SEO report of drakenscapital.com

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• <H2> Drakens Capital is a fund manager with extensive experience investing in emerging market equities. Our team has been investing in emerging and frontier markets for over 2 decades.
• <H1> To find out more about the funds we run and the solutions we provide to clients,
• <H3> We'd Love to Hear From You
• <H3> LEGAL
• <H5> Drakens Capital Pty Ltd is the new name of Renaissance Asset Managers (South Africa) Pty Ltd.The information on this website is for information purposes only. The entire content of this website is subject to copyright and all rights are reserved. By using the pages of this website, and/or by reading the material within it, you agree that you will use the information only for your internal business purposes and that you will not otherwise download, copy, transmit or distribute in any way any of this material in whole or in part, Renaissance Asset Managers (South Africa) Pty Ltd nor any of its affiliates accepts any liability whatsoever for the actions of third parties in this respect. The information may not be used to create any financial instruments or products or any indices. Neither Renaissance Asset Managers (South Africa) Pty Ltd and its affiliates, nor their directors, representatives, or employees accept any liability for any direct or consequential loss or damage arising out of the use of all or any part of the material. Viewing the information on this website is restricted to Professional Investors only and may not be lawful in certain jurisdictions. In further jurisdictions, only certain categories of person may be allowed to view such information. Any person who wishes to view the information on this website must first satisfy himself or herself that he or she is not subject to any local requirements which prohibit or restrict him or her from doing so. If you are not permitted to view the information on this website or are in any doubt as to whether you are permitted to view the information, please exit this website. 

The information on this website should not be construed an offer or solicitation to sell shares in any company or fund or their securities, by anyone in any jurisdiction in which such offer, solicitation or distribution would be unlawful or in which the person making such offer or solicitation is not qualified to do so or to anyone to whom it is unlawful to make such offer or solicitation. 

Descriptions of any company or fund or their securities or the markets or developments mentioned herein are not intended to be complete. The information on this website should not be regarded by recipients as a substitute for the exercise of their own judgment and has no regard to the specific investment objectives, financial situation or particular needs of any specific recipient. All information and opinions on this site are subject to change without notice, and Renaissance Asset Managers (South Africa) Pty Ltd are under no obligation to update or keep current the information contained on this site and accept no liability in respect of the accuracy or completeness of any information herein. 

This document contains certain forward-looking statements with respect to our management strategies or expectations. Forward-looking statements are typically identified by words or phrases such as "trend," "potential," "opportunity," "believe," "expect," "anticipate," "estimate," "position," "assume," "outlook," "continue," "remain," "maintain," "sustain," "seek," "achieve," and similar expressions, or future or conditional verbs such as "will," "would," "should," "could," "may" or similar expressions. Certain forward looking statements may not contain such words. Readers of this web site must be aware that that forward-looking statements are subject to numerous assumptions, risks and uncertainties, which change over time. Forward-looking statements speak only as of the date they are made, and we assume no duty to and does not undertake to update forward-looking statements. Actual results could differ materially from those anticipated in forward-looking statements and future results could differ materially from historical performance. 

The price of securities and any income generated from them can go down as well as up and you may not get back the amount invested. In considering the prior performance information contained herein, prospective investors should bear in mind that past performance is not necessarily indicative of future results, and that there can be no assurance that the comparable results will be achieved. The information contained on this site may not be reproduced, distributed or published, in whole or in part, for any purpose without the written permission of Renaissance Asset Managers (South Africa) Pty Ltd. Renaissance Asset Managers (South Africa) Pty Ltd accepts no liability whatsoever for the actions of third parties in this respect.  Renaissance Asset Managers (South Africa) Pty Ltd intends to change its name to Drakens Capital. At present the registered legal entity is Renaissance Asset Managers (South Africa) Pty Ltd registration number 2011/131287/07 Renaissance Asset Managers (South Africa) Pty Limited, is authorized and regulated by the South Africa FSB, FSP number 45511 we are also an advisor to Mori Capital Management Limited regulated by the Malta Financial Services Authority Registration No C66999
