INCORPORATING POPIA COMPLIANCE

PROMOTION OF ACCESS TO INFORMATION MANUAL

for

MOTUS HOLDINGS LIMITED

Prepared in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”)

This manual applies to Motus Holdings Limited, its South African subsidiaries and their divisions.

(Collectively referred to in this manual as “Motus”)

Contents

1. Introduction

2. Purpose of PAIA Manual

3. Contact details

4. Review

5. South African Human Rights Commission Guide on how to use PAIA

6. Records available in terms of any other legislation

7. Description of the subjects on which Motus holds records and the categories of records held on each subject.

8. Categories of records which are available without request

9. The processing of personal information under POPIA

10. Data subject access to personal information

11. Fees payable

12. Other information as prescribed

Annexure A – Form 2: Request for access to a record of a private body

Annexure B – List of all Motus’ South African entities

Annexure C – Form 3: Outcome of request and of fees payable

Sensitivity - Public

Description of the subjects on which Motus holds records and the categories of records held on each subject.

The following is a list of the subjects on which Motus holds records and the categories into which these records fall. The procedure in terms of which such records may be requested from Motus is set out in paragraph 9 of this manual. The records listed below will not in all instances be provided to a requester who requests them in terms of PAIA. The requester has to show that he or she has the right in terms of PAIA to be given access to the records in question.

CATEGORIES OF RECORDS	DESCRIPTION OF RECORDS HELD
Administration	Share register. Share certificates Applicable statutory documents, including but not limited to, certificates of incorporation and certificates to commence business Trademark registers and related documentation
Corporate Governance	Codes of Conduct Corporate social and investment records Minutes of meetings of, shareholders, the Board of directors, various committees and sub committees Boards of the directors of Motus’ Resolutions Executive committee meeting minutes Legal compliance records Policies Memorandum of Incorporation (MOI) Statutory returns to relevant authorities
Finance	Accounting records Tax records VAT records PAYE records Debtors’ records Creditors’ records Insurance records Auditors’ reports Interim and annual financial statements Bank statements and other banking records for business and trust accounts Invoices issued in respect of debtors and billing information. Records regarding Motus’ financial commitments Statistic SA returns
Human Resources	List of employees Statistics regarding employees Employment contracts Conditions of employment Information relating to prospective employees Personnel records including personal details, disciplinary records, performance, and internal evaluation records Employee tax information Records of Unemployment Insurance Fund contributions Records regarding group life assurance and disability income protection Provident fund records Payroll records Workplace skills plans Codes of conduct and other policies Disciplinary code and procedure Grievance procedure Appeal procedure Internal policies and procedures regarding dismissals, performance appraisal, recruitment, selection, advertising of positions, appointments, retirement, promotions, leave, extended sick leave, study leave, salaries, overtime, bonuses, medical aid, health and safety, adoption leave and benefits, BEE procurement, loans, working parents, black economic empowerment, smoking, use of company resources including Sensitivity - Public telephones, motor vehicles and computers, sexual harassment, HIV-Aids and Pro Bono policy. Training schedules and material Training records and statistics Training Agreements Learnership Programs Correspondence relating to personnel
Operations	Supplier lists and details of suppliers Agreements with suppliers Access control records Health and safety records Insurance documentation Travel documentation Vehicle registration documents Deal files including the following: vehicle needs analysis, offer to purchase, offer to purchase T&C, vehicle delivery note, copy of NaTIS and licence, PDI sheet/ multi-point safety check, a letter of proxy, relevant transaction-related ID copies and CIPC/ company documents and VAT registration certificate (where a company/ legal party is purchasing the vehicle (or trading in a vehicle), roadworthy certificate (2nd hand goods only), where applicable: full trade-in valuation, used vehicle purchase invoice, VAT 264 form, trade-in NaTIS, bank settlement letter, release note if outside finance, only applicable to Retail Division files: manufacturer certificate, warranty documents (new cars), vehicle handover letter, dealer invoice, proof of payment, fitment certificates, supplier invoices, tax invoice, COF and waybill (commercial vehicles), fleet documents and automate report Client transaction records in respect of finance products, valueadded products, and insurance products, as well as FAIS disclosure documents where applicable
Information Technology	Computer software Support and maintenance agreements Records regarding computer systems and programs All information related to the computer software and hardware
Property	Asset registers Lease agreements in respect of immovable property Records regarding insurance in respect of movable property Records regarding insurance in respect of immovable property
Miscellaneous	Internal correspondence Firm publications Policies required in terms of applicable licensing requirements

