PAIA Manual
Privacy Policy

Vunani Capital Partners Limited Registration no: 2019/431743/06
1) Introduction – This disclaimer governs your use of our website; by using our website, you accept this disclaimer in full. If you disagree with any part of this disclaimer, do not use our website.

(2) Intellectual Property Rights – Unless otherwise stated, we or our licensors own the intellectual property rights in the website and material on the website. Subject to the licence below, all our intellectual property rights are reserved.

(3) Licence to Use Website – You may view, download for caching purposes only, and print pages from the website, provided that:

(a) You must not republish material from this website (including republication on another website) or reproduce or store material from this website in any public or private electronic retrieval system. (Though we encourage fair use for academic / non-commercial purposes)

(b) You must not reproduce, duplicate, copy, sell, resell, visit, or otherwise exploit our website or material on our website for a commercial purpose, without our express written consent.

(4) Limitations of Liability – The information on this website is provided free-of-charge, and you acknowledge that it would be unreasonable to hold us liable in respect of this website and the information on this website. Whilst we endeavour to ensure that the information on this website is correct, we do not warrant its completeness or accuracy; nor do we not commit to ensuring that the website remains available or that the material on this website is kept up-to-date. To the maximum extent permitted by applicable law we exclude all representations, warranties, and conditions (including, without limitation, the conditions implied by law of satisfactory quality, fitness for purpose and the use of reasonable care and skill). Our liability is limited and excluded to the maximum extent permitted under applicable law. We will not be liable for any direct, indirect, or consequential loss or damage arising under this disclaimer or in connection with our website, whether arising in tort, contract, or otherwise – including, without limitation, any loss of profit, contracts, business, goodwill, data, income, revenue, or anticipated savings. However, nothing in this disclaimer shall exclude or limit our liability for fraud, for death or personal injury caused by our negligence, or for any other liability which cannot be excluded or limited under applicable law.

(5) Forum Posting / Comments – You must not use our website in any way that causes, or may cause, damage to the website or impairment of the availability or accessibility of the website. You must not use our website in any way which is unlawful, illegal, fraudulent, or harmful, or in connection with any unlawful, illegal, fraudulent, or harmful purpose or activity. You must not use our website for any purposes related to marketing without our express written consent. You must not use our website to copy, publish or send mass mailings or spam. You must not use our website to copy, publish or send material which is illegal or unlawful, or material which could give rise to legal action under English and other applicable law. All material you copy, publish or send via our website must not be defamatory, obscene, indecent, hateful, discriminatory or inflammatory; such material must not infringe any person’s intellectual property rights or rights of confidence, impinge upon any person’s privacy, or constitute incitement to commit a crime; further, material must not be misleading, deceptive, pornographic, threatening, abusive, harassing or menacing. We reserve the right to edit or remove any material posted upon our website. We may take such action as we deem appropriate to deal with the posting of unsuitable material, including suspending or cancelling your account, restricting your access to our website, or commencing legal proceedings against you. In respect of all material that you post on our website, you grant to us a worldwide, irrevocable, non-exclusive, royalty-free licence to use, reproduce, adapt, publish, translate and distribute such material in any media, together with the right to sub-licence such rights.

(6) Third party websites: The website contains links to other websites. We are not responsible for the content of third-party websites.

(7) Variation – We may revise this disclaimer from time-to-time. Please check this page regularly to ensure you are familiar with the current version

(8) Entire agreement – This disclaimer constitutes the entire agreement between you and us in relation to your use of our website and supersedes all previous agreements in respect of your use of this website

(9) Law and Jurisdiction – This notice will be governed by and construed in accordance with South African law, and any disputes relating to this notice shall be subject to the exclusive jurisdiction of the courts of South Africa.

(10) Our Contact Details – You can contact us via email on:

Users of this website are bound by these terms and conditions. If you do not agree to these terms and conditions, do not continue to use this website on the basis that your continued use of this website constitutes acceptance of these terms and conditions, unmodified by you.

All the information contained in this website ("the Information") is given by Vunani Limited, its subsidiaries and its associated companies ("Vunani") in good faith. Vunani neither makes nor intends to make any representation or warranty of any kind regarding the accuracy or completeness of any of the Information. It is specifically noted that funds managed by Vunani Fund Managers and Fairheads Benefits, have their own disclaimers that can be found on their respective documents and fact sheets.

Neither Vunani, nor any director, employee or agent of Vunani accepts any liability for any director indirect loss or damage, however caused, suffered by any person and/or any direct or indirect expenses or costs incurred by any person as a result of any usage of this website or reliance placed on the Information.

