KEY CONTACT DETAILS FOR ACCESS TO INFORMATION QUERIES

SAIY Asset Management will deal with all requests relating to any of the Entities. All requests in terms
of this Manual should be directed to the Information Officer (Philippa Owen).

The Oval, 1 Oakdale Road, Newlands 7700 - Informationofficer@saiy.co.za

THE ACT

PAIA grants a requestor access to records of a private body, if the record is required for the exercise or
protection of any rights. If a public body lodges a request, the public body must be acting in the public
interest. Requests in terms of PAIA shall be made in accordance with the prescribed procedures, at the
rates provided.

The Information Regulator has, in terms of section 10(1) of PAIA, updated and made available the
revised Guide on how to use PAIA (“Guide”), for those who wish to exercise any right contemplated in
PAIA and POPIA. The Guide can also be obtained from the website of the Regulator
(www.inforegulator.org.za ).

TYPES OF RECORDS AVAILABLE

Records available in terms of any other legislation

All records kept and made available in terms of legislation applicable to the Entities listed in this
Manual and the Financial Services Industry in general, as it applies to the specific environment in which
the Entities operate, are available in accordance with the said legislation.

Legislation includes the following:

Basic Conditions of Employment Act, 75 of 1997

Collective Investment Schemes Control Act, 45 of 2002

Companies Act, 71 of 2008

Compensation for Occupational Injuries and Diseases Act, 130 of
1993

Consumer Protection Act, 68 of 2008

Copyright Act, 98 of 1978

Customs and Excise Act, 91 of 1964

Electronic Communications and Transactions Act, 25 of 2002

Employment Equity Act, 55 of 1998

Financial Advisory and Intermediaries Services Act, 37 of 2002

Financial Intelligence Centre Act, 38 of 2001

Financial Markets Act, 19 of 2012

Foreign Account Tax Compliance Act

Income Tax Act, 58 of 1962

Labour Relations Act, 66 of 1995

Long Term Insurance Act, 52 of 1998

Medical Schemes Act, 131 of 1998

Occupational Health and Safety Act, 85 of 1993

Pension Funds Act, 24 of 1956

Protection of Constitutional Democracy against Terrorist and
Related Activities Act, 33 of 2004

Prevention of Organised Crime Act, 121 of 1998

Protection of Personal Information Act, 4 of 2013

Promotion of Access to Information Act, 2 of 2000

Skills Development Levies Act, 9 of 1999

Trademarks Act, 194 of 1993

Unemployment Insurance Act, 63 of 2001

Value Added Tax Act, 89 of 1991

RECORDS AVAILABLE ON REQUEST

Set out below are the subjects and categories of records that are available for the purposes of PAIA,
subject to grounds for refusal to the access thereof.

Personnel records

“Personnel” refers to any person who works for or provides services to or on behalf of the Entities, and receives or is entitled to receive remuneration and any other person who assists in carrying out or conducting the business of the Entities. This includes, without limitation, current and former: directors (executive and non executive), permanent, temporary and part-time staff, as well as contract workers.

Personnel records include the following:

Personal records provided to the Entities by their personnel;

Records provided by a third party to the Entities relating to their personnel;

Conditions of employment and other personnel-related contractual and quasi-legal
records;

Internal evaluation records and other internal records;

Correspondence relating to personnel.

Client related records

A “client” refers to any natural or juristic person that receives services from the Entities.
Client records include the following:

Records provided to the Entities by the Client;

Records pertaining to the Client provided to the Entities by a third party;

Records pertaining to the Client provided to the Entities by a third party acting for or on
behalf of the Entities;

Records generated by or within the Entities pertaining to the client.

Records of SAIY Asset Management and other Entities listed above

These records include, but are not limited to, the records which pertain to the various Entities’ own
affairs:

Financial & Operational records;

Databases and Information Systems;

Information Technology;

Marketing records;

Internal correspondence;

Records relating to products and services;

Statutory and Regulatory records;

Internal Policies and Procedures;

Treasury related records;

Securities and Equities;

Records held by officials of the Entities.

Records in the possession of or pertaining to other parties

Personnel, client, or Entity records which are held by another party, as opposed to the records held by the Entities;

Records held by the Entities pertaining to other parties, including without limitation, financial records, correspondence, contractual records, records provided by the other party and records third parties have provided about contractors and suppliers.

