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    The Association of Botswana Financial Advisers (ABFA) (the Association) encourages the highest professional and ethical standards in the provision of financial advice in Botswana.

    The Council and membership of the Association look to all members to meet these standards and to maintain the reputation of the Association by following this Code of Ethics and Conduct (the Code). It sets down the principles which all members of the Association should follow in the course of their professional duties.

    Members are obliged to comply with the Code. If they do not comply, this may result in the Association taking disciplinary action against the member as provided for in the Disciplinary Code of the Association.



    The key principles which set the standards for the behaviour of all ABFA members in respect of the key stakeholders (clients, colleagues, firms & institutions, the industry and the Association) are:

    1. To act honestly and fairly at all times when dealing with clients and counterparties and to be a good steward of their interests, taking into account the nature of the business relationship with each of them, the nature of the service to be provided to them and the individual mandates given by them.
    2. To act with integrity in fulfilling the responsibilities of your appointment and to seek to avoid any acts, omissions or business practices which damage the reputation of the organisation, the financial services industry or the Association.
    3. Complying with all relevant Laws (including the laws of the Association) and meeting the requirements of all applicable regulatory authorities, and appropriate codes of practice and codes of conduct, and to interpret and apply them according to principles rooted in trust, honesty and integrity.
    4. To be alert to and manage fairly and effectively and to the best of your ability avoid any relevant conflict of interest.
    5. To attain and actively maintain a level of technical and professional competence appropriate to your responsibilities, to commit to continuing learning to ensure the currency of your knowledge, skills and expertise and to promote the development of others.
    6. To decline to act in any matter about which you are not competent unless you have access to such advice and assistance as will enable you to carry out the work in a professional manner.
    7. To uphold the highest personal and professional standards in all dealings and relationships.
    8. To respect the confidentiality of information.
    9. To applying objectivity in making professional judgements and in giving opinions and statements, not allowing prejudice or bias or the influence of others to override objectivity.

    A member operating in a professional capacity has duties arising from these key principles, to a number of different groups. Within these relationships a member should always act ethically and their behaviour and conduct should meet the following code:

    Relations with clients

    1.         Members will seek to earn and maintain the trust of their clients at all times and should:
    1.1.      Give fair and proper consideration and the appropriate priority to the interests and requirements of all clients. Obtain and provide relevant information, including all necessary documentation and respect the confidentiality of information;
    1.2.      Avoid conflict between personal interests, or the interests of any associated company, person or group of persons, and their duties to all clients;
    1.3.      Avoid conflict between any competing interests of one or more client(s), stepping aside in one or all matters if such conflicts cannot be resolved;
    1.4.      Act at all times with due skill, care and diligence;
    1.5.      Act only within the limits of personal competence and any limits of authorisation;
    1.6.      Act in a financially honest and prudent manner, including ensuring the protection of any money and/or property held on behalf of clients;
    1.7.      Act openly, fairly and respectfully at all times, providing all clients with due respect, consideration and opportunity;
    1.8.      Be honest and trustworthy with clients and communicate with them in a clear, prompt and appropriate manner;
    1.9.      Provide suitable and objective recommendations to clients;
    1.10.    Comply with all Laws and Regulations regarding the supply of goods and services to clients;
    1.11.    Not offer or accept money, gifts, entertainment, loans or any other benefit or preferential treatment from or to any existing or potential client or provider, other than occasional gifts, entertainment or remuneration, which are provided as part of accepted business practice, and which are not likely to conflict with duties to clients.

