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1.1. The Financial Services Boar(“FSB”) announced in 2011 that it would be implementing a policy to regulate the financial services industry in South Africa, called Treating Customers Fairly (“TCF”). The main aim of this policy is to ensure the fair treatment of customers within the financial services industry. The policy also aims to raise the standards in the way the financial services industry carries out their business by introducing rules that will not only deter unfair treatment of customers, but will also be beneficial to customers and increase their confidence in the financial services industry.
1.2. Cloud Atlas, fully supports the objectives of TCF as without fair treatment of customers, and the deterioration of customer confidence in the financial services industry over time, their investment objectives will not reach their full potential.
1.3. The core objectives of this Treating Customers Fairly Policy (“TCF”) is to be able to create a culture of fairness within Cloud Atlas whre the 6 (six) key principles (“TCF”) which are central to the TCF initiative, thrive, these include:
1.3.1. consumers should be confident that they are dealing with firms where treating customers fairly is embedded in the corporate culture;
1.3.2. services marketed and sold are done so with the aim that they meet the needs of client and are targeted accordingly;
1.3.3. consumers should be provided with clear information and are kept appropriately informed before, during and after the service provision;
1.3.4. where advice is provided, it takes into account a client s individual circumstances;
1.3.5. the financial service provided is of an acceptable standard; and
1.3.6. consumers do not face unreasonable barriers to change the product, or the firm, or to make a complaint, post-sales.
1.4. Cloud Atlas is aware that TCF Principles need to be prevalent through all stages of the product life cycle including product design, marketing and promotion, advice, point of sale, after the sale, implementation, complaints handling and the ultimate payment of the benefits at claims (or withdrawal) stage. TCF is a regulation with a combination of principles and rules, it emphasises on embedding a TCF culture in conducting business, bearing this in mind, the TCF programme follows a top down approach by starting with the senior management rather than a delegated “tick box” compliance approach. Cloud Atlas will insure that internal processes that compel compliance with this TCF Policy by its staff, are in place and endeavour to carry on everyday business in accordance with the TCF Principles, cultivating an atmosphere where the TCF initiative can grow.
1.5. As the business is in its early stage, the TCF will be established, through this policy, and tested, reviewed and updated, as the business begins operations as a Collective Investment Scheme.
2.1. The purpose of this TCF Policy is to assist Cloud Atlas’s in meeting its obligatinos to be fit, proper and compliant with the TCF initiative.
2.2. Cloud Atlas has created this TCF Policy in order to achieve a common understanding amongst its staff and customers, of the TCF Principles, its aims and outcomes and how to implement and monitor it in a way that will satisfy the customers as well as the Regulator.
2.3. This TCF Policy sets out industry “best practise” within the TCF context, which Cloud Atlas Staff are encouraged to implement.
3. Generally accepted TCF Principles
The Cloud Atlas team must follow the following guidelines when dealing with customers daily:
3.1. . Pay due regard to the interest of their customers and treat them fairly in all their dealings with them.
3.2. Integrity: Conduct business with integrity.
3.3. Skill, care and diligence: Conduct business with due skill, care and diligence.
3.4. Management and control: Take reasonable care to organise and control their affairs responsibly and effectively, and in accordance with the risk management plan of the company.
3.5. Financial Prudence: Maintain adequate financial resources.
3.6. Market Conduct: Observe proper standards of market conduct, where the company does not have its own code of conduct.
3.7. Client Communications: Pay due regard to the information needs of clients and communicate information to them in a way which is clear, fair and not misleading.
3.8. Conflicts of Interest: Manage conflict of interest fairly, both between themselves and the customers and between customers and other clients.
3.9. Customer relationship of trust: Take reasonable care to ensure the suitability of advice and discretionary decisions for any customer who is entitled to rely upon their judgment.
3.10. Client assets: They should arrange adequate protection for client assets that fall under their responsibility.
3.11. Client information: Handle client information, with the knowledge that it is personal information and must be protected.