PROCESSING OF PERSONAL INFORMATION

If you wish to obtain access to a record pursuant to this manual, you should follow the procedure set out below:

1. Fill in the application form contained in Annexure A of this manual and provide it to us via hand delivery, postal service, or email, per the details provided in this manual.
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2. Provide sufficient details to enable us to identify:
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a) The record(s) requested;
b) The requestor (and if an agent is lodging the request, proof of capacity) and the
c) requestor’s contact details;
d) The form and manner of access required;
e) How the requestor wishes to be informed of the decision and the particulars thereof;
f) The right which the requestor is seeking to exercise or protect with an explanation of the reason the record is required to exercise or protect the right.
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3. Pay a non-refundable request fee (as indicated in Annexure B) at our office (or request our banking details via the contact details above). If you are an employee or ex-employee requesting access to your personnel record, then you do not have to pay the request fee. If a request for access to a record is made orally because of a lack of literacy or a disability of the requestor, the Information
Officer (or Deputy Information Officer) will complete Annexure C on behalf of the requestor and provide the requestor with a copy thereof.

OUR RESPONSE

We will consider your request and let you know our decision and if there are any fees payable, not more than 30 days after we receive your request. We will send you our decision in the prescribed form (see Annexure C).

Your application does not contain enough information to enable us to search for the record you want. Please provide additional details.

It is going to take us more than six hours to search through our records, and before we do so you must pay us a deposit.

We have found the record you're looking for, and you may have access to it, on payment of the prescribed fee (see Annexure B for the prescribed fees).

You may not have access to the record you want, for reasons which we will state in our reply. If you have paid a deposit, we will refund it (but not the request fee).

We have searched for the record and cannot find it. We will give you an affidavit explaining what steps we took to try and find the record. Should the missing record later be found, we will notify you.

We may need longer than the prescribed 30 days in which to locate the information. We may request an extension in writing and in accordance with s 57(1) of PAIA.

If we may or must refuse to give you access to part of the requested information, we will give you access to the remainder.

RIGHTS OF ACCESS AND REFUSAL

Your right of access to information

PAIA entitles you to have access to our records, if:

you need access to exercise or protect any of your rights, and

you apply for access according to the procedure set out in this manual, and

the Entities do not have grounds for refusing you access.

Our right to refuse access to information

We have the right to refuse to give you access to records if any of the following grounds apply:

the record would unreasonably disclose PI about a natural person, including a deceased individual (unless that third party or a representative of the deceased gives written permission for access);

the record contains (a) trade secrets, or (b) financial, commercial, scientific or technical information, or (c) information about research by a third party, which could put that third party at a disadvantage in a negotiation or prejudice him in competition (unless that third party gives written permission for access);

access would put us in breach of a duty of confidence which we owe to a third party (unless that third party gives written permission for access);

access could reasonably be expected to (a) endanger someone's life or physical safety, or (b) prejudice or impair the security of a building, structure, system, means of transport or other property;

the record is privileged from being produced as evidence in legal proceedings (unless the person protected by the privilege has waived that protection);

if the request is for access to your PI, and you could not provide adequate proof of identity to us.

AVAILABILITY OF THE MANUAL

This Manual is available for inspection at the offices of SAIY Asset Management free of charge during normal business hours and copies are available upon request (and upon payment of a
reasonable amount), and on the SAIY website www.saiy.co.za. It is also available to the Information Regulator upon request. A fee for a copy of the Manual, shall be payable per A4 photocopy made (see Annexure B for Fees).

UPDATING OF THE MANUAL

The head of Compliance and Risk will, on a regular basis, update this manual.

PRESCRIBED FEES

The following applies to requests (other than personal requests):

A requestor is required to pay the prescribed fees (R140.00) before a request will be processed.

If the preparation of the record requested requires more than the prescribed hours (six), a deposit shall be paid (of not more than one third of the access fee which would be payable if the request were granted).

A requestor may lodge an application with a court against the tender/payment of the request fee and/or deposit.

Records may be withheld until the fees have been paid.

The fee structure is available on the Information Regulator’s website at www.inforegulator.org.za.