PAIA Manual

Prepared in terms of section 51 of the Promotion of Access to Information Act, 2 of 2000. Last updated May 2026.

1. Introduction

The Promotion of Access to Information Act, 2 of 2000 (PAIA) gives effect to the constitutional right of access to information. Section 32 of the Constitution of the Republic of South Africa grants every person the right of access to any information held by the state or by another person if that information is required for the exercise or protection of any rights.

This manual is published in compliance with section 51 of PAIA and is intended to assist requesters in identifying the records held by our organisation and the procedure for accessing them.

2. Particulars of the Organisation

3. Information Officer

In terms of section 51(1)(a) of PAIA and section 55 of the Protection of Personal Information Act, the Information Officer for Heptagon Capital and Heptagon Wealth is:

4. Section 10 Guide

The Information Regulator (South Africa) has published a guide in terms of section 10 of PAIA which contains information that may assist requesters in exercising their rights under the Act. The guide is available from the Information Regulator at the following address:

5. Records held by Heptagon Capital and Heptagon Wealth

The following categories of records are held by us and may be subject to a request for access:

5.1 Records relating to clients

• Client onboarding documents, including FICA verification records
• Financial needs analyses and financial plans
• Records of advice and recommendations
• Application forms and supporting documentation for products advised on
• Correspondence with clients
• Records of complaints lodged and their resolution
• Records of consultation meetings, including notes and reviews

5.2 Records relating to product providers and partners

• Commission and fee agreements with product providers
• Franchise agreements with Old Mutual
• Service level agreements with partners
• Correspondence with insurers and investment houses

5.3 Records relating to the company

• Founding documents and company registration records
• Statutory registers (directors, shareholders, members)
• Financial statements and accounting records
• Tax records
• Records relating to employees
• Insurance records, including professional indemnity
• FSCA licence records and compliance reports
• Internal policies and procedures

6. Records accessible under other legislation

Certain records held by us are available under other legislation, including but not limited to:

• Financial Advisory and Intermediary Services Act, 37 of 2002 (FAIS)
• Financial Intelligence Centre Act, 38 of 2001 (FICA)
• Long-term Insurance Act, 52 of 1998
• Short-term Insurance Act, 53 of 1998
• Companies Act, 71 of 2008
• Income Tax Act, 58 of 1962
• Tax Administration Act, 28 of 2011
• Labour Relations Act, 66 of 1995
• Basic Conditions of Employment Act, 75 of 1997
• Protection of Personal Information Act, 4 of 2013 (POPIA)

7. How to request access to records

A request for access to a record must be made on the prescribed form (Form 02 of the PAIA Regulations) and submitted to the Information Officer. The form is available from the Information Regulator's website at www.justice.gov.za/inforeg/ or from our offices on request.

7.1 Requirements for a valid request

1. Provide sufficient detail to enable the record to be identified.
2. Indicate the form of access required (e.g. inspection of the record, a copy, a transcription).
3. Specify a postal address or email address within South Africa.
4. Identify the right that the requester is seeking to exercise or protect, and provide an explanation of why the record is required to exercise or protect that right (if the request is made on behalf of another person, also state the capacity in which the request is made).
5. If the request is made on behalf of a third party, the requester must submit proof of the capacity in which they are making the request.

7.2 Decision on request

The Information Officer will, within 30 days of receipt of the request, decide whether to grant or refuse access and notify the requester of the decision and the reasons for it. This period may be extended by a further 30 days under certain circumstances as set out in section 26 of PAIA.

7.3 Grounds for refusal

Access to a record may be refused on the grounds set out in Chapter 4 of PAIA, including:

• Protection of personal information of third parties
• Protection of commercial information of third parties
• Protection of confidential information of third parties
• Safety of individuals and protection of property
• Records privileged from production in legal proceedings
• Commercial information of the company
• Research information

8. Fees

The prescribed fees for access to records are those set out in the PAIA Regulations and the Information Regulator's most recent fee schedule. The fees may be revised by the Information Regulator from time to time.

8.1 Categories of fees

• Request fee: A non-refundable request fee is payable on submission of the request, except for personal requesters (a requester seeking access to records about themselves).
• Access fee: If access is granted, an access fee is payable for the reproduction of records, search and preparation time, and postage where applicable.
• Deposit: If the search and preparation time is expected to exceed six hours, a deposit may be required before the request is processed.

8.2 Current prescribed fee schedule

Current fees are published by the Information Regulator and may be obtained from www.justice.gov.za/inforeg/. A copy is available on request from our Information Officer.

9. Remedies available

A requester who is aggrieved by a decision of the Information Officer may, within 180 days of being notified of the decision:

1. Lodge a complaint with the Information Regulator in terms of section 77A of PAIA; or
2. Apply to a court of competent jurisdiction for appropriate relief.

10. Updating of this manual

This manual is reviewed and updated as necessary to reflect any changes in our records or operations. The most recent version is available on our website at www.heptagonc.com or on request from the Information Officer.

11. Contact

Any queries relating to this manual or to a request for access to records should be directed to the Information Officer:

Email: talktous@heptagonc.com
Telephone: +27 11 660 1291
WhatsApp: +27 60 541 4685