Sylvania Platinum : Promotion of Access to Information Manual

PAIA MANUAL

The Sylvania Platinum Limited Group of Companies

This manual has been prepared in terms of the section 51 of the South African Promotion of Access to Information Act 2/2000 and to address the requirements of the Protection of Personal Information Act 4/2014, understanding that the primary operating functions of Sylvania Platinum Limited occur within the borders of South Africa, under the ambit of its South African based subsidiaries, therefore making the aforementioned legislation applicable.

Table of Contents
1.	Definitions ................................................................................................................	2
2.	Introduction ..............................................................................................................	2
3.	Contact Details ..........................................................................................................	3
4.	Guider of SAHRC..................................................................................................................	3
5.	Latest Notices in terms of section 52(2) of PAIA..............................................................	3
6.	Availability and publication of certain records in terms of PAIA........................................	3
7.	Request Process .........................................................................................................	5
8.	Grounds for refusal ....................................................................................................	6
9.	Remedies should a request be refused ..........................................................................	7
10.	Fees .........................................................................................................................	7
11.	POPI.........................................................................................................................	7

Page 1 of 15

1. Definitions
2. 1. "Client" refers to any natural or juristic person that received or receives services from the Sylvania Platinum Limited Group of Companies;
   2. "Conditions for Lawful Processing" refers to the conditions for the lawful processing of Personal Information as fully set out in chapter 3 of POPI and in paragraph 11 of this Manual;
   3. "Data Subject" - as ascribed thereto in section 1 of POPI;
   4. "Information Officer" - the duly authorised Head (as defined in section 1 of PAIA) of each of the Sylvania Platinum Limited Group of Companies;
   5. "Manual" - this manual prepared in accordance with section 51 of PAIA and regulation 4(1)
   6. 1. of the POPI Regulations;
   7. "PAIA" - the Promotion of Access to Information Act 2 of 2000;
   8. "Personal Information" - as ascribed thereto in section 1 of POPI;
   9. "Personnel" - any person who works for, or provides services to or on behalf of the Sylvania Platinum Limited Group of Companies , and receives or is entitled to receive remuneration and any other person who assists in carrying out or conducting the business of the Sylvania Platinum Limited Group of Companies, which includes, without limitation, directors (executive and non-executive), all permanent, temporary and part-time staff as well as contract workers;
   10. "POPI" - the Protection of Personal Information Act 4 of 2013;
   11. "POPI Regulations"- the regulations promulgated in terms of section 112(2) of POPI;
   12. "Private Body" - as ascribed thereto in sections 1 of both PAIA and POPI;
   13. "Processing" - as ascribed thereto in section 1 of POPI;
   14. "Records" - information requested and that can be obtained in accordance with this manual and applicable legislation as stipulated herein.
   15. "Requestor" - as ascribed thereto in section 1 of PAIA;
   16. "Request for Access" - as ascribed thereto in section 1 of PAIA;
   17. "Right" - as ascribed thereto within the Bill of Rights enshrined in the Constitution of South Africa Act 108 of 1996.
   18. "SAHRC" - the South African Human Rights Commission;
   19. "Sylvania" - Sylvania Platinum Limited Group of Companies
   20. Any other terms not described herein will have the meaning as ascribed to it in terms of PAIA or POPI.
3. Introduction
4. 1. For the purposes of POPI and PAIA, the Sylvania Platinum Limited Group of Companies are defined as private bodies. In accordance with Sylvania's obligations in terms of POPI and PAIA,of the Sylvania Platinum Limited Group of Companies have produced this manual.
   2. This manual sets out all information required by both PAIA and POPI.
   3. This manual also deals with how requests are to be made in terms of PAIA.

Page 2 of 15

1. 1. This manual also establishes how compliance with POPI is to be achieved.
2. Contact Details
3. 1. Business Name: Sylvania Platinum Limited
   2. Registered Office: Clarendon House, 2 Church Street, Hamilton, HM 11, Bermuda
   3. Office of Operations: Constantia Office Park, Cycad House, Ground Floor, Block 17, Corner 14th Avenue and Hendrik Potgieter Road, Weltevreden Park, Gauteng, South Africa, 1709
   4. South African Postal Address: PO Box 976, Florida Hills, Gauteng, 1716
   5. Directors: Stuart Angus Murray, Roger Williams, Eileen Carr, Adrian Reynolds, Jacobus Johannes Prinsloo, Lewanne Carminati
   6. Contact Person: Lisa Watermeyer
   7. Tel # of Contact Person: 011 673 1171
   8. E-MailAddress of Contact Person: [e-mail]
4. Guide of SAHRC
5. 1. A guide to PAIA has been published pursuant to section 10 of PAIA.
   2. The guide contains information required by an individual who may wish to exercise their rights in terms of PAIA.
   3. Should you wish to access the guide you may contact the SAHRC at the following details:
      PAIA UNIT
      Postal Address: Private Bag 2700, Houghton, 2041.
      Telephone: [phone]
      Website:http://www.sahrc.org.za
      Email|:[e-mail]
6. Latest Notices in terms of section 52(2) of PAIA
7. 1. At this stage no Notice(s) has / have been published.
8. Availability and publication of certain records in terms of PAIA
9. 1. The Sylvania Platinum Limited Group of Companies hold and/or process the following records for the purposes of PAIA and POPI.

Employment Contracts	On request in terms of PAIA

Page 3 of 15

Personal records provided by personal and third	On request in terms of PAIA
parties
Internal records, including internal evaluation of	On request in terms of PAIA
personnel
Correspondence in relation to personnel	On request in terms of PAIA
Training of personnel	On request in terms of PAIA
Records relating to all clients of the Sylvania Platinum	On request in terms of PAIA
Limited Group of Companies
Records generated for its clients by the Sylvania	On request in terms of PAIA
Platinum Limited Group of Companies
Operational records	On request in terms of PAIA
Database	On request in terms of PAIA
Information technology	On request in terms of PAIA
Marketing records	On request in terms of PAIA
Internal Correspondence	On request in terms of PAIA
Internal Policies	On request in terms of PAIA
Financial records	On request in terms of PAIA
Trade Secrets	On request in terms of PAIA
Domain Name Registrations	On request in terms of PAIA
Tradename Registrations	On request in terms of PAIA
Trademark Registrations	On request in terms of PAIA
Company Documentation	On request in terms of PAIA
Agreements With Suppliers	On request in terms of PAIA
Supplier Agreements	On request in terms of PAIA
Customer Agreements	On request in terms of PAIA
Website Information	On request in terms of PAIA

6.2. Information is available in terms of the following South African legislation, if and where applicable (the Records):

1. Basic Conditions of Employment Act No. 75 of 1997
2. Companies Act No. 71 of 2008
3. Compensation of Occupational Injuries and Diseases Act No. 130 of 193
4. Electronic Communications and Transactions Act No. 25 of 2002
5. Employment Equity Act No. 55 of 1998
6. Income Tax Act No. 58 of 1962

Page 4 of 15