Last Updated: 1 January 2025

Section 1: Introduction and Purpose

This manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000) ("PAIA") and applies to Richters Corporate Advisory & Forensics (Pty) Ltd ("the Company").

The purpose of this manual is to foster a culture of transparency and accountability by giving effect to the constitutional right of access to information held by private bodies, subject to justifiable limitations.

Section 2: Contact Details

Section 3: Information Officer

In terms of Section 51(1)(a) of PAIA, the Company has appointed an Information Officer responsible for processing requests for access to information.

Section 4: Guide on How to Use PAIA

The South African Human Rights Commission (SAHRC) has compiled a guide to assist persons wishing to exercise their rights under PAIA. The guide is available in all official languages and contains information on:

• The objects of PAIA
• How to request access to information
• Remedies available if a request is refused
• The functions and contact details of the Information Regulator

How to Obtain the Guide:

• Website: www.sahrc.org.za
• Email: PAIA@sahrc.org.za
• Telephone: +27 11 877 3600
• Physical Address: 29 Princess of Wales Terrace, Cnr York & St Andrews Street, Parktown, Johannesburg

Section 5: Categories of Records Held

The Company holds various categories of records in accordance with statutory requirements and operational needs. These records include, but are not limited to:

5.1 Corporate and Statutory Records

• Certificate of Incorporation and Memorandum of Incorporation
• Directors' register and shareholders' register
• Minutes of board meetings and shareholder meetings
• Annual financial statements and audit reports
• Tax returns and SARS assessments
• VAT, PAYE, and UIF records
• B-BBEE certificates and compliance documentation
• Professional indemnity insurance certificates

5.2 Client and Engagement Records

• Client engagement letters and service agreements
• FICA/KYC documentation and client due diligence records
• Conflict of interest checks and clearance certificates
• Fee agreements, invoices, and billing records
• Work product, deliverables, and reports
• Client communication records (email, correspondence, meeting notes)
• File opening and closure documentation

5.3 Employment and Human Resources Records

• Employment contracts and job descriptions
• Personnel files and performance reviews
• Payroll records and remuneration details
• Leave records and attendance registers
• Disciplinary and grievance records
• Training and development records
• Employment equity and skills development records

5.4 Financial and Accounting Records

• General ledger, journals, and trial balances
• Bank statements and reconciliations
• Accounts payable and receivable records
• Asset registers and depreciation schedules
• Management accounts and budgets
• Expense claims and supporting documentation

5.5 Professional Regulatory Records

• Law Society practicing certificates and annual renewals
• SAICA/SAIPA membership certificates
• CIPC insolvency practitioner registration
• Continuing Professional Development (CPD) records
• Professional conduct compliance documentation
• Fidelity fund and professional indemnity claims records

5.6 Information Technology and Data Records

• IT policies and procedures
• Software licenses and service agreements
• Data backup and disaster recovery records
• Cybersecurity incident reports
• Access control and audit logs
• Website analytics and user data (anonymized)

5.7 Marketing and Communications Records

• Marketing materials and publications
• Website content and digital assets
• Client testimonials and case studies (with consent)
• Media releases and public statements
• Newsletters and email marketing records

Section 6: How to Request Access to Records

A request for access to information must be made on the prescribed form (Form A or Form C) as set out in Annexure A and B of the PAIA Regulations, and must:

• Be addressed to the Information Officer
• Provide sufficient detail to enable the Information Officer to identify the record
• Specify the form in which access is required (inspection, copy, transcript, etc.)
• Specify the postal or email address for correspondence
• Identify the right the requester is seeking to exercise or protect and explain why the record is required
• Be accompanied by the prescribed request fee (if applicable)

Request Forms

The prescribed PAIA request forms can be obtained from:

• The Information Officer at paia@richtersconsulting.com
• The Information Regulator website: www.justice.gov.za/inforeg
• The SAHRC website: www.sahrc.org.za

Section 7: Grounds for Refusal of Access

Access to a record may be refused on the following grounds, as provided in PAIA:

7.1 Mandatory Protection of Privacy of Third Parties (Section 63)

Access must be refused if disclosure would involve the unreasonable disclosure of personal information about a third party.

7.2 Mandatory Protection of Commercial Information (Section 64)

Access must be refused if the record contains:

• Trade secrets of a third party
• Financial, commercial, scientific, or technical information that could harm the commercial or financial interests of a third party
• Information disclosed in confidence that could prejudice future supply of similar information

7.3 Mandatory Protection of Confidential Information (Section 65)

Access must be refused if the record contains information protected by legal professional privilege, attorney-client privilege, or settlement negotiations.