• <H3> COMPLAINTS POLICY AND PROCEDURE
• <H5> Drakens Capital is committed to providing its clients with quality service. In the event of a client having a complaint the following procedures are available to the client: The complaints procedure is available to clients on our website and at our offices. Clients may download it from the website or request it either by e mail, post or in person and must be given a copy of the complaints procedure on request. The client has the right to advise the staff member at Drakens Capital who they are dealing with that they are unhappy and wish to lay a complaint.The staff member must advise them that the policy of the firm is to lodge the complaint in writing with a full explanation of the complaint. The staff member must advise his or her line manager of the incoming complaint. The business ensures that there are sufficient and appropriate management controls in place to exercise effective control of the complaints process.On receipt of the written complaint it must be: Entered into the complaints register and referred to the line manager for resolution. The customer must be advised of receipt of the complaint in writing by the line manager with contact details of the line manager. The customer may also contact us via our website if they prefer not to deal with the individual staff member - http://www.drakenscapital.com The line manager must deal with the complaint as a matter of urgency and refer it to whoever is needed to resolve the matter if it cannot be resolved by the line manager. Where the complaint is a non-routine serious complaint it must be escalated to a senior staff member who has sufficient experience to handle the complaint. Complaints records are to be maintained for 5 years. The line manager must record the resolution/solution provided in the complaints register.The customer must be advised of the solution or resolution of the complaint in writing within 3 weeks. The customer mast also be advised of: The fact that if they feel that the complaint has not been fairly and correctly dealt with they may refer the complaint to the Ombudsman and have 6 months to do so. The customer must be given the contact details of the Ombudsman which are: Telephone: +27 12 762 5000 / +27 12 470 9080 Facsimile: +27 86 764 1422 / +27 12 348 3447 E-mail Address: info@faisombud.co.za Website: www.faisombud.co.za Sussex Office Park Ground Floor, Block B 473 Lynnwood Road Cnr Lynnwood Road & Sussex Ave, Lynnwood, 0081If after consideration the result of the complaint are not in favor of the customer full details of the reasons must be included in the written reply to the customer, within 6 weeks of the complaint. Where the customer is to receive redress this must be offered without any delay.If the complaint is due to a procedure that must be amended to ensure it does not happen again the line manager must liaise with the necessary people to ensure that this is implemented.Where the procedure was found to be a reason for the complaint the head of that department must together with the line manager design new procedures that prevent a recurrence of such complaints. This procedure must be adopted as soon as possible. Staff must comply with the guidelines in this complains policy. Where staff do not comply they will be subject to an investigation as to why the complaint was not dealt with in terms of policy. Where the staff member was at fault a hearing will be convened to determine adequate sanctions for the particular staff member.
• <H4> FIRM DETAILS
• <H5> Address: 2nd Floor, 191 Jan Smuts Ave. Parktown North, Johannesburg South Africa, 2193 Telephone: +27 (0)10 140 6600 Website: www.drakenscapital.com Director: S Richter Company Auditors: Moores Rowland FSB no.: 45511 Reg. no.: 2011/131287/07
• <H3> CONFLICT OF INTEREST POLICY
• <H5> POLICY ADOPTED – JANUARY 2016 REVIEWED – February 2016 The policy forms part of the internal control structures and procedures of the firm. I, Sven Richter, as Key Individual of the FSP herby confirm adoption of this document. SIGNED : DATE : Drakens Capital is committed to ensuring the fair treatment of all its clients, while recognizing that conflicts of interest cannot always be avoided. The Firm and its representatives are committed towards acting within the best interests of our clients and to avoid all conflict of interests in relation to the provision of financial services. Where we are unable to avoid a conflict of interest, we will take all necessary precautions to ensure that any actual or potential conflict of interest is mitigated and adequately disclosed to our clients. Guiding principles have therefore been established, outlining its approach to properly identifying and managing conflicts of interest as well as situations where potential conflicts may arise such as personal account dealing or the providing and receiving of gifts. Purpose The purpose of this policy is to: Give guidance to staff as to how to identify a conflict of interest and how to deal with one. Advise staff of the firm’s commitment and process to avoiding and mitigating any potential or actual conflict of interest. Specify the procedures to be followed and the measures to be adopted in order to manage such conflicts.