Categories of records which are available without request.
No notices relating to Motus have been published by the Minister in terms of section 52(2) of PAIA.
Certain records are available without needing to be requested in terms of the request procedures set out in PAIA and detailed in paragraph 9 of this manual. This information may be inspected, collected, purchased, or copied (at the prescribed fee for reproduction) at the offices of Motus. Certain information is also available on Motus’ website: www.motus.co.za
The records include:
- A detailed description of the business of Motus
- Key management team
- Intraday share price
- SENS announcements
- Motus pre-listing statement (2018)
- Motus investor presentations (published)
- Motus Integrated Reports (published)
- Motus Code of Ethics
- Supply Chain Code of Conduct
- Ethical and Responsible Business Conduct
- Safe and Healthy Operating Environment
- Employer of choice document
- Ensuring Well-being of consumers by providing high-quality products and services
- Motus BBBEE Certificate and Annexures
- Anti-Bribery and Corruption policies
- POPIA documentation (section 18 disclosure, glossary, privacy statement, cookie policy, website terms and conditions)

The processing of personal information under POPIA

The purpose of the processing
Motus processes personal information for various lawful purposes permitted by section 11(1) of POPIA, authorised in Part B of Chapter 3 of POPIA governing the processing of Special Information and in Part C of Chapter 3 of POPIA governing the processing of Children’s information This includes, but is not limited to the following:
- to fulfil Motus’ responsibilities to customers, employees, suppliers and other natural or juristic persons across our four business segments, as set out in paragraph 1 above;
- to comply with legislative, regulatory, risk and compliance requirements (including directives, sanctions, and rules), voluntary and involuntary codes of conduct and industry agreements or to fulfil reporting requirements and information requests;
- to maintain employees’, customers’, and suppliers’ records;
- to respond to customers/suppliers’ enquiries and complaints;
- to inform customers of new products and/or services;
- for recruitment, employment and/or apprenticeship purposes;
- for general administration, financial and tax purposes;
- for legal or contractual purposes;
- for health and safety purposes;
- to secure and manage access to Motus’ premises and facilities;
- to transact with Motus’ suppliers and business partners;
- to help Motus improve the quality of its products and/or services;
- to detect, prevent and report theft, fraud, money laundering and other crimes. This may include the processing of special personal information, e.g., alleged criminal behaviour, or the supply of false, misleading, or dishonest information;
- to enforce and collect on any agreement when Motus needs to recover debts; and
- to identify products and services which might be of interest to data subjects and to inform them about Motus’ products and services.

A description of the categories of data subjects and of the information or categories of information relating to those data subjects

Categories of data subjects	Personal information processed
Customers, potential customers, and previous customers	Personal information and special personal information including - name, identity number or passport number, date of birth, citizenship, residence status, telephone number(s), email address(es), income tax numbers, physical and postal addresses, financial information, and banking information.
	Customer vehicle information
	Customer contracts, motor plans and warranties
	Customer contact information
Motus’ distributors, wholesale, retail, and rental franchises	Personal information of the dealer/partner/manager including - name, identity number, contact details
	Personal information of employees of the dealer/partner/manager including - name, identity number, contact details
Employees (previous and existing)	Personal information and special personal information including - name, identity number or passport number, date of birth, citizenship, residence status, telephone number(s), email address(es), income tax numbers, physical and postal addresses, financial information, banking information, medical information, and beneficiary information
	Pension and provident fund information
	Payroll records
	Physical access records
	Time and attendance records
	Video records
	Performance records and disciplinary procedures
	Employment contracts
	Disability information
	Electronic access records
	Training records
	Employment history, background checks and criminal checks
Suppliers / service providers	Supplier/service provider personal information including supplier contracts and bank details
Suppliers / service providers	Personal information of supplier/service provider representatives including - name, identity number, contact details
Job applicants	Curriculum vitae and application forms
	Background and criminal record checks
	Employee education and psychometrics records
Visitors	Physical access records
	Electronic access records and scans
	Video records

