1       Introduction

This manual is published in terms of Section 51 of the Promotion of Access to Information Act, No. 2 of 2000 (“the Act” / “PAIA”). It is intended to foster a culture of transparency and accountability by giving effect to the right to information that is required for the exercise or protection of any right and to actively promote a society in which the people of South Africa have effective access to information to enable them to more fully exercise and protect their rights.

The Act gives effect to the provisions of Section 32 of the Constitution of the Republic of South Africa, which provides for the right of access to information held by the State and to information held by another person that is required for the exercise and / or protection of any right.

Section 9 of the Act however recognises that such right to access to information cannot be unlimited and should be subject to justifiable limitations, including, but not limited to:

  • Limitations aimed at the reasonable protection of privacy;
  • Commercial confidentiality;
  • Effective, efficient and good governance;
  • And in a manner which balances that right with any other rights, including such rights contained in the Bill of Rights in the Constitution.

This manual provides a reference to the records held by Steyn Capital Management (Pty) Ltd (“the company”) and the process that needs to be adopted to access such records. All requests for access to information (other than information that is available to the public) should be addressed to the contact person as identified in this manual, as she is our designated Information Officer.


2       Steyn Capital Management (Pty) Ltd

Steyn Capital Management (Pty) Ltd is a registered financial services provider (FSP number 37550). The license enables the company to deliver the following services:

  • Category      I – Advisory and Intermediary FSP: Securities and Instruments: Shares and      Derivative Instruments
  • Category      II - Discretionary FSP: Securities and Instruments: Shares and Derivative      Instruments
  • Category      IIA – Hedge Fund FSP

The company obtained its license to act as a financial services provider in June 2009 and is a value-orientated alternative investment manager focussed on investing principally in publicly traded African equity securities. We seek to maximise investor capital by buying securities with trading values materially lower than their intrinsic values, and by selling short securities with trading values materially higher than their intrinsic values. Our aim is to achieve high absolute rates of return over the long term while minimising the risk of capital loss. 

The company combines the analytical discipline of determining fair value with a practical understanding of markets. We invest in securities where we assess the value of the company to be considerably higher than the current market valuation and where can ascertain the reason for the difference in valuation.

3       General information and contact details

Company registration number:                       2008/018143/07

Registered address:                                       Verdi House

                                                                       Klein D'Aria Estate

                                                                       97 Jip de Jager Drive




Postal address:                                               PO Box 5673



Website:                                                           www.steyncapital.co.za

Telephone number:                                         (021) 001 4682

Email:                                                               info@steyncapitalmanagement.com

Director:                                                           André Steyn

Shareholder and Chief Executive Officer:        André Steyn

Chief Operating Officer:                                   Jamie Kent

Chief Financial Officer:                                    Thea van Rooyen

Designated Information Officer:                       Thea van Rooyen


4       Guide of South Africa Human Rights Commission

A guide has been complied in terms of Section 10 of PAIA by the Human Rights Commission. It contains information required by a person wishing to exercise any right, contemplated by PAIA. It is available in all of the official languages.

The Guide is available for inspection, inter alia, at the office of the offices of the Human Rights Commission at Braampark forum 3, 33 Hoofd Street, Braamfontein, and on its website at www.sahrc.org.za.

The Guide describes in each official language:

  • What the objects of the Act are;
  • The details of each private body (where possible);
  • The process that needs to be followed in order to make a request;
  • How to get copies of the Guide at no charge;
  • How to get access to the manual of a private body; and
  • All  the legal remedies available to you.

The Guide was printed in each official language in the Government Gazette.

Please direct queries to:

The South African Human Rights Commission

PAIA Unit – The Research and Documentation Department

Postal address: Private Bag 2700, Houghton, 2041

Telephone: +27 (0)11 877 3600

Fax: +27 (0)11 403 0625

Website: www.sahrc.org.za

E-mail: PAIA@sahrc.org.za

For your convenience and information, some extracts of the Guide are summarised below. Note that these extracts are abridged and do not purport to be a full or accurate copy. Please refer to the original guide.


5       Records available in terms of other legislation

All records that can be accessed without the submission of a formal request (i.e. a formal request as defined by the Promotion of Access to Information Act) can be accessed by contacting our designated Information Officer. Additionally, we are required to ensure that certain records are available in terms of other legislation, which are mentioned below:

  • 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 Affairs (Unfair Business Practices) Act 71 of 1988
  • Consumer Protection Act 98 of 1978
  • Employment Equity Act 55 of 1998
  • Financial Advisory and Intermediary Services Act 37 of 2002 (“FAIS”)
  • Financial Intelligence Centre Act 38 of 2001 (“FICA”)
  • Harmful Business Practices Act 23 of 1999
  • Income Tax Act 95 of 1967
  • Labour Relations Act 66 of 1995
  • Occupational Health & Safety Act 85 of 1993
  • Prevention of Organised Crime Act 121 of 1998
  • Protection of Businesses Act 99 of 1978
  • Security Services Act 36 of 2004
  • Skills Development Levies Act 9 of 1999
  • Skills Development Act 97 of 1998
  • Unemployment Contributions Act 4 of 2002
  • Unemployment Insurance Act 63 of 2001
  • Value Added Tax 89 of 1991

Please note that while we have made every effort to identify all pertinent legislation, we cannot guarantee that all legislation has been included. Should you be aware of any specific legislation that should be included and which has been omitted, please contact our designated Information Officer.