• <H4> GENERAL PROVISION AND GUIDING ETHOS
• <H5> In terms of the General Code of Conduct a provider and a representative must avoid, and where this is not possible, mitigate any conflict of interest between the provider and a client, or a representative of the provider and his, her or its clients. The Firm and its representatives are committed towards acting within the best interests of our clients and to avoid all conflict of interests in relation to the provision of financial services. Where we are unable to avoid a conflict of interest, we will take all necessary precautions to ensure that any actual or potential conflict of interest is mitigated and adequately disclosed to our clients. In order to ensure the continued demonstration of our commitment, management has adopted a Conflict of Interest Management policy to provide for the effective management of any actual or potential conflicts of interest that may arise wholly or partially, in relation to the provision of financial services. The purpose of the Conflict of Interest Management Policy is therefore to:Establish internal controls and mechanisms towards the identification of conflicts of interest. Establish measures to avoid conflicts of interest, and where avoidance is not possible, to provide the reasons therefore. Establish measures to ensure that any unavoidable conflicts of interest are mitigated. Establish measures to ensure the proper disclosure of any conflicts of interest. Establish processes, procedures and internal controls to facilitate compliance with the policy. Communicate the consequences of non-compliance with the policy.IDENTIFYING A CONFLICT OF INTEREST INDIVIDUAL IDENTIFICATION The primary responsibility for the identification of a conflict of interest rests with the representatives, employees and individual members of the governing body of the Firm. Throughout the process of rendering a financial service to a client, a representative must apply his or her mind to answering the following questions: Is there any situation that exists that influences the objective performance of my obligations to my client? Is there any situation that exists that prevents me from rendering an unbiased and fair financial service to my client? is there any situation that exists that prevents me from acting in the best interest of my client? If the answer to all three questions is “no”, then there is no conflict of interest associated with the financial service and the representative may proceed. If the answer to any one of the three questions is “yes”, the representative must proceed to answer the following additional questions: Is the situation caused as a result of an actual or potential relationship with a third party? (see definition of “third party”) is the situation caused by an actual or potential financial or ownership interest? (see definition of “financial interest” and “ownership interest”) If the answer to any one of these question is “yes”, an actual or potential conflict of interest will have been identified. FURTHER GUIDANCE ON IDENTIFYING A CONFLICT OF INTEREST The definition of a Conflict of Interest incorporates the following terminology:…influence the “objective performance” of his, her or its obligations to that client…. …prevent a provider or representative from rendering an “unbiased and fair financial service” to that client….. …including but not limited to a “financial interest” It is generally understood that the word “objective” refers to a situation where an individual’s personal feelings or opinions are completely removed from the equation. The “objective performance” of a FSP or representative’s obligations therefore implies a situation where financial services are rendered without any untoward influences. The word “bias” or “biased” is understood to mean a form of prejudice towards a particular person or viewpoint, whereas the word “fair” or “fairness” indicates a situation of just circumstances or being treated on an equal footing. An unbiased financial service therefore implies a financial service that does not lend itself to a particular persuasion, where no reasonable justification for such persuasion can be found. Similarly, a fair financial service implies a situation where the same conclusion or outcome will consistently present itself given the exact same set of circumstances. Subject to section 3A(1)(c) of the General Code of Conduct, the FSP and its representatives may only receive or offer the following “financial interest” from or to a “third party”: commission authorised under the Long-term Insurance Act, Short-term Insurance Act or under the Medical Schemes Act. fees authorised under the Long-term Insurance Act, the Short-term Insurance Act or the Medical Schemes Act, if those fees are reasonably commensurate to a service being rendered. fees for the rendering of a financial service in respect of which commission or fees referred to above is not paid, if those fees:are specifically agreed to by a client in writing; and may be stopped at the discretion of that client fees or remuneration for the rendering of a service to a third party, which fees or remuneration are reasonably commensurate to the service being rendered. an immaterial financial interest (subject to any other law). a financial interest, not referred to above for which a consideration, fair value or remuneration that is reasonably commensurate to the value of the financial interest, is paid by that Firm or representative at the time of receipt thereof. The Firm will not offer any financial interest to its representatives for: giving preference to the quantity of business secured for the Firm to the exclusion of the quality of the service rendered to clients; or giving preference to a specific product supplier, where a representative may recommend more than one product supplier to a client; or giving preference to a specific product of a product supplier, where a representative may recommend more than one product of that product supplier to a client. SPECIFIC SITUATIONS The following table identifies potential conflicts of interest and reflects the Drakens Capital (DC) policy and procedures to mitigate these potential conflicts of interest.