The recipients or categories of recipients to whom the personal information may be supplied.
Motus may share the personal information of data subjects for any of the purposes outlined above with the following:
- Motus Holdings Limited, its South African subsidiaries and their divisions, and any subsidiaries based in jurisdictions outside of South Africa;
- Motus authorised dealerships, rental companies, and motor-related financial services;  any operators who perform services on behalf of Motus;
- any applicable medical aid funds, pension funds, provident funds, credit bureau, and/or recruitment companies;
- the Financial Sector Conduct Authority and the regulators appointed for the various financial sectors; and
- other industry regulators to comply with any regulation passed under the relevant legislation, or any legal process.
If Motus is the responsible party for personal information that is to be shared, before the personal information is shared by Motus, Motus will conclude a written contract with the operator requiring that the operator establishes and maintains appropriate technological and organisational measures to protect against unauthorised access or processing of the personal and against loss of, damage to and the unauthorised destruction of personal information.
Planned transborder flows of personal information.
Motus will only transfer personal information across South African borders to foreign countries, if necessary to comply with legislation, the transfer is necessary for the conclusion or performance of a contract of which data subjects may be parties, protects the legitimate interest of the data subject, or is necessary for Motus to pursue its legitimate interests, or that of a third party to which the data is supplied.
Before transferring personal information across a South African border to a foreign country Motus will take steps to ensure that recipients of transborder personal information are bound by laws or agreements that provide an adequate level of protection and uphold principles for reasonable and lawful processing of personal information, in terms of POPIA.
If Motus relies on the legitimate interest of a data subject, prior to transferring personal information cross border, it will conduct a legitimate interest assessment.
Security Safeguards
Motus complies with POPIA in protecting the integrity and confidentiality of personal information. In doing so it has due regard to generally accepted information security practices and procedures.

Request procedure in terms of PAIA
Any individual or interested party (hereafter called requester) may in terms of Section 50 of PAIA request access to records held by Motus.
To request access to a record of Motus, a requester must complete the form annexed to this manual marked “Annexure A”.
A requester must provide sufficient detail on the prescribed form to allow Motus to identify the record or records which have been requested and the identity of the requester. If a request is made on behalf of another person or entity, the requester must submit details and proof of the capacity in which the requester is making the request, which must be reasonably satisfactory to. The requester is also required to indicate the form of access to the relevant records that is required, and to provide his, her or its contact details in the Republic of South Africa.
The requester must identify the right that he, she or it is seeking to exercise by accessing records held by Motus and must explain why the particular record or records requested is or are required for the exercise or protection of that right.
Motus may, and must in certain instances, refuse access to records on any of the grounds set out in Chapter 4 of Part 3 of PAIA which include: that access would result in the unreasonable disclosure of personal information about a third party, that it is necessary to protect the commercial information of a third party or of Motus itself, that it is necessary to protect the confidential information of a third party, that it is necessary to protect the safety of individuals or property, that a record constitutes privileged information for the purpose of legal proceedings, and that it is necessary to protect the research information of a third party or Motus itself. Access to documents may also be refused based on professional privilege.
Motus is required to inform a requester in writing of its decision in relation to a request in the form of a reply as set out in Annexure C. If the requester wishes to be informed of Motus’ decision in another manner as well, this must be set out in the request and the relevant details included, to allow Motus to inform the requester in the preferred manner.
Motus will decide in relation to a request for records within 30 days of receiving it, unless third parties are required to be notified of the request or the 30-day period is extended as provided for in PAIA. Motus will notify the requester if the 30-day period for processing a request is to be extended.
Where a request is refused, a requester may submit a complaint in writing to the Information Regulator within 180 days of being informed of the refusal of the request, in the prescribed manner and form for appropriate relief.
A requester may only lodge an application to the Court after exhausting the Information Regulator complaints procedure. The requester may apply to the Court within 180 days of the decision of the Information Regulation in the prescribed manner and form for appropriate relief. The Court will determine whether the records should be made available or not.