Vunani may amend these terms and conditions at any time by updating this page. It is the user’s responsibility to ensure that he/she is satisfied with any such amendments. If a user is not satisfied with the amendments, he/she must refrain from using this website in any way on the basis that your continued use of this website constitutes acceptance of such amended terms and conditions.

For these purposes it is recorded that these terms and conditions were last amended on 27 May 2021.

The use of this website and the Information is subject to South African law and only the South African courts shall have jurisdiction to hear any disputes that may arise from such usage and/or accessing of the Information. No part of this or any other section of the Vunani website may be reproduced in any form or by any means or distributed without the prior written consent of Vunani Chief Financial Officer. Any personal information of any user of this website will receive protection in accordance with applicable South African legislation and will be used solely for the purpose for which it was originally disclosed.


This manual applies to Vunani Limited, its subsidiaries and associated companies as disclosed in the Vunani Limited consolidated annual report for the financial year ended 28 February 2020 (hereunder referred to collectively as “Vunani Limited”).


Vunani Limited is a diversified financial services group, which operates through the following segments:

  • Asset management
  • Investment banking and advisory
  • Investment holdings
  • Securities broking
  • Property investments and developments

Head of body: Ethan Dube (Executive Deputy Chairman)

Physical Address: Vunani Office Park
151 Katherine Street
Postal Address: PO Box 652419 Benmore 2010

Tel No: +27 11 263 9500
Fax No: +27 11 784 2550


A guide to the Act (as contemplated under section 10 of the Act) is available from the South African Human Rights Commission. The guide contains such information as may reasonably be required by a person who wishes to exercise any right contemplated in the Act. Any enquiries regarding this guide and its contents should be directed to:

The South African Human Rights Commission:
PAIA Unit (the Research and Documentation Department)
Postal address : Private Bag 2700, Houghton, 2041
Telephone : +27 11 484-8300
Fax : +27 11 484-7146
Website :
E-mail :


Records held by the Company may be accessed on request only once the requirements for access have been met.

A requester is any person making a request for access to a record of the Company and in this regard, the Act distinguishes between two types of requesters:

Personal Requester
A personal requester is a requester who is seeking access to a record containing personal information about the requester. Subject to the provisions of the Act and applicable law, the Company will provide the requested information, or give access to any record with regard to the requester’s personal information.

Other Requester
This requester (other than a personal requester) is entitled to request access to information pertaining to third parties. However, the Company is not obliged to grant access prior to the requester fulfilling the requirements for access in terms of the Act. The prescribed fee for reproduction of the information requested will be charged by the Company.


This section of the manual sets out the subject and categories of records held by the Company. The inclusion of any subject or category of records should not be taken as an indication that records falling within those subjects and/or categories will be made available under the Act. More specifically, certain grounds of refusal as stipulated in the Act may be applicable to a request for such records.

Personnel documents and records:

  • Employment Contracts/ Letter of appointment
  • Employment Equity Plan
  • Staff qualifications, curriculum vitae, identity documents
  • Salary records
  • Leave Records
  • Best Practice Guidelines
  • Leave Policy
  • Study Policy
  • Disciplinary codes, policies, procedures and records

Financial Records:

  • Financial reports, statement and other accounting records;
  • Taxation records
  • Banking details and statements
  • Electronic banking records
  • Audit reports and documentation
  • Annual Financial Statements
  • Tax Clearance Certificates
  • Asset Register
  • Workplace Skills Plan

SARS Statutory Records:

  • Documents issued to employees for income tax purposes
  • Records of payments made to SARS on behalf of employees
  • PAYE, SDL & UIF records, including computations, returns and payment details
  • VAT records, including computations, returns and payment or refund details
  • Workmen’s Compensation return

Company secretarial:

  • Documents of incorporation;
  • Memorandum and Articles of Association;
  • Minutes of Board of Directors meetings;
  • Records relating to the appointment of directors/ auditor / secretary public officer
    and other officers;
  • Share Register;
  • Other Statutory records and registers;

Other party records:

  • Records held by the Company pertaining to other parties (i.e. clients), including but not limited to correspondence, contractual and transactional records and FICA documentation.