• <H4> IDENTIFYING A CONFLICT OF INTEREST
• <H5> INDIVIDUAL IDENTIFICATION The primary responsibility for the identification of a conflict of interest rests with the representatives, employees and individual members of the governing body of the Firm. Throughout the process of rendering a financial service to a client, a representative must apply his or her mind to answering the following questions: Is there any situation that exists that influences the objective performance of my obligations to my client? Is there any situation that exists that prevents me from rendering an unbiased and fair financial service to my client? is there any situation that exists that prevents me from acting in the best interest of my client? If the answer to all three questions is “no”, then there is no conflict of interest associated with the financial service and the representative may proceed. If the answer to any one of the three questions is “yes”, the representative must proceed to answer the following additional questions: Is the situation caused as a result of an actual or potential relationship with a third party? (see definition of “third party”) is the situation caused by an actual or potential financial or ownership interest? (see definition of “financial interest” and “ownership interest”) If the answer to any one of these question is “yes”, an actual or potential conflict of interest will have been identified. FURTHER GUIDANCE ON IDENTIFYING A CONFLICT OF INTEREST The definition of a Conflict of Interest incorporates the following terminology:…influence the “objective performance” of his, her or its obligations to that client…. …prevent a provider or representative from rendering an “unbiased and fair financial service” to that client….. …including but not limited to a “financial interest” It is generally understood that the word “objective” refers to a situation where an individual’s personal feelings or opinions are completely removed from the equation. The “objective performance” of a FSP or representative’s obligations therefore implies a situation where financial services are rendered without any untoward influences. The word “bias” or “biased” is understood to mean a form of prejudice towards a particular person or viewpoint, whereas the word “fair” or “fairness” indicates a situation of just circumstances or being treated on an equal footing. An unbiased financial service therefore implies a financial service that does not lend itself to a particular persuasion, where no reasonable justification for such persuasion can be found. Similarly, a fair financial service implies a situation where the same conclusion or outcome will consistently present itself given the exact same set of circumstances. Subject to section 3A(1)(c) of the General Code of Conduct, the FSP and its representatives may only receive or offer the following “financial interest” from or to a “third party”: commission authorised under the Long-term Insurance Act, Short-term Insurance Act or under the Medical Schemes Act. fees authorised under the Long-term Insurance Act, the Short-term Insurance Act or the Medical Schemes Act, if those fees are reasonably commensurate to a service being rendered. fees for the rendering of a financial service in respect of which commission or fees referred to above is not paid, if those fees:are specifically agreed to by a client in writing; and may be stopped at the discretion of that client fees or remuneration for the rendering of a service to a third party, which fees or remuneration are reasonably commensurate to the service being rendered. an immaterial financial interest (subject to any other law). a financial interest, not referred to above for which a consideration, fair value or remuneration that is reasonably commensurate to the value of the financial interest, is paid by that Firm or representative at the time of receipt thereof. The Firm will not offer any financial interest to its representatives for: giving preference to the quantity of business secured for the Firm to the exclusion of the quality of the service rendered to clients; or giving preference to a specific product supplier, where a representative may recommend more than one product supplier to a client; or giving preference to a specific product of a product supplier, where a representative may recommend more than one product of that product supplier to a client. SPECIFIC SITUATIONS The following table identifies potential conflicts of interest and reflects the Drakens Capital (DC) policy and procedures to mitigate these potential conflicts of interest.
• <H4> SPECIFIC SITUATIONS
• <H5> The following table identifies potential conflicts of interest and reflects the Drakens Capital (DC) policy and procedures to mitigate these potential conflicts of interest.
