime broker will place the highest priority on total consideration (the combination of price and costs associated with dealing).

For Limit orders, where the client has stipulated a price that is not immediately available in the market, SHARENET’s prime broker will place the highest priority on execution at the client’s specified price at the first possible opportunity. This means that SHARENET’s prime broker will prioritise speed and certainty of execution.

SHARENET’s prime broker selected venue

SHARENET’s prime broker will normally provide liquidity from its internal flow aggregation book. This will provide the best outcome for clients because:

•     SHARENET’s prime broker internal flow aggregation model allows it to place larger trades in the underlying market at prices that would not be available for the smaller trades usually undertaken by its clients.

•     Its continuous two-way order flow means that it usually able to use a single (mid-market) price to which it adds its spread. In less liquid market conditions, it may quote a two-way price. However, its pre- charge price is always within the best bid and offer prices available to it in the underlying market.

•     The foreign exchange spot market is characterised by rapid price movements relative to the costs of dealing. Providing liquidity from its own book allows it to avoid the delays that would arise in routing trades to the underlying market.

In limited circumstances, where SHARENET’s prime broker believe it is necessary to do so to enhance the experience for the majority of its customers, it may route particular orders directly to third party execution venues.

Price formation

SHARENET’s prime broker constantly monitors the prices available to it in the wider market. Its price for foreign exchange spot transactions is formed from these prices (including any associated costs that it is able to allocate on a trade-by- trade basis).

SHARENET’s prime broker price is normally a single price valid for buying or selling, to which its charges are added. Depending on its risk appetite and proprietary interests, SHARENET’s prime broker may set its single price anywhere between the best price at which it is able to sell the relevant currency pair and the best price at which it is able to buy it.

SHARENET’s prime broker capacity to provide liquidity in any given currency pair is subject to its internal exposure limits. If a particular order would cause it to breach those limits, SHARENET’s prime broker may suspend dealing on its price until it is able to reduce its exposure.

SHARENET’s charges

SHARENET’s charges may include the following, some of which may be included in the net price at which the client trades:

•     Price Mark Up/Mark Down.

SHARENET’s main dealing charges will normally be imposed through an addition to/subtraction from the price at which the client deals with it. This add-on or deduction will not form part of the price for best execution comparison purposes.

•     Flat or percentage-based commission charges.

In some cases, such as where SHARENET allows a client direct access to the underlying market, the client will pay a commission-based charge. This charge will be shown separately from the trade price.

•     Financing Adjustments.

Where a client holds a position in a rolling spot contract open overnight, SHARENET’s prime broker will make a cash adjustment to reflect the financing implications of the position. This is based on the interest rates of the currencies in question. Generally, if the client is long, the currency with the lower interest rate, this adjustment will be a cost to the client. If the client is long, the currency with the higher interest rate, it may be in the clients favour. There is a charge element in the interest rates SHARENET’s prime broker uses to calculate these financing adjustments.

•     Liquidity Utilisation Charges.

Where SHARENET’s prime broker acts as liquidity provider, it will provide executable prices to meet the majority of the orders it receives. However, SHARENET’s prime broker will not be obliged to provide liquidity in excess of the liquidity available to it in the underlying market. For larger transactions, SHARENET’s prime broker may add an additional mark up or mark down to its price.

If a client undertakes repeated transactions, SHARENET’s prime broker will view them on a cumulative basis for the purpose of determining the liquidity utilisation charge until a period of 20 seconds has elapsed since his last trade.

Schedule 9: Foreign exchange forward Products in scope:

Purchase and sale of foreign exchange forward contracts.

Not in scope:

Foreign exchange transactions undertaken with the intention of converting money from one currency to another – including transactions undertaken to facilitate settlement of other transactions.

Order types available

•     Immediate or Cancel (IOC) Market Order See Foreign Exchange Spot for details.

•     Immediate or Cancel (IOC) Limit Order See Foreign Exchange Spot for details. Relevant execution factors

SHARENET’s prime broker will place the highest priority on total consideration – being the combination of price and costs associated with dealing.

SHARENET’s prime broker’s selected venues

Foreign exchange forward prices are based on the spot price for the relevant currency pair and a spot/forward swap price.

When SHARENET’s prime broker executes an order for a client, in relation to foreign exchange forward, the spot component will be executed in the same way that SHARENET’s prime broker would execute a spot order for that client.

For the forward swap element, SHARENET’s prime broker provides liquidity from its internal flow aggregation book. This allows SHARENET’s prime broker to aggregate risks and undertake consolidated hedging trades in the underlying market. These larger trades attract keener pricing that SHARENET is able to pass on to its clients.

Price formation

The spot component of a foreign exchange forward contract is priced in the same way that SHARENET’s prime broker would price a foreign exchange spot contract for that client.

