PAIA MANUAL

1. INTRODUCTION

This Manual has been prepared in accordance with Section 51 of the Promotion of Access to Information Act, 2000 ("PAIA") and gives effect to the constitutional right of access to information held by private bodies where such information is required for the exercise or protection of any rights.

Sandton Index (Pty) Ltd ("Sandton Index", "the Company", "we", "our", or "us") is committed to transparency, accountability, and compliance with applicable South African legislation, including PAIA and the Protection of Personal Information Act, 2013 ("POPIA").

This Manual provides information regarding the records held by Sandton Index and the procedures to be followed when requesting access to such records.

2. COMPANY PARTICULARS

3. PURPOSE OF THIS MANUAL

The purpose of this Manual is to:

• Describe the categories of records held by Sandton Index.
• Explain how to request access to records.
• Provide details of the Information Officer.
• Outline the procedures prescribed by PAIA.
• Provide information regarding rights under POPIA.
• Facilitate requests for access to information.

4. INFORMATION OFFICER

In terms of POPIA and PAIA, the Information Officer of Sandton Index is responsible for overseeing requests for access to information.

All PAIA requests should be submitted in writing to the Information Officer.

5. GUIDE ON HOW TO USE PAIA

A guide explaining how to exercise rights under PAIA is available from the Information Regulator.

The Information Regulator may amend its contact details from time to time. Users should consult the official Information Regulator website for current information.

6. APPLICABLE LEGISLATION

Sandton Index maintains records in accordance with, among others, the following legislation:

• Companies Act 71 of 2008
• Promotion of Access to Information Act 2 of 2000
• Protection of Personal Information Act 4 of 2013
• Electronic Communications and Transactions Act 25 of 2002
• Basic Conditions of Employment Act 75 of 1997
• Employment Equity Act 55 of 1998
• Labour Relations Act 66 of 1995
• Occupational Health and Safety Act 85 of 1993
• Income Tax Act 58 of 1962
• Value-Added Tax Act 89 of 1991
• Financial Intelligence Centre Act 38 of 2001 (where applicable)
• Consumer Protection Act 68 of 2008
• Any other legislation applicable to the Company's operations.

7. RECORDS AUTOMATICALLY AVAILABLE

Certain information may be made available without a formal PAIA request. Examples include:

• Public company information
• Website content
• Public announcements
• Published policies
• Marketing materials
• Public notices
• Contact information

Availability of such records remains at the discretion of the Company.

8. CATEGORIES OF RECORDS HELD BY SANDTON INDEX

The following categories describe records maintained by the Company:

Corporate Records

• Memorandum of Incorporation
• Company registration documents
• Shareholder records
• Director records
• Governance documents
• Statutory records
• Compliance records

Financial Records

• Accounting records
• Tax records
• Financial statements
• Banking records
• Invoices
• Receipts
• Audit records
• Payment records

Human Resources Records

• Employment contracts
• Personnel files
• Payroll records
• Leave records
• Training records
• Performance records
• Recruitment records

Customer and User Records

• User registration records
• Verification records
• Membership records
• Account information
• Communication records
• Payment records
• Project submission records
• Platform activity records

Project and Marketplace Records

• Project applications
• Project verification records
• Project approvals
• Project communications
• Capital partner interactions
• Introduction records
• Marketplace activity records

Legal and Compliance Records

• Contracts
• Agreements
• Legal opinions
• Regulatory correspondence
• Compliance reports
• Litigation records
• Dispute records

Information Technology Records

• Website records
• System logs
• Security records
• Access records
• Backup records
• User activity logs
• Audit logs

9. PROCESSING OF PERSONAL INFORMATION

Sandton Index processes personal information in accordance with POPIA. Personal information may include:

• Identity information
• Contact information
• Verification information
• Financial information
• Membership information
• Communication records
• Technical information
• Transaction information

Personal information is processed only for lawful and legitimate business purposes.

10. PURPOSES FOR PROCESSING PERSONAL INFORMATION

Personal information may be processed for:

• Identity verification
• Membership administration
• Platform operation
• User authentication
• Security monitoring
• Fraud prevention
• Customer support
• Project verification
• Regulatory compliance
• Financial administration
• Communication with users
• Contractual obligations
• Legal obligations

11. RECIPIENTS OF PERSONAL INFORMATION

Personal information may be shared with:

• Employees
• Service providers
• Payment processors
• Professional advisors
• Regulatory authorities
• Law enforcement agencies
• Auditors
• Technology providers

Information will only be disclosed where legally permitted or required.

12. TRANSBORDER INFORMATION FLOWS

Certain service providers may process information outside South Africa.

Where personal information is transferred internationally, Sandton Index will take reasonable steps to ensure appropriate safeguards are in place in accordance with POPIA.

13. INFORMATION SECURITY

Sandton Index implements reasonable technical and organisational measures to protect information against:

• Unauthorised access
• Loss
• Misuse
• Disclosure
• Alteration
• Destruction

Security measures may include:

• Access controls
• Encryption
• Secure servers
• Password protection
• Monitoring systems
• Audit logging
• Staff confidentiality obligations

14. REQUEST PROCEDURE

A requester seeking access to information must submit a written request to the Information Officer.

The request should include:

• Full name and surname
• Contact details
• Identification details
• Description of the requested record
• Reason for requesting access
• Description of the right to be exercised or protected
• Preferred form of access

Requests should be sent to: legal@sandtonindex.com

15. REQUEST FEES

Sandton Index may charge request fees and access fees as permitted under PAIA.

Applicable fees will be communicated to the requester before records are released.

Payment may be required before processing or releasing requested information.

16. RESPONSE TO REQUESTS

The Company will consider requests in accordance with PAIA. A response may:

• Grant access
• Partially grant access
• Refuse access
• Request additional information

Responses will be communicated within the period prescribed by applicable law.

17. GROUNDS FOR REFUSAL OF ACCESS

Access may be refused where permitted by PAIA, including where disclosure would:

• Unreasonably disclose personal information of another person
• Reveal confidential commercial information
• Breach confidentiality obligations
• Compromise security measures
• Prejudice legal proceedings
• Endanger individuals
• Violate intellectual property rights
• Be prohibited by law

The Company reserves all rights provided under PAIA.

18. REMEDIES AVAILABLE

Where a requester is dissatisfied with a decision, the requester may:

• Request reasons for the decision;
• Submit a complaint to the Information Regulator; or
• Seek appropriate legal remedies in accordance with applicable legislation.

19. AVAILABILITY OF THIS MANUAL

This Manual is available:

• On the Company's website at www.sandtonindex.com;
• Upon written request to legal@sandtonindex.com; and
• In any other manner required by applicable law.

20. MANUAL UPDATES

Sandton Index reserves the right to amend this Manual from time to time to reflect changes in legislation, regulatory requirements, business operations, or Company policies.

The latest version of this Manual shall supersede all previous versions.

21. CONTACT DETAILS

End of PAIA Manual