Fees payable

The fees payable by requesters to enable access to information is described in the table below:

Item	Description	Amount
1.	Request fee payable by every requester	R140,00
2.	Photocopy of A4-size page	R2,00 per page or part thereof
3.	Printed copy of A4-size page	R2,00 per page or part thereof
4.	Copy in a computer-readable form on: flash drive (to be provided by requester) compact disc if provided by requester If provided to the requester	R40,00 R40,00 R60,00
5.	Transcription of visual images per A4-size page	Service to be outsourced. Will depend on quotation from service provider.
6.	Copy of visual images
7.	Transcription of an audio record, per A4- size page	R24,00
8.	Copy of an audio record on: flash drive (to be provided by requester) compact disc if provided by requester If provided to the requester	R40,00 R40,00 R60,00
9.	To search and prepare the record for disclosure for each hour or part of an hour, excluding the first hour, reasonably required for such search and preparation.	R145,00
9.	To not exceed a total cost of	R435,00
10.	Deposit – if the search exceeds 6 hours	One third of amount per request, calculated in terms of items 2 to 8 above.
11.	Postage, e-mail, or any other electronic transfer	Actual expense, if any.

The information officer, whose contact details are available at paragraph 3 of this manual will assist you if required.

Other information as prescribed
The Minister has not prescribed that any further information must be contained in this manual.

ANNEXURE A (FORM 2)

REQUEST FOR ACCESS TO A RECORD HELD BY MOTUS HOLDINGS LIMITED (Motus)

Section 53(1) of the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000) (“PAIA”)

NOTE:

Proof of identity must be attached by the requester.
If requests made on behalf of another person, proof of such authorisation, must be attached to this form.

PARTICULARS OF PRIVATE BODY

Postal address	Physical address	Information Officer contact details
The Information Officer	The Information Officer	Name	Brandon Cohen
PO Box 1719	1 Van Buuren Road	Name	Brandon Cohen
Edenvale	Cnr. Van Dort & Geldenhuis Streets	Tel No.	011 607 7300
1610	Bedfordview	Email	compliance@faims.co.za
	2008	Email	compliance@faims.co.za

MARK WITH AN X

Request is made in my own name

Request is made on behalf of another person.

PARTICULARS OF PERSON REQUESTING ACCESS TO THE RECORD

The particulars of the person who requests access to the records must be recorded below. Furnish an address and/or fax number in the Republic of South Africa to which information must be sent. Proof of capacity in which the request is made, if applicable, must be attached.
Full names and surname
Identity number
Capacity in which request is made (when made on behalf of another person)
Postal address
Street address
Email address
Contact numbers	Tel	Fax
	Cell
Important: If authorised under a resolution or power of attorney, provide the resolution or power of attorney with this request

PARTICULARS OF PERSON ON WHOSE BEHALF A REQUEST IS MADE

This section must be completed only if a request for information is made on behalf of another person.
Full names and surname
Identity number
Postal address

Street address

Email address
Contact numbers	Tel	Fax
	Cell

PARTICULARS OF RECORD REQUESTED

Provide full particulars of the record to which access is requested, including the reference number if that is known to you, to enable the record to be located. If the space provided is inadequate, please continue on a separate folio and attach it to this form. The requester must sign all the additional folios.
Description of record or relevant part of the record	Reference number, if available








Any further particulars of record

TYPE OF RECORD

Mark the appropriate box with an X
Record is in written or printed form
Record comprises virtual images (this includes photographs, slides, video recordings, computergenerated images, sketches, etc)
Record consists of recorded words or information which can be reproduced in sound
Record is held on a computer or in an electronic, or machine-readable form

FORM OF ACCESS TO RECORD

Mark the appropriate box with an X
Printed copy of record (including copies of any virtual images, transcriptions and information held on computer or in an electronic or machine-readable form)
Written or printed transcription of virtual images (this includes photographs, slides, video recordings, computer-generated images, sketches, etc)
Transcription of soundtrack (written or printed document)
Copy of record on flash drive (including virtual images and soundtracks)
Copy of record on compact disc drive(including virtual images and soundtracks)
Copy of record saved on cloud storage server