    Relations in employment

    2.         Members should aim to ensure good relations with their employer and employees and should:
    2.1.      Avoid conflict between personal interests, or the interests of any associated company or person, and their duty to their employer;
    2.2.      Not make improper use of information obtained as an employee or disclose, or allow to be disclosed, information confidential to their employer;
    2.3.      Seek to be a responsible employer or employee and be honest and trustworthy at work;
    2.4.      Act openly, fairly and respectfully at all times, treating other employees, colleagues, clients and suppliers with equal respect, consideration and opportunity;
    2.5.      Aim to take every opportunity to improve their professional capability, knowledge and skills;
    2.6.      Accurately and completely account for and report in employer records all business dealings;
    2.7.      Not provide or accept money, gifts, entertainment, loans or any other benefit or preferential treatment from or to any existing or potential supplier or business associate, other than occasional gifts, entertainment or remuneration, which are provided as part of accepted business practice, provided this is not likely to conflict with any duty that is owed to their employer.
    In addition, where a member holds a position of influence within an organisation they should:
    2.8.      Provide, or encourage their employer to provide, suitable arrangements for the internal review of decisions, policies and actions where an employee raises concerns of unethical behaviour. (Employees should not be penalised for raising matters of ethical concern even if this results in a loss to the organisation or a client);
    2.9.      Incorporate, or encourage their employer to incorporate, ethical standards into the organisation’s governance standards, including the development of an ethical code. (This part of the Code will operate alongside any employer policies, guidance, work rules, contracts and conduct documents. Where this part of the Code sets higher standards, the Code should be followed.)

    Relations with Regulators and the Law

    3.         Members must respect and abide by all Laws and Regulations that affect their business and must:
    3.1.      Ensure they operate within the Law and within the spirit of the Law, at all times;
    3.2.      Ensure they deal with regulators in an open, transparent and co-operative manner and meet any requirements correctly made of them.
    3.3.      Ensure that appropriate licenses are obtained and such licenses are kept current.

    Relations with the community and the public

    4.         Members should recognise the important wider role that they play as professionals and should:
    4.1.      Seek to advance the reputation of financial advisory services, financial planning, and associated trades through their own conduct;
    4.2.      Operate in a way that respects environmental concerns and issues;
    4.3.      Act in a socially responsible manner;
    4.4.      Strive to be trusted individuals and fulfil their responsibilities to the societies and communities in which they operate professionally.

    Relations with the Association

    5.         Members receive various benefits as ABFA members, but they also have responsibilities to the Association and its members. They should:
    5.1.      Act at all times according to the laws of the Association (including this Code of Ethics and Conduct);
    5.2.      Ensure a transparent relationship with the Association, based on trust, respect, responsibility and integrity;
    5.3.      Have pride in their status as an ABFA member;
    5.4.      Ensure they do not make improper use of information or disclose, or allow to be disclosed, information confidential to the Association;
    5.5.      Aim to seek opportunities to support the work of the Association and to promote its values to others, especially industry bodies, employers and prospective members;
    5.6.      Aim to seek opportunities to support ABFA activities;
    5.7.      Demonstrate to others the value of professional qualifications and continuing professional development;
    5.8.      Treat other ABFA officers, other members and ABFA employees with the same respect they would wish to be given;
    5.9.      Ensure that their membership of the Association is not publicised in any way, that might suggest that they hold a professional qualification which they are not entitled to;
    5.10.    Ensure that any conduct, promotion or public announcement with which a member is connected, does not bring the Association, another member, or their profession into disrepute;
    5.11.    Advise the Association of any members who are not following its rules or this Code, and advise the Association of anyone wrongly representing themselves as a member;
    5.12.    Aim to ensure the expected standard of technical competence is maintained and that they remain informed of current developments (to ensure they remain competent to carry out their role) by undertaking appropriate professional development.


    Members who find themselves in a position which might require them to act in a manner contrary to the Principles or Code of Ethics and Conduct should:

    1. Discuss their concerns with their line manager.
    2. Seek advice from their internal compliance department.
    3. Approach their firm’s non-executive directors or audit committee.
    4. Contact the Association of Botswana Financial Advisers.


    An entity wishing to register a complaint against any member of the Association should:

    1. Address the complaint in writing to each individual or company concerned.
    2. Follow the formal complaints procedure of the individual(s) or company(ies) concerned.
    3. If the complaint cannot be resolved by the individual(s) or company(ies) concerned within two months, the complaint should be made, in writing, to the Disciplinary Committee of the Association.