• <H4> ASSOCIATES AND OWNERSHIP INTERESTS
• <H5> 
• <H4> AVOIDING AND MITIGATING CONFLICT OF INTEREST
• <H5> Once an actual or potential conflict of interest has been identified, the following procedures will be followed in order to determine whether the conflict of interest is avoidable: The directors of the FSP will convene and evaluate the actual or potential conflict of interest in an open and honest manner. All information that’s led up to and resulting in, or causing the actual or potential conflict of interest will be disclosed to the FSP’s directors and the FSP’s compliance officer The directors of the FSP will apply its mind and determine by way of majority vote whether the FSP is in a position to avoid the actual or potential conflict of interest During the evaluation process, the directors of the FSP will take into account the following possible outcomes prior to a finding in favour of unavoidability: The possible negative impact it will have on the FSP’s clients where the actual or potential conflict of interest is deemed to be unavoidable. The possible negative impact it will have on the integrity of the financial services industry where the actual or potential conflict of interest is deemed to be unavoidable Where the governing body of the FSP has determined that the actual or potential conflict of interest is in fact avoidable, the following processes will be followed: The directors will remove the underlying cause or situation that results in the actual or potential conflict of interest as soon as reasonably possible. Any immediate negative impact or prejudice towards clients pending the removal of the actual or potential conflict of interest will be kept to a minimum. The reasons why the actual or potential conflict of interest was determined to be avoidable will be recorded in the FSP’s Compliance Manual. Similar circumstances that has led up to the actual or potential conflict of interest will be avoided in the future. Where the governing body of the FSP has determined that the actual or potential conflict of interest is unavoidable, the following processes will be followed: The governing body of the FSP and the FSP’s compliance officer will convene and determine the measures that will be implemented in order to mitigate the actual or potential conflict of interest as far as reasonably possible. The reasons why the actual or potential conflict of interest was considered to be unavoidable will be recorded in the FSP’s Compliance Manual. Any measures implemented towards mitigating the actual or potential conflicts of interest will include the following arrangements: The status of whether the actual or potential conflicts of interest’s is still deemed to be unavoidable shall be reassessed on a continuous basis. Where a previously deemed unavoidable actual or potential conflicts of interest is subsequently deemed to be avoidable, such actual or potential conflict of interest shall immediately be avoided. All representatives will be notified of any actual or potential conflicts of interest as well as the reasons for its unavoidability. When rendering financial service a representative shall be required to disclose to the client in writing that an actual or potential conflict of interest exist. The FSP and/or the FSP’s compliance officer shall report on the status of the actual or potential conflict of interest in the FSP’s compliance report to be submitted to the Financial Services Board
• <H4> DISCLOSURE OF CONFLICTS OF INTEREST
• <H5> It is acknowledged that while disclosure alone will often not be enough, disclosure must be treated as an integral part of managing conflicts of interest. The FSP is therefore committed to ensure that clients are fully informed about actual or potential conflicts of interest in relation to the provision of financial services. The FSP has adopted the following disclosure measures: The FSP shall disclose to a client any conflict of interest in respect of that client. The disclosure shall be made in writing at the earliest reasonable opportunity. The disclosure may be communicated by way of appropriate electronic media. The disclosure shall include the nature of any relationship or arrangement with a third party that gives rise to a conflict of interest The disclosure shall be made in sufficient detail to enable the client to understand the exact nature of the relationship or arrangement and the conflict of interest. The disclosure shall include the measures taken to avoid or mitigate the conflict. The disclosure shall include any ownership interest or financial interest, other than an immaterial financial interest, that the FSP or representative may be or become eligible for. The disclosure shall include a reference to the FSP’s Conflict of Interest Management Policy and how it may be accessed
• <H4> COMPLIANCE MEASURES
• <H5> The measures implemented towards ensuring the FSP’s continued compliance with the Conflict of Interest Management Policy rests with the governing body of the FSP. The FSP’s appointed Compliance Officer will monitor the FSP’s continued compliance with the policy on an ongoing basis. The FSP has adopted the following internal controls and processes: The governing body of the FSP shall ensure that the Conflict of Interest Management Policy is kept in the FSP’s Compliance Manual. The governing body of the FSP shall ensure that all relevant personnel read the Conflict of Interest Management Policy and understand their duties in respect thereof. The governing body of the FSP shall ensure that all personnel, and where appropriate, associates are made aware of the contents of the Conflict of Interest Management Policy and shall provide personnel with training and educational material where deemed appropriate. The governing body of the FSP shall ensure that all Conflict of Interest declarations are signed by relevant personnel on a quarterly (3 monthly) basis. Where an employee or representative have any concerns whether or not an actual or potential conflict of interest might arise in a particular situation, the employee or representative will be required to refer his or her concern to the FSP’s Compliance Officer. The governing body of the FSP shall ensure that a list of all the FSP’s associates is annexed to the Conflict of Interest Management Policy and that a review of the list shall be conducted annually. The governing body of the FSP shall ensure that a list of all the parties in which the FSP holds an ownership interest is annexed to the Conflict of Interest Management Policy and that a review of the list shall be conducted annually. The governing body of the FSP shall ensure that a list of all third parties that holds an ownership interest in the FSP is annexed to the Conflict of Interest Management Policy and that a review of the list shall be conducted annually. The governing body of the FSP shall continue to maintain a Gift Register and shall ensure that all gifts received from a third party with an estimated value of R500 or more are recorded in the FSP’s Gift Register. The governing body of the FSP shall ensure that the proper disclosures are made to the client regarding actual or potential conflicts of interest. The Conflict of Interest Policy shall be regularly reviewed by the appointed Compliance Officer, and where necessary, updated to ensure that the measures contained herein remains effective. The governing body of the FSP shall publish its Conflict of Interest Management Policy in appropriate media and ensure that it is easily accessible for public inspection at all reasonable times. The governing body of the FSP shall ensure that the Conflict of Interest Management Policy is reviewed on at least an annual basis.