MANNER OF ACCESS

Mark the appropriate box with an X
Personal inspection of record at registered address of public/private body (including listening to recorded words, information which can be reproduced in sound, or information held on computer or in an electronic or machine-readable form)
Postal services to postal address
Postal services to street address
Courier service to street address
Facsimile of information in written or printed format (including transcriptions)
E-mail of information (including soundtracks if possible)
Cloud share/file transfer
Preferred language (Note that if the record is not available in the language you prefer, access may be granted in the language in which the record is available)

PARTICULARS OF RIGHT TO BE EXERCISED OR PROTECTED

If the provided space is inadequate, please continue to a separate page and attach it to this form. The requester must sign all the additional pages.

Indicate which right is to be exercised or protected

Explain why the requested record is required for the exercising or protecting the aforementioned right

FEES

A request fee must be paid before the request will be considered.
You will be notified of the amount of the access fee to be paid.
The fee payable for access to a record depends on the form in which access is required and the reasonable time required to search for and prepare a record.
If you qualify for exemption of the payment of any fee, please state the reason therefor.

Reason for exemption from payment of fees

NOTICE OF DECISION REGARDING REQUEST FOR ACCESS

You will be notified in writing whether your request has been approved or denied, and if approved, the costs relating to your request, if any.
Please indicate your preferred manner of correspondence.
Postal Address	Facsimile	Electronic communication (Please Specify)

Signed at __________ this __________ day of __________ 20 __________

_____________________________________

SIGNATURE OF REQUESTER/PERSON ON

WHOSE BEHALF REQUEST IS MADE

FOR OFFICIAL USE ONLY

Reference number:
Request received by: (State Rank, Name and Surname of Information Officer)
Date received:
Access fees:
Deposit (if any):

______________________________

Signature of Information Officer

ANNEXURE B

List of all Motus’ South African entities (including wholly and partly owned South African subsidiaries and divisions)

B1	MOTUS ENTITIES COVERED BY THIS PAIA MANUAL	REGISTRATION NUMBER
1.	Motus Holdings Limited	2017/451730/06
2.	Auto Pedigree Proprietary Limited	1969/005581/07
3.	F&I Management Solutions Proprietary Limited	2008/004511/07
4.	Auto Pedigree Finance Products and Services Proprietary Limited	2004/035245/07
5.	Kaalfontein Yard Proprietary Limited	2006/023937/07
6.	Lereko Motors Proprietary Limited	2002/009777/07
7.	Llumar Films Proprietary Limited	2006/001769/07
8.	Motus Africa Proprietary Limited	2014/063620/07
9.	Motus Capital Proprietary Limited	2017/164032/07
10.	Motus Corporation Proprietary Limited	1969/002321/07
11.	Motus Group Limited	1983/009088/06
12.	Motus South Africa Investment (Proprietary) Limited	2000/017238/07
13.	Synapt Group Proprietary Limited	2015/064730/07
14.	Getworth Proprietary Limited	2016/084131/07

