Category I – Advisory and Intermediary FSP:

• Shares
• Derivative Instruments
• Participatory interests in a hedge fund

Category II – Discretionary FSP

• Shares
• Derivative Instruments
• Participatory interests in a hedge fund
• Participatory interests in collective investment schemes

Category IIA – Hedge Fund FSP

• Participatory interests in a hedge fund
• General Category IIA experience

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: Jamie Kent

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:

• 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.

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

• 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
• Asset register
• Rental agreements
• Invoices
• Insurance information
• Property / investments held or owned
• Financial reports, balance sheets, income statements

Revenue Records

• 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

Personnel documents and Records

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

Business & Operational Records

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

Technology Records

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

Marketing and Customer Relations Records

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

Compliance Records

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

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:

• Provide sufficient particulars to enable the Information Officer to identify the record(s) requested and to identify the requester;
• Indicate the information being requested and the required format;
• Provide sufficient detail in respect of his/her contact details and if the requester wishes to be informed of the decision of the company in any manner (in addition to written), the manner and particulars thereof;
• Specify the right 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 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.

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.

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.