Promotion of Access to Information Act
Manual

1. Introduction

This manual is published in terms of Section 51 of the Promotion of Access to Information Act, No. 2 of 2000 ("PAIA"). PAIA gives effect to the constitutional right of access to any information held by the State and any information held by another person that is required for the exercise or protection of any rights.

SV Capital (Pty) Ltd ("SV Capital") is committed to transparency and to fulfilling its obligations under PAIA. This manual describes the categories of records held by SV Capital and the process for requesting access to those records.

2. About SV Capital

3. Information Officer

The Information Officer is responsible for receiving and processing PAIA requests on behalf of SV Capital.

4. Guide on How to Use PAIA

The South African Human Rights Commission (SAHRC) has published a guide on how to use PAIA. This guide is available from the SAHRC at PAIA@sahrc.org.za or at the SAHRC's offices. Any person who requires assistance with a request may also contact the Information Regulator of South Africa.

5. Categories of Records Held

SV Capital holds the following categories of records:

5.1 Corporate and Statutory Records

• Memorandum of Incorporation and company registration documents
• Minutes of board and shareholder meetings
• Annual financial statements and audited accounts
• FSP licence and FSCA correspondence
• Regulatory filings and compliance reports

5.2 Investor Records

• Investor account information and FICA/KYC documents
• Investment agreements and product term sheets
• Transaction records and account statements
• Maturity and payout records
• Correspondence and support communications

5.3 Investment Pool Records

• Investment pool agreements and underlying asset documentation
• Pool performance reports and valuations
• Cattle purchase/sale records (for cattle-backed pools)
• Solar project agreements and generation reports (for solar pools)
• Delivery bike fleet agreements and repayment records
• Short-term debt agreements and repayment records

5.4 Financial Records

• General ledger and accounting records
• Bank statements and payment records
• Fee and commission records
• VAT returns and SARS correspondence
• Tax certificates issued to investors

5.5 Human Resources Records

• Employee contracts and personnel files
• Payroll records
• Training and competency records
• Disciplinary and grievance records

5.6 Operational Records

• IT system records and security logs
• Marketing materials and communications
• Service provider contracts
• Insurance policies

6. How to Request Access to Records

Any person wishing to access records held by SV Capital must submit a written request using the prescribed PAIA Form C, available from the South African Human Rights Commission or the Department of Justice.

7. Fees

The following fees apply to PAIA requests (as prescribed by the PAIA Regulations):

Note: Requesters who are unable to pay fees may apply for exemption by submitting a written motivation. Fees are subject to change in accordance with PAIA Regulations.

8. Grounds for Refusal

SV Capital may refuse access to records on grounds provided in Chapter 4 of PAIA, including but not limited to:

• Protection of the privacy of a third party (personal information)
• Commercial information of third parties (trade secrets, confidential business information)
• Confidential correspondence with an attorney (legal privilege)
• Records that could endanger the safety of an individual
• Records that are publicly available
• Records the disclosure of which would constitute a breach of a duty of confidence

9. Remedies if Access is Refused

If SV Capital refuses access to a record, the requester may:

• Apply to the Information Regulator for a review of the decision within 30 days of receiving the refusal
• Apply to a court for relief, upon exhausting the internal remedies

The Information Regulator can be contacted at:

10. Records Available Without a Formal PAIA Request

Certain categories of records are made available by SV Capital without requiring a formal PAIA request:

• This PAIA Manual (publicly available)
• POPIA Privacy Notice
• Terms of Use
• Complaints Policy
• General product information and marketing materials
• Investor's own account records (available via the investor portal)
• Own investment agreements and statements (available on request via email)

11. Updating This Manual

This manual will be updated at least annually or when there is a material change in SV Capital's information holdings or PAIA procedures. The current version is available on the SV Capital website and will be provided free of charge to any person who requests it.