B2	MOTUS ENTITIES COVERED BY THEIR OWN PAIA MANUAL OR A DIVISIONAL PAIA MANUAL	REGISTRATION NUMBER
1.	58 Fleet Proprietary Limited	2016/438375/07
2.	Accordian Investments Proprietary Limited	2003/027086/07
3.	Golf and Utility Fleet SA (Proprietary) Limited	1972/002784/07
4.	Anvil Premium Finance Proprietary Limited	1998/001411/07
5.	Beekman Super Canopies Proprietary Limited	2005/014249/07
6.	Brietta Trading Proprietary Limited	2007/031442/07
7.	C2 Computer Investments Proprietary Limited	2005/036504/07
8.	Car Hire Brokers Proprietary Limited	1998/021881/07
9.	Dealernet Proprietary Limited	2002/008624/07
10.	Europcar South Africa (Proprietary) Limited	2017/243996/07
11.	Future Automobile Distributors Proprietary Limited	2012/037781/07
12.	Hyundai Automotive South Africa Proprietary Limited	1999/015934/07
13.	Motus Automotive Importers Proprietary Limited	1968/011636/07
14.	Kia South Africa Proprietary Limited	1968/003273/07
15.	Konvoi Proprietary Limited	2017/217199/07
16.	KUTS Automotive Outlet (Proprietary) Limited	2019/528546/07
17.	Liquid Capital Proprietary Limited	2001/012511/07
18.	Motor Compliance Solutions Proprietary Limited	2001/000890/07
19.	Motus Emerging Brand Importers (Proprietary) Limited	2000/027015/07
20.	Motor Happy Proprietary Limited	2014/020352/07
21.	Motus Vehicle Distributor Proprietary Limited	2001/006874/07
22.	M-Sure Mobility Fund Proprietary Limited	2013/171924/07
23.	M-Sure Financial Services Proprietary Limited	2002/022941/07
24.	National Automobile Parts Association Limited	1971/013578/06
25.	Niterra South Africa Proprietary Limited	2006/014122/07
26.	Paint Tech Maintenance Proprietary Limited	2010/003758/07
27.	Rhinoman Outdoor and Offroad Proprietary Limited	2013/130656/07
28.	SA Vehicle Maintenance Proprietary Limited	2000/009578/07
29.	Tempest South Africa (Proprietary) Limited	2017/232547/07

ANNEXURE C:

(FORM 3) OUTCOME OF REQUEST AND OF FEES PAYABLE

[Regulation 8] Note:

If your request is granted the—
1. amount of the deposit, (if any), is payable before your request is processed; and
2. requested record/portion of the record will only be released once proof of full payment is received.
Please use the reference number hereunder in all future correspondence.
Reference number: _______________________
TO:
______________________________ ______________________________ ______________________________ ______________________________
Your request dated _____________, refers.

You requested:

Personal inspection of information at registered address of public/private body (including listening to recorded words, information which can be reproduced in sound, or information held on computer or in an electronic or machine-readable form) is free of charge. You are required to make an appointment for the inspection of the information and to bring this Form with you. If you then require any form of reproduction of the information, you will be liable for the fees prescribed in Annexure B.

OR

You requested:

Printed copies of the information (including copies of any virtual images, transcriptions and information held on computer or in an electronic or machine-readable form)
Written or printed transcription of virtual images (this includes photographs, slides, video recordings, computer-generated images, sketches, etc)
Transcription of soundtrack (written or printed document)
Copy of information on flash drive (including virtual images and soundtracks)
Copy of information on compact disc drive (including virtual images and soundtracks)
Copy of record saved on cloud storage server

To be submitted:

Postal services to postal address
Postal services to street address
Courier service to street address
Facsimile of information in written or printed format (including transcriptions)
E-mail of information (including soundtracks if possible)
Cloud share/file transfer
Preferred language: (Note that if the record is not available in the language you prefer, access may be granted in the language in which the record is available)

Kindly note that your request has been:

Approved

Denied, for the following reasons:

Fees payable with regards to your request:

Item	Cost per A4-size page or part thereof/item	Number of pages/items	Total
Photocopy
Printed copy
For a copy in a computer-readable form on: (i) Flash drive • To be provided by requestor (ii) Compact disc • If provided by requestor • If provided to the requestor	R40.00 R40.00 R60.00
For a transcription of visual images per A4- size page	Service to be outsourced. Will depend on the quotation of the service provider
Copy of visual images
Transcription of an audio record, per A4-size	R24.00
Copy of an audio record (i) Flash drive • To be provided by requestor (ii) Compact disc • If provided by requestor • If provided to the requestor	R40.00 R40.00 R60. 00
Postage, e-mail, or any other electronic transfer:	Actual costs
TOTAL:

Deposit payable (if search exceeds six hours):
Yes No
Hours of search Amount of deposit (calculated on one third of total amount per request)
The amount must be paid into the following Bank account:
Name of Bank: ____________________________________
Name of account holder: ____________________________________ Type of account: ____________________________________
Account number: ____________________________________
Branch Code: ____________________________________
Reference Nr: ____________________________________
Submit proof of payment to: ____________________________________
Signed at ____________________ this ___________ day of ________________ 20 _________ ___________________________________
Information officer

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