Legal and compliance:

  • All applicable contracts, service level agreements and mandates;
  • FICA documentation;
  • Records in terms of FAIS and FICA legislation;
  • Records in terms of JSE rules and directives;
  • Records in terms of other applicable legislation;

Records Available in terms of other Legislation:

  • Companies Act
  • Income Tax Act
  • Value Added Tax Act
  • Employment Equity Act
  • Unemployment Insurance Act
  • Skills Development Act
  • Basic Conditions of Employment Act
  • Compensation for Occupational Injuries and Disease Act

Mandatory grounds for refusal include but are not limited to:

  • Information for the protection of the privacy of individuals;
  • Information for the protection of commercial information and confidential information of third parties;
  • Commercial and research information of the company.
  • Basic Conditions of Employment Act 57 of 1997
  • Broad-based Black Economic Empowerment Act 53 of 2003
  • Companies Act 61 of 1973
  • Companies Act 71 of 2008
  • Compensation for Occupational Injuries and Diseases Act 130 of 1993
  • Competition Act of 1998
  • Consumer Protection Act of 1998
  • Copyright Act 98 of 1978
  • Electronic Communications and Transactions Act 25 of 2002
  • Employment Equity Act 55 of 1998
  • Exchange Control Amnesty and Amendment of Taxation Laws Act of 2003
  • Financial Advisory and Intermediary Services Act 37 of 2002
  • Financial Intelligence Centre Act 38 of 2001
  • Financial Services Board Act 97 of 1990
  • Income Tax Act 58 of 1962
  • Insider Trading Act 135 of 1998
  • Labour Relations Act 66 of 1995
  • Occupational Health and Safety Act 85 of 1993
  • Regulation of Interception of Communications and Provision of Communication-Related
  • Pension Funds Act 24 of 1956
  • Prevention of Organised Crime Act 121 of 1998
  • Prevention and Combating of Corrupt Activities Act 12 of 2004
  • Promotion of Access to Information Act 2 of 2000
  • Protected Disclosures Act 26 of 2000
  • Protection of Constitutional Democracy against Terrorist and Related Activities Act 33 of 2004
  • Securities Services Act 36 of 2004
  • Securities Transfer Tax Act 25 of 2007
  • Skills Development Act 97 of 1998
  • Skills Development Levies Act 9 of 1999
  • Trade Marks Act 194 of 1993
  • Unemployment Insurance Act 63 of 2001
  • Unemployment Insurance Contributions Act 4 of 2002
  • Value Added Tax Act 89 of 1991

Reference to the above-mentioned legislation shall include subsequent amendments to such
legislation and all relevant sections within such legislation of which the company holds


A requester must comply with all the procedural requirements contained in the Act relating to
a request for access to a record.
A requester must complete the prescribed form and submit same as well as payment of a request fee and a deposit, if applicable to the information officer at the postal or physical address, fax number or electronic mail address stated herein.
The prescribed form (Annexure A) must be filled in with enough particularity to at least enable
the information officer to identify:

  • The record or records requested;
  • The identity of the requester;
  • What form of access is required; and
  • The postal address or fax number of the requester.

A requester must state that he or she requires the information in order to exercise or protect a right, and clearly state what the nature of the right is so to be exercised or protected. The requester must also provide an explanation of why the requested record is required for the exercise or protection of that right.

The Company will process a request within 30 days, unless the requestor has stated special reasons which would satisfy the information officer that circumstances dictate that the this time period not be complied with.

The requester shall be informed in writing whether access has been granted or denied. If, in addition, the requester requires the reasons for the decision in any other manner, he or she must state the manner and the particulars so required.

If a request is made on behalf of another person, the requester must then submit proof of the capacity in which the requester is making the request to the satisfaction of the information officer.

If an individual is unable to complete the prescribed form because of illiteracy or disability, such a person may make the request orally to the information officer.


The Company will, within 30 days of receipt of a request, decide whether to grant or decline a
request and give notice with reasons (if required) to that effect.
The 30 day period within which the Company has to decide whether to grant or refuse a
request, may be extended for a further period of not more than 30 days if the request is for a
large quantity of information, or the request requires a search for information held at another
office of the Company (other than the head office) and the information cannot reasonably be
obtained within the original 30 day period. The information officer will notify the requester in
writing should an extension be necessary.


There are two types of fees to be paid in terms of the PAIA, namely:

  • the request fee, and
  • an access fee, which must be calculated by taking into account reproduction costs,

search and preparation time and cost, as well as postal costs where applicable.
(See Annexure B for the prescribed fees)
When a request is received by the information officer of the Company, the information officer shall by notice require the requester, other than a personal requester, to pay the prescribed request fee (if any), before further processing of the request.

If a search for the record is necessary and the preparation of the record for disclosure, including arrangement to make it available in the requested form, requires more than the hours prescribed in the regulations for this purpose, the information officer shall notify the requester to pay as a deposit the prescribed portion of the access fee which would be payable if the request is granted.

The information officer shall withhold a record until the requester has paid the fee or fees as indicated.

A requester whose request for access to a record has been granted, must pay an access fee for reproduction and for search and preparation, and for any time reasonably required in excess of the prescribed hours to search for and prepare the record for disclosure including making arrangements to make it available in the request form.