• <H4> CONSEQUENCES OF NON-COMPLIANCE
• <H5> Where there is reason to believe that an employee or representative has failed to disclose an actual or potential conflict of interest via the proper communication channels, the FSP will proceed to conduct an investigation and take any appropriate steps it deems necessary to limit any financial prejudice that may be suffered by the FSP, its clients or any other third party. Where an investigation concludes that an employee or representative of the FSP has indeed failed to disclose an actual or potential conflict of interest, the FSP shall immediately take appropriate disciplinary steps and corrective actions against such employee or representative. Any failure by an employee to comply with the Conflict of Interest Management Policy will be considered serious form of misconduct and a dismissible offence.
• <H4> FIRM DETAILS
• <H5> Address: 2nd Floor, 191 Jan Smuts Ave. Parktown North, Johannesburg South Africa, 2193 Telephone: +27 (0)10 140 6600 Website: www.drakenscapital.com Director: S Richter Company Auditors: Moores Rowland FSB no.: 45511 Reg. no.: 2011/131287/07
• <H4> DEFINITIONS
• <H5> Conflict of Interest Any situation in which a provider or a representative has an actual or potential interest that may, in rendering a financial service to a client: influence the objective performance of his, her or its obligations to that client; or prevent a provider or representative from rendering an unbiased and fair financial service to that client, or from acting in the interest of that client,including but not limited to: a financial interest an ownership interest any relationship with a third party Financial Interest Any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, other incentive or valuable consideration, other than: an ownership interest training, that is not exclusively available to a selected group of providers or representatives, on: products and legal matters relating to those products general financial and industry information specialised technological systems of a third party necessary for the rendering of a financial service, but excluding travel and accommodation associated with that training Immaterial Financial Interest Any financial interest with a determinable monetary value, the aggregate of which does not exceed R1 000 in any calendar year from the same third party in that calendar year received by: a provider who is a sole proprietor; or a representative for that representative’s direct benefit; a provider, who for its benefit or that of some or all of its representatives, aggregates the immaterial financial interest paid to its representatives; Ownership Interest – any equity or proprietary interest, for which fair value was paid by the owner at the time of acquisition, 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 - a product supplier another provider an associate of a product supplier or a provider a distribution channel any person who in terms of an agreement or arrangement with a person referred to above provides a financial interest to a provider or its representatives Associate - In relation to a natural person: a person who is recognised in law or the tenets of religion as the spouse, life partner, or civil union partner of that person a child of that person, including a stepchild, adopted child and a child born out of wedlocka parent or stepparent of that person a person in respect of which that person is recognised in law or appointed by a Court as the person legally responsible for managing the affairs of or meeting the daily care needs of the first mentioned person a person who is a spouse, life partner or civil union partner of a person referred to above a person who is in a commercial partnership with that person In relation to a juristic person: which is a company, means 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 which is a close corporation registered under the Close Corporations Act, means any member thereof as defined in section1 of that Act which is not a company or a closed corporation, means another juristic person which would have been a subsidiary or holding company of the first-mentioned juristic person: had such first-mentioned juristic person been a company, or in the case where that other person, too, is not a company, had both the first-mentioned juristic person and that other person been a company means any person in accordance with whose directions or instructions the board of director of or, in the case where such juristic person is not a company, the governing body of such juristic person is accustomed to act. In relation to any person: means any juristic person of which the board of directors or, in the case where such juristic person is not a company, of which the governing body is accustomed to act in accordance with the directions or instructions of the person first-mentioned in this paragraph includes any trust controlled or administered by that person Distribution Channel - any arrangement between a product supplier of any of its associates and one or more providers or any of its associates in terms of which arrangement any support or service is provided to the provider or providers in rendering a financial service to a client any arrangement between two or more providers or any of their associates, which arrangement facilitates, supports or enhances a relationship between the provider or providers and a product supplier any arrangement between two or more product suppliers or any of their associates, which arrangement facilitates, supports or enhances a relationship between a provider or providers and a product supplier

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