7.4 Protection of Safety of Individuals and Property (Section 66)

Access may be refused if disclosure could endanger the life or physical safety of an individual or prejudice the security of property.

7.5 Commercially Sensitive Information (Section 68)

Access may be refused if the record contains:

• Trade secrets of the Company
• Financial, commercial, scientific, or technical information that could harm the commercial or financial interests of the Company
• Information that could put the Company at a disadvantage in negotiations or commercial competition

7.6 Research Information (Section 69)

Access may be refused if premature disclosure would expose the Company to serious disadvantage in research or commercial exploitation.

Section 8: Processing of Requests and Timeframes

Upon receipt of a valid PAIA request:

• The Information Officer will acknowledge receipt within 7 days
• A decision on the request will be made within 30 days of receipt
• The timeframe may be extended by a further 30 days if the request is complex or involves a large volume of records, with written notice to the requester
• If access is granted, the record will be provided in the requested format (subject to practical limitations)
• If access is refused, the requester will be notified in writing with reasons for the refusal and information on internal appeal or external remedies

Section 9: Fees

PAIA prescribes fees for requesting and accessing records:

9.1 Request Fee

A request fee of R50.00 is payable when submitting Form C (requests other than personal records). No fee is payable for personal information requests using Form A.

9.2 Access Fees

If access is granted, the following fees may apply:

• Photocopies (A4): R1.10 per page
• Printed copies (A4): R0.75 per page
• CD/DVD with information: R70.00 per disc
• Transcript of audio/visual records: R20.00 per page
• Inspection of records: No charge for first hour, R30.00 per hour thereafter
• Postage: Actual postal or courier cost

Note: Fees are subject to change in accordance with PAIA Regulations.

9.3 Fee Exemptions

Requesters who cannot afford the prescribed fees may apply for an exemption by completing the relevant section of the request form and providing supporting documentation.

Section 10: Remedies Available if Request is Refused

If a PAIA request is refused, the requester has the following remedies:

10.1 Internal Appeal

The requester may lodge an internal appeal with the Company's head of the private body within 60 days of notification of the decision.

10.2 Application to Court

The requester may apply to a court of competent jurisdiction for appropriate relief within 180 days of notification of the decision.

10.3 Complaint to Information Regulator

The requester may lodge a complaint with the Information Regulator:

Section 11: Records Automatically Available

The following records are automatically available without the need for a formal PAIA request:

• This PAIA Manual
• Privacy Policy (POPIA compliance)
• Terms of Use
• Professional Services Disclaimer
• Company registration details (available from CIPC)
• Published marketing materials and website content

These documents are available on our website at www.richtersconsulting.com or by contacting the Information Officer.

Section 12: Records Subject to Other Legislation

Certain records held by the Company are subject to access provisions in other legislation, including:

• Companies Act 71 of 2008: Company records, financial statements, directors' registers
• Basic Conditions of Employment Act 75 of 1997: Employment records
• Labour Relations Act 66 of 1995: Disciplinary and dismissal records
• Employment Equity Act 55 of 1998: Employment equity plans and reports
• Tax Administration Act 28 of 2011: Tax returns and assessments
• Financial Intelligence Centre Act 38 of 2001: Client due diligence and transaction records
• Protection of Personal Information Act 4 of 2013: Personal information of data subjects
• National Credit Act 34 of 2005: Credit agreements and consumer information

Access to such records will be governed by the applicable legislation in conjunction with PAIA.

Section 13: Data Protection and POPIA Alignment

This PAIA Manual operates in conjunction with the Company's Privacy Policy and POPIA compliance framework. Personal information held by the Company is processed in accordance with POPIA's eight conditions for lawful processing, and data subjects have rights of access, correction, and deletion as provided by both PAIA and POPIA.

For information on how we process personal information, please refer to our Privacy Policy.

Section 14: Updates and Amendments

This PAIA Manual will be reviewed and updated annually or as required by changes in legislation or business operations. The current version is always available on our website and from the Information Officer.

Section 15: Contact for PAIA Requests

All PAIA requests and inquiries should be directed to:

This PAIA Manual is prepared in compliance with Section 51 of the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000) and is effective as of the date stated above.