Legal Information

Legal Information

Information contained herein is for information purposes only and is merely illustrative. It is not deemed as advice as defined in the Financial Advisory and Intermediary Services Act (FAIS Act).

ClucasGray and its employees shall not be held responsible for any losses sustained by any person acting based on the information. Past performance of any of our portfolios is not indicative of their future performance.

ClucasGray (Pty) Ltd is an independent investment management company registered in South Africa, company registration number 2005/12445/07 and an authorised financial services provider under the Financial Sector Conduct Authority (FSCA) registration number 21117. The main business of ClucasGray is the provision of investment management services to private and institutional clients.

Conflict Of Interest

This policy is available on request, please email  if you require a copy.

Complaints Policy


In order for a complaint to receive the attention that it deserves, we request that your complaint is submitted to us in writing. Please ensure, that where the complaint is delivered by hand or by any other means, that you retain proof of delivery.


The financial services environment is complex. We will endeavour to address all reasonable requests from our clients, but may also refer you to a more appropriate facility. Where the complaint pertains to any aspect of our service, or any disclosures that ought to be made by us, we will endeavour to address those complaints in writing, within seven days.
In instances where the complaint pertains to something not within our control, such as product information or investment performance we will forward the complaint to the product provider concerned.


The following is a step-by-step guideline of how a complaint will be dealt with, once received by us:

  1. The complaint will be lodged in our central complaints register on the same day that it is made and confirmation of receipt forwarded to you.
  2. The complaint is immediately brought to the attention of the Key Individual of this provider for allocation to a trained and skilled person who specialises in that type of complaint.
  3. The complaint will be investigated and we will revert to you with our findings within thirty working days.
  4. In the event that you are not satisfied with our solution, you may refer the complaint to the Managing Director of our business. The Managing director may amend the solution or confirm it. Please be informed that certain decisions may have to be approved by the Board or Management committee of the organisation. In such a case, we will communicate that fact to you, as well as the date on which a decision will be taken.
  5. If, after having referred the complaint to the Managing Director, you are still not satisfied with the outcome, we will regard the complaint as being unsatisfactorily resolved. In such a case, you may approach the office of the Ombud for Financial Services Providers or take such other steps as may be advised by your legal representatives. The referral to the office of the Ombud must be done in accordance with the provisions of section 21 of the FAIS Act and the rules promulgated in terms of that section. In instances where we have not been able to arrive at a resolution within six weeks after you have lodged your complaint, the matter may automatically be referred to the Ombud.
  6. You must, if you wish to refer a matter to the Ombud, do so within a period of six months. The Ombud will not adjudicate in matters exceeding a value of R800 000.00.
  7. The FAIS Ombudsman may be contacted at their offices in Pretoria, at the following address:
  8. The FAIS Ombudsman
    125 Dallas Avenue
    Menlyn Central,
    Waterkloof Glen,  Pretoria, 0010
    P O Box 74571
    Lynwood Ridge,  Pretoria, 0040  Tel: +27 860 663 247

In the event of us not reverting to you within the time periods indicated above, kindly contact Paul Carter for an explanation as to why we have not yet communicated with you. Please do not accept any communication from any person until it has been confirmed in writing.

Protection Of Personal Information Policy


ClucasGray takes your privacy and the protection of your personal information very seriously. We will only use your personal information in accordance with applicable data protection legislation.

We have implemented reasonable operational measures to keep your personal information secure.

By signing our Application Forms and Mandate, you consent to us processing your personal information.


We may collect the following information about you:

  • Your name, address, contact details, date of birth, place of birth, identity number, passport number, bank details, details about your employment, tax number and financial information;
  • Information about your beneficial owner and any related parties (if applicable)
  • Records of correspondence or enquiries from you or anyone acting on your behalf;
  • Details of transactions you carry out with us;
  • Details of contracts you carry out with us;

We may require you to provide additional personal and tax-related information, in order for us to meet our legal or regulatory obligations

Where you provide us with the personal information of third parties you should take steps to inform the third party that you need to disclose their details to ClucasGray Asset Management and how their data will be processed.


We may use, transfer and disclose your personal information for the purposes of:

  • Providing you with the services and products you have requested;
  • Processing your personal information for ordinary business purposes (this includes opening and maintenance of your investments, and maintaining our overall relations with you).
  • Managing your investments;
  • Complying with your instructions;
  • Complying with Applicable Laws, including lawful requests for information received from local or foreign law enforcement, government and tax collection agencies;


We will retain your information in accordance with retention periods set out in Applicable Laws, unless we need to retain it for longer for a lawful purpose.


You may request details of personal information which we hold about you under the Promotion of Access to Information Act 2 of 2000 (“PAIA”).

You may request the correction of personal information we hold about you. Please ensure that the information we hold about you is complete, accurate and up to date.


Should you believe that we have processed your personal information contrary to Applicable Laws, you undertake to first attempt to resolve any concerns with us.

If you are not satisfied with such process, you may have the right to lodge a complaint with the Information Regulator, using the contact details listed below:

Tel: 012 406 4818
Fax: 086 500 3351