6       Subjects and categories of records held by Steyn Capital Management

We set out below the subjects / categories and some examples of the records that are held by the company and which may be the subject of a request for the purpose of the Act. Please note that our records can be found in various forms including electronic or paper.


  • Documents of incorporation
  • Memorandum of incorporation
  • Minutes of Board of directors meetings
  • Records relating to the appointment of directors / auditors / secretary / public officer and other officers
  • Share register and other statutory registers
  • Annual financial statements
  • Tax returns
  • Accounting records
  • Banking records, bank statements, electronic banking records
  • Rental agreements
  • Invoices
  • Insurance information
  • Property / investments held or owned
  • Financial reports, balance sheets, income statements


  • PAYE records
  • Documents issued to employees for income tax purposes
  • Records of payments made to SARS on behalf of employees
  • All other statutory compliances:   VAT, Skills development levies, UIF, Workmen’s compensation


  • Employment  contracts
  • Disciplinary records
  • Salary records
  • Records of training provided to employees


  • E-mails
  • Business process and activity documentation
  • Agreements with clients
  • Contracts with service providers
  • Investor records
  • Investor information
  • Investment-related documentation
  • Policy-related documentation


  • Licenses
  • Software packages
  • Operating systems
  • Service provider contracts


  • Introductory material
  • Description of products & services
  • Correspondence
  • Factsheets and quarterly letters


  • Compliance reports
  • Statutory information
  • Information required by FAIS and FICA


7       Procedure to follow when submitting a formal request of access to records

The requester must complete Form C of Annexure B as identified in Regulation 6 of the Government Notice Number 187 of 15 February 2002. This form must be submitted via conventional mail or e-mail, together with a request fee, to the designated Information Officer. A copy of Form C has been included at the end of this manual.

The form must:

  • Provide  sufficient particulars to enable the Information Officer to identify the record(s) requested and to identify the requester;
  • Indicate which form of access is required;
  • Specify a postal address or fax number of the requester is seeking to exercise or protect, and provide an explanation as to why the requested record is required for the exercise or protection of that right.

If in addition to a written reply, the requester wishes to be informed of the decision on the request in any other manner, the form must state that manner and the necessary particulars to be informed in the other manner.

If the request is made on behalf of another person, the requester must submit written and adequate proof of the capacity in which the requester is making the request.

Our designated Information Officer will respond to the request within 30 days of receiving the request by indicating whether the request for access has been granted. Please note that the successful completion and submission of an access request form does not automatically allow the requester access to the requested record.

Assuming the request of access is granted, the requester will be able to gain access to the requested records as soon as is reasonably possible and once the access fee has been paid.

Access will be granted to a record if the following criteria are fulfilled:

  • The record is required for the exercise or protection of any right;
  • The requester complies with the procedural requirements in the Act relating to  a request; and
  • Access to the record is not refused in terms of any ground for refusal as contemplated in Chapter 4 of Part 3 of the Act.


8       Denial of access

Access may be refused under limited circumstances, including:

  • Protecting personal information that the company holds about a third person from unreasonable disclosure;
  • Protecting commercial information that we hold about a third party (for example trade secrets: financial, commercial, scientific or technical information that may harm the commercial or financial interests of a third party);
  • If disclosure would result in a breach of a duty of confidence owed to a third party;
  • If disclosure would jeopardise the safety or life of an individual;
  • If disclosure would prejudice or impair the security of property;
  • If disclosure would prejudice or impair the protection of a person in accordance with a witness protection scheme;
  • If disclosure would prejudice or impair the protection of the safety of the public;
  • The record is privileged from production in legal proceedings unless the privilege has been waived;
  • If the record is a computer programme;
  • Disclosure of the record will put the company at a disadvantage in contractual or other negotiations or prejudice it in commercial competition;
  • Disclosure of the record (containing trade secrets, financial, commercial, scientific, or technical information) would harm the commercial or financial interests of the company; and
  • Records containing information about research being carried out or about to be carried out on behalf of a third party or the company.


9       Fees

The applicable fees are prescribed in terms of the regulations that relate to the Act. There are two basic types of fees applicable – “request” and “access” fees. The non-refundable request fee (currently R57.00 inclusive of VAT) is payable on submission of the request for access to a record (unless the request is for personal records of the requester in which event there is no applicable fee).

The access fee is payable prior to gaining access to the records in the required form.

The applicable fees are prescribed in terms of Part III of Annexure A as identified in Government Notice Number 187 of 15 February 2002 and is available on www.sahrc.gov.za.


10    Requests for access to information about third parties

If a request is received to access a record that contains information about a third party, we are obliged to attempt to contact this third party to inform them of the request and to give them an opportunity to respond by either consenting to the access or by providing reasons why the access should be denied.

In the event that the third party furnishes reasons for the support or denial of access, our designated Information Officer will consider these reasons in determining whether access should be granted. The requester may appeal against a refusal of access by our designated Information Officer.

Please refer to Part 4 of the Promotion of Access to Information Act for further details on the Appeal Process.