Steyn Capital Management

PAIA Manual

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.

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 designated Information Officer as identified in this manual.

Steyn Capital Management (Pty) Ltd (“the company” is a registered financial services provider (FSP number 37550) in terms of the Financial Advisory & Intermediary Service Act and regulated by the Financial Sector Conduct Authority (“FSCA”). The license enables the company to deliver the following services:

Category I – Advisory and Intermediary FSP:

Category II - Discretionary FSP

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. The company seeks 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. Its 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. It invests in securities where it assesses the value of the investee company to be considerably higher than the current market valuation and where it can ascertain the reason for the difference in valuation.

General information and contact details

Company registration number: 2008/018143/07

Registered address:
Verdi House, Klein D’Aria Estate
97 Jip de Jager Drive
Bellville , 7530

Postal address: PO Box 5673, Tygervalley, 7536
Website: steyncapitalmanagement.com
Telephone number: +27 (0) 21 001 4682
Email: info@steyncapitalmanagement.com
Designated Information Officer: Thea van Rooyen

Access to Records

PAIA grants a requester access to certain records of a private body if the said records are required to exercise or protect any rights of the requester. Should a public body lodge such a request, it must be acting in the public interest.

Any request for information in terms of PAIA, must be made in accordance with the prescribed form and manner, at the rates provided, as dealt with in this document.

The South African Human Rights Commission (“SAHRC”) has complied and published a useful guide in terms of section 10 of PAIA, containing valuable information for the purposes of exercising any right in terms of PAIA. The guide is made available in all official languages on the website of the SAHRC at the following URL: https://www.sahrc.org.za/home/21/files/Section%2010%20guide%202014.pdf

The contact details of the SAHRC are as follows:

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

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 PAIA) 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:

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.

Subjects and categories of records held by the company

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.

Companies Act Records

Revenue Records

Personnel documents and Records

Business & Operational Records

Technology Records

Marketing and Customer Relations Records

Compliance Records

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

The requester must complete the prescribed “Form C” to request access to the information as per section 6 above. Form C can be downloaded from the following URL: https://www.justice.gov.za/forms/form_paia.htm

This form must be submitted via conventional mail or e-mail, together with a request fee, to the designated Information Officer.

The form must:

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:

Denial of access

Access may be refused under limited circumstances, including:

Fees

A 7A requester who seeks access to a record containing personal information about that requester is not required to pay a request fee.

Every other requester, who is not a personal requester, must pay the required request fee, as prescribed from time to time. If the preparation of the record requested requires more than the prescribed hours (six), a deposit shall be paid (of not more than one third of the access fee which would be payable if the request were granted). A requestor may lodge an application with a court against the tender / payment of the request fee and / or deposit.

Records may be withheld until the fees have been paid. The fees can be downloaded from the following URL: https://www.sahrc.org.za/home/21/files/PAIA%20Notice%20on%20fees.pdf

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 PAIA for further details on the Appeal Process.

Availability of the manual

This manual is available for inspection at the offices of the company free of charge upon prior arrangement with the designated Information Officer.