Public Disclosure Policy

1. Purpose of the Policy

This Public Disclosure Policy ensures that all information disseminated by GBS Fin Serv (Pty) Ltd ("the FSP") complies with the FAIS Act, the General Code of Conduct, the Financial Sector Regulation Act, Treating Customers Fairly (TCF) outcomes, and all FSCA advertising and conduct requirements.

This policy is aligned with the firm's business model as an execution-only intermediary facilitating OTC derivatives and crypto asset transactions through authorised partners Finalto (ODP) and VALR (CASP), as described in the Business Plan.

2. Scope of Application

This policy applies to all public-facing communications, including:

Website and platform disclosures
Digital marketing, social media, and paid campaigns
Marketing brochures, workshops, presentations
Client-facing emails and written notices
Any communication prepared internally or by third-party service providers

3. Core Principles for Public Communication

All communications must comply with FAIS General Code, and reflect:

Accuracy and Verifiability

All data, performance figures, and statements must be factual, supportable, and not misleading.

Clear and Understandable Language

Communications must be written in plain language appropriate for Retail, Corporate, and High Net-Worth clients as stated in the Business Plan.

Fairness and Balance

Risks and benefits must be presented equally and prominently.

Prohibition of Misleading Content

Marketing may not imply portfolio management, guaranteed returns, or advisory services.

4. Mandatory Disclosures in Public Communications

4.1 Regulatory Status Disclosure

All content must prominently display:

GBS Fin Serv (Pty) Ltd – FSP 47645
Confirmation that the FSP is authorised under FAIS to render intermediary services in Derivatives, Short- and Long-term Deposits, and Crypto Assets (pending approval)
Statement of regulation by the FSCA

4.2 Nature of Service Disclosure

Communications must clearly state:

• GBS Fin Serv operates strictly as an execution-only intermediary and does not provide financial advice.
• Clients make their own trading decisions on trading platforms.
• The FSP acts as an Introducing Broker to Finalto for derivatives and VALR for crypto assets.
• Fees and commissions payable, including: spreads, funding/rollover charges, withdrawal fees, and commissions earned from liquidity partners.

4.3 Risk Warnings

All derivative and crypto-related communication must include:

• Risk of significant loss or total loss of capital
• High volatility and leverage warnings
• Crypto asset volatility, liquidity, and speculative nature
• Clear statement that past performance does not guarantee future results

5. Content Creation, Review, and Approval Process

5.1 Creation

Marketing and Communications teams draft public-facing material. Third-party marketing agencies may only create content under documented instruction.

5.2 Compliance Review

All public communication must be reviewed and approved by:

The Key Individual
The Compliance Officer

Review includes:

Accuracy of disclosures
Prominence of risk warnings
Confirmation of execution-only role
Alignment with Business Plan service model
Compliance with FSCA standards

5.3 Monitoring

Compliance must monitor:

Website updates
Social media postings
Digital advertisements
Marketing partner output

Important: Non-compliant content must be removed or corrected immediately.

6. Record-Keeping

In accordance with FAIS General Code Section 18:

All approved communication material must be retained for five (5) years.
Records must include draft versions, approval timestamps, and factual substantiation.

7. Alignment With the Business Plan

This policy directly supports:

The Intermediary revenue model (commission-based)
The Introducing Broker model for derivatives (Finalto) and crypto assets (VALR)
trading platform usage for execution-only trading
The defined target market: Retail, Corporate, and High Net-Worth clients
The FSP's commitment to compliance, non-advice, client suitability testing, and transparency

8. Review of the Policy

The policy will be reviewed annually, or sooner if required by:

FSCA guidance
Product changes (e.g., expansion of derivatives or crypto assets)
Business Plan updates

9. Enforcement

Non-compliance may result in disciplinary action and may trigger notification duties to the FSCA.

Policy Acknowledgment

GBS Fin Serv (Pty) Ltd is committed to transparent, accurate, and compliant public communications. This policy ensures that all stakeholders receive fair and balanced information about our services and the associated risks.

For any questions regarding this policy, please contact our Compliance Officer.