The forward swap component of the price is calculated from the spot price (as above) and the differential between the interest rates for the two currencies for the relevant forward value date.

SHARENET’s prime broker interest rates for US Dollars are based on interbank rates.

For other currencies, SHARENET’s prime broker interest rates are implied from the US Dollar rates and the forward swap rates available to SHARENET’s prime broker from its hedging counterparties.

Where there is no published interest rate for the specified date, SHARENET’s prime broker will calculate a rate by interpolation between the available dates on either side.

SHARENET’s prime broker creates a single mid-market price for the forward swap for the client’s chosen dates. The spread SHARENET’s prime broker adds to this mid-point varies depending upon the spot rate, the interest rates applying to the currencies concerned, and the time to maturity. SHARENET and/or its prime broker will disclose the total spread for each transaction before the client trades.

SHARENET’s charges

See foreign exchange spot for details of charges that may apply to foreign exchange trades.

Schedule 10: Foreign exchange options Products in scope:

Foreign Exchange Vanilla, Barrier and Binary Touch Options.

Not in scope:

All foreign exchange options are in-scope.

Order types available

•     Dealing on Quotes

SHARENET’s prime broker will provide prices for foreign exchange options to clients on request. These prices will be calculated to meet its obligation to provide the client with the best possible outcome on his transaction in terms of total consideration.

If a client wishes to trade, they may elect to do so at the price SHARENET’s prime broker has quoted. Acceptance of the trade is subject to filters based on time elapsed and/or price movements in the underlying market since the price was quoted.

Relevant execution factors

SHARENET’s prime broker will place the highest priority on total consideration – being the combination of price and costs associated with dealing. SHARENET’s prime broker will also prioritise speed and certainty of execution and the ability to trade in retail sizes.

The underlying market for foreign currency options is the ‘inter-bank market’. Transactions undertaken in this market are normally of a wholesale size. It is not normally practical to undertake individual smaller transactions.

SHARENET’s prime broker’s selected venue(s)

Option prices are based on a number of factors, the most significant of which are the spot price of the underlying and the ‘implied volatility’ of the relevant currency pair.

For the implied volatility, SHARENET’s prime broker provides liquidity from its internal flow aggregation book. This allows it to aggregate risks and undertake consolidated hedging trades in the underlying market. These larger trades attract keener pricing that SHARENET’s prime broker is able to pass on to its clients.

Price formation

SHARENET’s prime broker uses the Black Scholes pricing model to price options from its own liquidity. This model generates a single mid-market price based on spot prices, interest rates and ‘implied volatilities’ for the currencies concerned.

SHARENET’s prime broker uses the Black Scholes pricing model to price options from its own liquidity. This model generates a single mid-market price based on spot prices, interest rates and ‘implied volatilities’ for the currencies concerned.

SHARENET’s prime broker premium for any given option is derived from three factors which it internally treats as separate markets. SHARENET’s prime broker net spread for an option trade is derived from the spread it quotes on each component. The net spread on any particular option transaction will be disclosed before the client trades. Spreads will normally be wider for longer dated options than for shorter dated ones; and wider for closer to the money options than for deeper in or out of the money ones.

SHARENET’s charges

SHARENET’s charges may include the following, some of which may be included in the net price at which the client trades:

•     Price Mark Up/Mark Down.

SHARENET’s main dealing charges will normally be imposed through an addition to/subtraction from the price at which the client deals with it. This add-on or deduction will not form part of the price for best execution comparison purposes.

•     Flat or percentage-based commission charges.

In some cases, the client will pay a commission-based charge. This charge will be shown separately from the trade price.

Globally, financial regulatory bodies are increasingly focused on market conduct rules across the financial markets and products. Consequently, new financial regulation comes into force on an ongoing basis, and most recently through the introduction of Market Abuse Regulation.

It is therefore essential that you, as a client of THE SHARENET GROUP, receive information on and gain insight into which part of the said rules and regulations you are required to comply with. Below, you will find an overall description of the rules. You will also find a non-exhaustive list describing situations which you need to avoid as these constitute violations of market rules.

Market conduct rules

Regulation of the financial markets and market conduct rules are aimed at ensuring trust and integrity and thus promoting integrated, efficient and transparent markets. Specific rules set forth unacceptable market conduct by prohibiting the abuse of insider information and various forms of market manipulation. The exchanges/trading venues may have specific rules about market disruption so at the end of this document you will find links to the relevant sites. One example of such rules is that some exchanges have specific limits for the size of positions in various derivatives.

Market conduct rules and regulation applies to all individuals and all legal entities; therefore, all market participants are obliged to familiarize themselves with the relevant rules and regulations. It should be noted that the responsibility of complying with the specific rules lies solely with the individual market participant, and i.e. you as our client.

