Legal

1. INTRODUCTION

154 Investment Managers (Pty) Ltd is a private body as defined in the Promotion of Access to Information Act, 2 of 2000 (“PAIA”). This manual is compiled in accordance with Section 51 of PAIA and is intended to:

• Provide an overview of the records held by 154 Capital.
• Outline the procedure for requesting access to these records.
• Detail the requirements for processing personal information in terms of the Protection of Personal Information Act, 4 of 2013 (“POPIA”).

2. CONTACT DETAILS (Section 51(1)(a))

All requests for access to records under PAIA must be directed to the designated Information Officer:

• Head of Body / Information Officer: The Chief Executive Officer
• Physical Address: 90 Rivonia Road, Sandhurst, Sandton, Gauteng, 2196
• Postal Address: 90 Rivonia Road, Sandhurst, Sandton, Gauteng, 2196
• Telephone: +27 (011) 312 7551
• Email: compliance@154capital.com

3. THE INFORMATION REGULATOR’S GUIDE (Section 51(1)(b))

A guide on how to use PAIA (the “Section 10 Guide”) has been compiled by the South African Information Regulator. This guide contains information required by a person wishing to exercise any right contemplated in PAIA.

The guide is available from the Information Regulator (SA):

• Website: https://inforegulator.org.za/
• Email: enquiries@inforegulator.org.za

4. RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION (Section 51(1)(d))

154 Capital maintains records in accordance with other legislation, including but not limited to:

• Companies Act, 71 of 2008
• Financial Intelligence Centre Act, 38 of 2001
• Income Tax Act, 58 of 1962
• Value Added Tax Act, 89 of 1991
• Basic Conditions of Employment Act, 75 of 1997
• Protection of Personal Information Act, 4 of 2013

5. SUBJECTS AND CATEGORIES OF RECORDS HELD (Section 51(1)(e))

The following subjects and categories of records are held by 154 Capital. Access to these records is subject to the grounds for refusal as set out in PAIA.

6. RECORDS AUTOMATICALLY AVAILABLE (Section 51(1)(c))

The following categories of records are automatically available for inspection, purchase, or photocopying and do not require a formal PAIA request:

• Information and content published on the 154 Capital website.
• Any other marketing or informational material intended for public distribution.

7. PROCEDURE FOR REQUESTING ACCESS TO RECORDS

To request access to a record not listed in Section 6, the requester must use the prescribed form (Form 2). This form must be submitted to the Information Officer at the contact details provided in Section 2.

The requester must:

1. Provide sufficient particulars to enable the Information Officer to identify the record(s) requested and the identity of the requester.
2. Specify the form of access required.
3. Identify the right the requester is seeking to exercise or protect and explain why the requested record is required for that right.
4. If the request is made on behalf of another person, submit proof of the capacity in which the request is made.

The Information Officer will assess the request and notify the requester of the decision within 30 days. This period may be extended once for a further 30 days under specific circumstances.

8. PRESCRIBED FEES

The following fees are payable:

• Request Fee: A prescribed request fee is payable by all requesters (other than personal requesters).
• Access Fee: If the request is granted, an access fee is payable for the search, preparation, and reproduction of the records.

A full schedule of fees is available from the Information Officer or on the Information Regulator’s website.

9. GROUNDS FOR REFUSAL OF ACCESS (Chapter 4 of PAIA)

A request for access may be refused on grounds specified in PAIA, including, but not limited to:

• Mandatory protection of the privacy of a third party (natural person).
• Mandatory protection of the commercial information of a third party.
• Mandatory protection of confidential information of a third party.
• Protection of the commercial information of 154 Capital.
• Protection of research information.

10. PROCESSING OF PERSONAL INFORMATION (POPIA) (Section 51(1)(c))

154 Capital processes personal information in compliance with POPIA for the following purposes:

• Purpose of Processing:
  • To conduct our business as a proprietary investment firm.
  • To perform Customer Due Diligence (CDD) as required by FICA.
  • For employment and human resources management.
  • For general administration, finance, and procurement.
  • To respond to enquiries from our website or other channels.
• Categories of Data Subjects and Information Processed:
  • Employees: Name, ID number, contact details, employment history, tax information, remuneration.
  • Counterparties (Individuals, Directors, Shareholders): Name, ID/passport number, contact details, proof of address, source of funds (as required by FICA).
  • Service Providers: Names, contact details, registration numbers, VAT numbers, banking details.
  • Website Users: Name, email, phone number (if provided via contact form), cookie data (with consent).
• Recipients of Personal Information:
  • Personal information is accessible only by authorized 154 Capital personnel.
  • It may be shared with regulatory bodies (e.g., FIC, FSCA, SARS) as required by law.
  • It may be shared with service providers (e.g., payroll, IT) who are bound by confidentiality and data protection agreements.
• International Transfers:
  • Personal information may be transferred between our offices in South Africa and Mauritius. Both jurisdictions have adequate data protection laws (POPIA and the DPA).
• Security Measures:
  • We employ appropriate technical and organizational measures to secure the integrity and confidentiality of all personal information in our possession.

11. AVAILABILITY OF THE MANUAL

This manual is available for inspection, free of charge, at the offices of 154 Investment Managers (Pty) Ltd and on our website.