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FAIS General Code

Conflict of Interest Management Policy

TheIntrepid (Pty) Ltd, FSP 52207, has adopted this Conflict of Interest Management Policy in terms of the General Code of Conduct for Authorised Financial Services Providers and Representatives. The policy is published here so that it is easily accessible for public inspection.

Last updated 31 August 2026

Purpose and scope

TheIntrepid must render financial services honestly, fairly, with due skill, care and diligence, and in the interests of clients and the integrity of the financial services industry. This policy sets out how we identify, avoid, mitigate and disclose conflicts of interest that may arise in the course of our business.

It applies to the FSP, its Key Individuals, representatives, partners, employees, and any other person who may influence the rendering of financial services. It is available to clients, investors and the public on this website and on request from the compliance department.

What we treat as a conflict of interest

A conflict of interest is any situation in which TheIntrepid or a representative has an actual or potential interest that may influence the objective performance of obligations to a client, or prevent TheIntrepid or the representative from rendering an unbiased and fair financial service, or from acting in the best interests of a client. An interest includes a financial interest, an ownership interest, and any relationship with a third party.

Examples relevant to our business include, without limitation:

  • Investing alongside, or in, a business in which a partner, employee, associate or related party has an existing interest.
  • Receiving or offering financial interests, gifts, hospitality or other incentives that could influence advice, intermediary services or investment decisions.
  • Board seats, advisory mandates or other roles at current or prospective portfolio companies.
  • Allocation of investment opportunities among the firm, co-investors, related funds or personal accounts.
  • Using confidential information obtained in one mandate for the benefit of another party.

Avoidance, mitigation and disclosure

Our order of preference is to avoid a conflict. Where a conflict cannot be avoided, we will mitigate it through controls appropriate to the circumstances (for example recusal, information barriers, independent review, or declining the mandate) and we will disclose it to the affected client in writing, in a manner that allows the client to make an informed decision.

Disclosure will include the nature of the conflict, the measures taken, and any financial or ownership interest involved, at a level of detail that is reasonably sufficient in the circumstances.

Financial interests, gifts and hospitality

TheIntrepid and its representatives may not receive or offer a financial interest that would be inconsistent with the FAIS General Code, including the restrictions on financial interests from product suppliers and third parties.

The internal gift and hospitality threshold is R1,000 (one thousand rand) per calendar year per third party, aligned with the FAIS General Code definition of an immaterial financial interest. Gifts, hospitality or other financial interests above that threshold are not accepted in connection with the rendering of financial services unless the Compliance Officer has approved them in writing as consistent with the Code. Cash or cash equivalents are not accepted as gifts. All gifts and hospitality at or above a nominal value are recorded in the gifts register.

Ownership interests and associates

As at 31 August 2026, the only material ownership interest requiring public disclosure is TheIntrepid's current investment in PBT Holdings Ltd (formerly PBT Group Limited), a JSE-listed portfolio company described on the Portfolio page of this website. Partners may hold board seats at that company and at other entities, as described in their biographies. There are no other associate relationships or third-party ownership interests that currently require additional public disclosure under this policy. Client-specific conflicts, if any arise, are recorded in the COI register and disclosed to the affected client.

Personal account dealing and outside interests

Partners, Key Individuals, representatives and employees must declare outside business interests and obtain approval before accepting roles that could conflict with their duties. Personal account dealing in securities of current or prospective portfolio companies, or in instruments that could reasonably be affected by the firm's activities, is subject to pre-clearance and restriction where required.

Training, records and review

  • Key Individuals, representatives and relevant staff receive training on this policy and on the FAIS conflict-of-interest rules.
  • The Conflict of Interest register and the gifts register are maintained by the Key Individual, Galen Hossack, with oversight from the FSP's appointed external Compliance Officer.
  • This policy is reviewed at least annually, and whenever there is a material change to the business or to the applicable law. It was last reviewed on 31 August 2026 and is updated on this website when amended.
  • A copy is available for public inspection at our Cape Town office during ordinary business hours and on request at the email below.
Key Individual
Galen Hossack
Compliance Officer
Debra Gill, External Compliance Officer

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