Trading activity is being monitored and any suspicious activity will be investigated by the relevant markets and authorities. The following is a non-exhaustive list of examples of conduct that violate market conduct rules:

• Taking advantage of price-sensitive non-published information concerning a company in order to make a profit or avoid incurring losses by buying or selling stocks and/derivatives or to attempt to take advantage of the said information in any other way (insider trading).
• Passing on insider information.
• Disseminating false or misleading information on circumstances of substantial importance for the valuation of a security (e.g. a company's earnings, orders or product pipeline or a general supply shortage).
• Disseminating false or misleading information, rumors or messages that may influence the price of a security with the intent to exploit the resulting price movement.
• Entering low-volume purchase orders with successively higher prices to simulate an increased demand amid rising prices (painting the tape).
• Simultaneously buying and selling the same securities for the account of one and the same beneficial owner to create false or misleading signals regarding the supply of, demand for, or market price of securities (wash trades).
• To distort liquidity or prices by entering equal but opposite buy and sell orders in the same security by prior mutual agreement between a number of parties (matched orders or daisy chains coordinated among a number of parties).
• Constricting the market by building up large positions (cornering) or depositing securities with third-parties (parking) to distort securities prices (creating a squeeze).
• Buying or selling securities shortly before the exchange closes with the intent to influence closing prices (marking the close).
• Buying or selling securities to move prices (ramping) or keep them at a specific level (e.g. capping, pegging).
• Influencing commodity prices to give out false or misleading signals regarding the supply of or demand for securities.
• Placing orders but with no intention to execute (Spoofing).
• Similar to spoofing, market participants “layer” or “bait” other market participants to react and trade with a bona fide order on the other side of the market without intention to trade (Layering).
• Attempting to push down the price of a stock by heavy selling or short selling (bear raiding)

For further information regarding market regulations and practices please make sure and visit the following exchanges:

Trading in the products and services of Sharenet Group of Companies (“Sharenet”) may, even if made in accordance with a Recommendation, result in losses as well as profits. In particular trading in leveraged products, such as but not limited to, foreign exchange, derivatives and commodities can be very speculative and losses and profits may fluctuate both violently and rapidly.

This risk disclosure statement is made pursuant to the rules. The risk of loss arising from trading in financial instruments can be substantial. You should carefully consider whether such investments are suitable for you in the light of your circumstances and financial resources. You should be aware of the following points:

1. Under certain market conditions it may be difficult or impossible to close out a position. This may occur, for example, where trading is suspended or restricted at times of rapid price movement.

2. Where permitted, placing a stop-loss order will not necessarily limit your losses to the intended amounts, for market conditions may make it impossible to execute such orders at the stipulated price.

3. Prior to the commencement of trading, you should require from your FSP written confirmation of all current commissions, fees and other transaction charges for which you will be liable.

4. FSP’s may also be dealers trading for their own account in the same markets as you, in which case their involvement could be contrary to your interests.

5. Investing in securities traded on stock, bond and derivatives exchanges will mean that the value of the assets, and the income received from them, may go down as well as up and the Client may not get back all the money invested. These are some of the main reasons why this might happen:

5.1 The actual and perceived financial standing and trading well-being of the organisation involved may change;

5.2 The securities themselves are subject to the laws of supply and demand and are capable of significant price movements irrespective of market and corporate factors. Such movements could be a reflection of company size and marketability;

5.3 Stock markets are capable of large movements due to economic, political and other factors.

5.4 Fixed interest investments are subject to the above factors and values are particularly affected by actual or expected changes in levels of interest rates. If they are purchased above their ultimate redemption price, a capital loss will be incurred if held to redemption.

6. Assessing the relative risk of any of these factors is highly subjective and, in line with market conditions, can change over time in response to specific events or revised social or economic forecasts. It is not possible to lay down precise guidelines for the measurement of risk or the potential impact, whether positive or negative, upon an investment portfolio.

7. Risk can be managed by creating a well-diversified portfolio and by the use of collective investments such as investment trusts and units in collective investment schemes. Diversification within a market and/or throughout a number of geographical areas also helps to lower exposure to economic and political factors. The Client should, however, bear in mind that investing overseas may involve other risks, such as currency fluctuations; different accounting standards to those recognised in South Africa and, often, limited information.

8. Accordingly, the Client acknowledges that it is aware of the risks inherent in asset management and accepts that such risks may result in financial loss and hereby waives all and any rights which it may have to hold The Discretionary Financial Services Provider or any of its employees or contractors liable therefor, whether directly or indirectly.

9. If you have any doubts or concerns regarding the risks of trading in financial instruments you may contact the Securities Exchange or Securities and or Platform Provider for more detailed information before signing this statement. This brief statement cannot disclose all risks of investment in financial instruments. They are not suitable for many members of the public and you should carefully study such investments before you commit funds to them. They may also have tax consequences and on this you should consult your lawyer, accountant or other tax advisor.