If a deposit has been paid in respect of a request for access, which is refused, then the information officer shall repay the deposit to the requester.


Internal Remedies

The Company does not have internal appeal procedures. As such, the decision made by the information officer pertaining to a request is final, and requestors will have to exercise such external remedies at their disposal if a request is refused, and the requestor is not satisfied with the response provided by the information officer.

External Remedies
A requestor that is dissatisfied with the information officer’s refusal to disclose information, may within 30 days of notification of the decision, apply to a court for relief. Likewise, a third party dissatisfied with the information officer’s decision to grant a request for information, may within 30 days of notification of the decision, apply to a court for relief. For purposes of the Act, courts that have jurisdiction over these applications are the Constitutional Court, the High Court or another court of similar status.


The manual is available for inspection, on reasonable prior notice, at the office of the company free of charge. Copies of the manual of the Company are also available from the SAHRC and the Company’s website.

Signed at SANDTON on this 28th day of February 2020

Chief Financial Officer


This privacy policy sets out how Vunani Limited and its Subsidiaries (“Vunani Limited”) uses and protects any information that you give to Vunani Limited when you use this website. A list comprising the subsidiary companies is available on request.

Vunani Limited is committed to ensuring that your privacy is protected. Should we ask you to
provide information by which you can be identified when using this website you can be assured
that it will only be used in accordance with this privacy notice.

By using the website, you are accepting the terms of this privacy notice and you consent to the collection, processing, further processing and storage of your personal information as contemplated in this privacy notice in accordance with the POPI Act.

Vunani Limited may change this privacy notice from time to time by updating this page. You
should check this page occasionally to ensure that you are aware of any changes.
This privacy policy is effective from 27th May 2021


The personal information that Vunani Limited collects about you will be sourced primarily from
the information and materials you provide and your communications to us.
This includes the following information:

  • a list of the products and services you express an interest in when you use the website;
  • your name and contact information, including email address and company details which
    you may submit to us when you interact with the website; and
  • information regarding your personal or professional interests, demographics,
    experiences with our products and contact preferences to provide you with further
    correspondence about our products and services.

We require this information to understand your needs and provide you with a better service,
including but not limited to the following reasons:

  • for internal record keeping;
  • to update our records about you;
  • fulfilment of our contractual and legal obligations to you;
  • to maintain our relationship with you;
  • for fraud prevention and detection, and to comply with applicable laws and regulations;
  • to market products and services; or
  • to respond to your enquiries and/or complaints or process your requests in relation to
    your information;
  • If you believe that any information we are holding about you is incorrect or incomplete, please
    email us as soon as possible on We will promptly correct any
    information found to be incorrect.

Vunani Limited respects your rights to privacy and confidentiality and consequently undertakes
not to give, sell or exchange personal information with any third party.
Vunani Limited will however disclose information when required under the following

  • to persons and entities within the Vunani Limited;
  • when requested by a court order or by any regulatory authority (such as Financial
    Services Conduct Authority or the Financial Intelligence Centre);
  • in order to comply with Vunani Limited’s legal and regulatory obligations in terms of any
    legislation or regulation applicable to Vunani Limited and its business dealings (including
    fraud prevention and anti-money laundering);
  • in order to conduct required credit checks; or
  • to any third-party service providers (who in turn have an obligation of confidentiality to
    Vunani Limited)

To keep you informed of important and relevant industry, financial and company information and
news we may provide communication to you through email. If you do not wish to receive specific
communications that you are subscribed to you may opt-out by following the “opt-out” procedure
in such messages.
Note: Vunani Limited takes reasonable measures to ensure the security of documents sent to
you. However, if you choose to receive your personal financial documents (including statements,
letters and reports) through the South African Postal Service or through electronic mail, Vunani
Limited will not be held liable for any unauthorised access or disclosure of your information once


Your personal information is only processed and retained for as long as the purpose it was
collected for continues, or for as long as required to comply with legal or regulatory requirements
or to protect Vunani Limited’s legal interests. This may result in your information being retained
for longer than any minimum period required by law.


We take all reasonably practical steps to ensure that your personal information is secure from
unauthorised access, modification or deletion.


You may request, amend or delete details of personal information which Vunani LImited holds
about you under the Promotion of Access to Information Act, 2 of 2000. The Promotion of Access
to Information Act, No 2 of 2000 was enacted to give effect to the constitutional right of access to
any information held by any private or public body that is required for the exercise or protection of
any rights. Certain requirements, however, must be met for access to any information being


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Our website contains links to other websites of interest, subsidiary companies and investee
companies. However, once you have used these links to leave our site, you should note that we
do not have any control over that other website.
Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Any questions about our privacy policy should be addressed to this