3.12. Relations with the Regulator: They should deal with the Regulator in an open and cooperative way and must appropriately disclose to the FSB anything relating to the business of which the FSB would reasonably expect notice.
4. TCF OUTCOMES
Cloud Atlas aims to achieve the following outcomes through the TCF:
4.1. TCF Checklist
Cloud Atlas aims to enforce an internal TCF checklist
process to ensure that the following areas of our business are in line with the TCF Principles:
- Promotional Material;
- Sales Advice Process;
- Client Contract Information;
- Compliant Handling;
- Staff Training and Awareness;
- Remuneration and incentives;
- Management Information;
- Risk assessment process to monitor compliance; and
- Product understanding.
Fair treatment of customers is central to the corporate culture.
Products and services marketed and sold are designed to meet the needs of identified consumers and are targeted accordingly. We ascertain the appropriateness of the requested service for all new clients prior to accepting an instruction, ensuring it is in line with their knowledge and experience.
Customers are provided with clear, fair and unambiguous information and are kept appropriately informed through the entire cycle of a product.
We make certain our clients understand the risks associated with our services at the outset of an instruction.
We work hard to ensure that service and risk information remains clear and prominent at all times.
In the event that there is a conflict of interest, we inform our clients as soon as we become aware of it.
Advice, where appropriate, is suitable and takes account of each client’s peculiar circumstances. As our product is available through financial advisers, we will also ensure financial advisers are fully aware of the risks of our product.
Consumers are provided with products that perform as companies have led them to expect and the associated service is both of an acceptable standard and as they have been led to expect.
4.7. Post-sale treatment
Consumers do not face unreasonable post-sale barriers when wanting to change product, switch provider, submit a claim or submit a complaint.
We ensure our services are delivered with clarity and transparency and do not contain hidden conditions or rely on complex technical definitions.
The following principles are always at the forefront when dealing with claims:
- simple claims making and handling procedures and processes;
- speedy settlement and payments;
- fast and effective communications with claimants; and
- no variations in treatment of customers.
5. BUSINESS CULTURE
5.1. In fostering a TCF Culture the following list of considerations are always forefront:
5.1.1. the right leadership appointed and educated to spearhead the TCF program and set the standard, as Cloud Atlas is in its early stages it will be a culture driven by all staff members and as the business evolves so will the policy;
5.1.2. the right strategy employed to implement TCF as part of the business strategy process;
5.1.3. the right controls such as monitoring compliance at a management level maintaining and ensuring management information that is accurate, timely, relevant and consistent;
5.1.4. the right recruitment and training program that will introduce and encourage TCF compliance and a TCF culture; and
5.1.5. the right rewards and recognition is given to staff and promotes TCF.
6. Our service
6.1. Our approach is to provide our clients with an excellent service underpinned by quality and choice. We are committed to ensuring that our employees, customers and agents, want to buy our services, stay with us and recommend us to their families, friends and colleagues.
6.2. Our service is shaped by listening to our client’s needs and understanding what is important to them. We take responsibility for meeting the needs of our clients and always look for ways to improve the quality of our service. This is evident with the development of our indices over time; they have being shaped by what the market wants, while maintaining their purpose and objective.
6.3. We aim to treat our clients fairly and deliver high quality services which meet their expectations throughout their relationship with us.
6.4. We recognise that our employees are critical to delivering a positive client experience and ensuring our customers are treated fairly. Our culture and values encourage and support our employees to deliver this.
7.1. questions and queries, and address any issues or concerns promptly. All customer complaints are dealt with and escalated as appropriate and as required by us in order to me our obligations to our clients and regulation authorities.
7.2. We are happy to provide full details of our complaints process on request.
Cloud Atlas Investing (Cloud Atlas RF (Pty) Ltd) is a registered manager of the Cloud Atlas Scheme, a Collective Investment Scheme approved by the Financial Services board. Under the Scheme Cloud Atlas Investing is an authorised Exchange Trade Fund Issuer by the Johannesburg Stock Exchange.