10. When investing in foreign investment products it is important to be aware of the following risks: 10.1 Getting access to investment performance information may be more difficult than South African based investments.

10.1 Investments are exposed to different tax regimes that may change without warning and it may influence investment returns.

10.2 Exchange control measures may change in the country of investment and it may influence accessibility to the invested capital.

10.3 Currency Risk: The value of the Rand has deteriorated over the last number of years. However, it is important to understand that should the Rand exchange rate strengthen against the exchange rate of the foreign currency(ies) in which the Client’s money is invested, it may create a loss of capital or reduced returns when the money is returned to South Africa in Rand. Furthermore, the Foreign Exchange market is made up of a Base currency and a Reference currency. The Reference currency can move up or down relative to the Base currency. This may introduce the risk that a currency may move against the original position that a client has taken.

10.4 Leverage Risk: In the event where a hedge has been done on a specific currency, this risk may manifest in a “Margin Call” being made where the client needs to pay in “Maintenance Margin” in order to keep the hedge in place. In the event of a Forward contract being supplied by a bank, the afore mentioned bank may require additional security to keep that Forward in place.

10.5 Event Risk: Event risk is the risk that a foreign currency denominated or forex transaction may be affected by events experienced or anticipated by the market. Examples of these include; an anticipated rate statement, a speech from a central banker, or a long awaited trade deal announcement.

10.6 Operational risk: Operational risk is the risk that an Investment may be affected by the operational processes legal risks, fraud and security of the Investment Manager or Counterparty involved in the transaction.

17 INITIAL Sharenet Group of Companies are authorised financial services providers. Sharenet Securities FSP#: 28430 | Sharenet Wealth FSP #: 41688

Speculative trading is not suitable for all investors.

Any mentioning, if any, in a Publication of the risks pertaining to a particular product or service may not and should neither be construed as a comprehensive disclosure nor full description of all risks pertaining to such product or service and Sharenet strongly encourages any recipient considering trading in its products and services to employ and continuously consult suitable financial advisors prior to the conclusion of any investment or transaction.

No recommendations

Sharenet does not in any of its Publications take into account any particular recipient's investment objectives, special investment goals, financial situation, and specific needs and demands. Therefore, all Publications of Sharenet are, unless otherwise specifically stated, intended for informational and/or marketing purposes only and should not be construed as:

• business, financial, investment, hedging, legal, regulatory, tax or accounting advice;
• a recommendation or trading idea; or
• any other type of encouragement to act, invest or divest in a particular manner (collectively “Recommendations”).

Sharenet shall not be responsible for any loss arising from any investment based on a perceived Recommendation.

No Representation, No Warranty

Sharenet uses reasonable efforts to obtain information from reliable sources, but all Publications are provided on an “as is” basis without representation or warranty of any kind (neither express nor implied) and Sharenet disclaims liability for any Publication not being complete, accurate, suitable and relevant for the recipient. Specifically, Sharenet disclaims liability towards any subscriber, client, partner, supplier, counterparty and other recipients for:

• the accuracy of any market quotations;
• any delay, inaccuracy, error, interruption or omission in providing market quotations; and
• any discontinuance of market quotation.

The Publications of Sharenet are not updated after their release and may due to changing circumstances become inaccurate and possibly misleading after a period of time which may vary from seconds and minutes to days, weeks and months depending on the Information. Sharenet gives no guarantee against, and assumes no liability towards any recipient for, a Publication being outdated.

If a Publication becomes outdated Sharenet shall be under no obligation to:

• update the Publication;
• inform the recipients of a Publication; or
• perform any other action.

Any Publication may be personal to the author and may not reflect the opinion of Sharenet. Sharenet reserves the right at its sole discretion to withdraw or amend any Publication or Information provided at any time without notice (prior or subsequent).

Internet Trading Risks

There are risks associated with utilising an Internet-based deal execution trading system including, but not limited to, the failure of hardware, software, and Internet connection. Since Sharenet does not control signal power, its reception or routing via Internet, configuration of your equipment or reliability of its connection, we cannot be responsible for communication failures, distortions or delays when trading via the Internet. Sharenet employs backup systems and contingency plans to minimize the possibility of system failure, and trading via telephone is available.

Use of the website

Any use of the Sharenet website is subject to Sharenet's “Terms of Use”, as amended from time to time, and the “Copyright” provisions, as amended from time to time, both of which shall be construed as constituting an integrated part of this disclaimer.

Sharenet shall not be liable for any damage or injury arising out of any person's or entity's access to, or inability to access, the website of Sharenet. This limitation includes, but is not limited to, any damage to computer equipment and computer systems caused by virus, malware and any other harmful computer coding.

Consulting the website of Sharenet does not constitute a customer relationship and Sharenet shall not have any duty or incur any liability or responsibility towards any person or entity as a result of such person or entity consulting the website of Sharenet.