PAIA Manual

1. Introduction

This PAIA Manual is compiled in terms of the Promotion of Access to Information Act, 2000. PAIA gives effect to the constitutional right of access to information and provides a process for requesting access to records held by public and private bodies. This manual sets out:

• the nature of Nova’s business;

• Nova’s contact details;

• the details of Nova’s Information Officer;

• the categories of records held by Nova;

• the procedure for requesting access to records;

• the grounds on which access may be refused;

• the remedies available to requesters.

This manual should be read together with Nova’s Privacy Policy, POPIA Policy, Complaints Management Policy and other applicable compliance documents.

2. Definitions

For purposes of this manual: Data Subject means the person or entity to whom personal information relates.

Guide means the official guide on how to use PAIA, made available by the Information Regulator. Information Officer means the person responsible for dealing with requests made under PAIA and supporting compliance with PAIA and POPIA. Personal Information means information relating to an identifiable natural person or, where applicable, an identifiable juristic person. Private Body means a natural person, partnership, company or juristic person that carries on trade, business or profession, including NovaOne Advisory (Pty) Ltd. Record means any recorded information, regardless of form or medium, held by or under the control of Nova. Requester means any person, including a public body or official, making a request for access to a record. Third Party means any person other than the requester and Nova.

3. Nova’s Business and Functional Structure

NovaOne Advisory (Pty) Ltd, trading as Nova Insurance, is an insurance advisory and intermediary business. Nova operates as a juristic representative of FSP 55553. Nova provides insurance advisory, intermediary, policy servicing, claims support and related administrative services to personal and commercial insurance clients. Nova’s business activities include:

• short-term insurance advice;

• client risk review;

• quotation support;

• insurance placement;

• policy servicing;

• endorsements;

• renewals;

• claims support;

• client communication;

• compliance recordkeeping;

• complaints handling.

As part of its business operations, Nova may hold records relating to clients, prospective clients, employees, directors, service providers, insurers, underwriting managers, administrators, compliance providers and other stakeholders.

4. Company Contact Details

Company name: NovaOne Advisory (Pty) Ltd Trading name: Nova Insurance Registration number: 2024/074957/07 Juristic representative status: Juristic Representative of FSP 55553 Website: www.novainsurance.co.za General email: info@novainsurance.co.za Registered Office: Unit 601, Westlake Eco Estate Modderfontein Gauteng 1645 Postal Address: Unit 27, 57 On The Waterhouse 57 Waterhouse Road Brentwood Park Gauteng 1500

5. Information Officer Contact Details

Nova’s Information Officer is: Name: Brad Rimmer Designation: Operations and Systems Email: info@novainsurance.co.za Direct Email: brad@novainsurance.co.za Website: www.novainsurance.co.za PAIA and POPIA-related requests should be submitted to: info@novainsurance.co.za Where required, Brad Rimmer may be contacted directly at: brad@novainsurance.co.za

6. Guide on How to Use PAIA

The Information Regulator has published guidance on how to use PAIA and how to request access to records from public and private bodies. A copy of the PAIA guide may be obtained from the Information Regulator. Information Regulator South Africa Website: www.inforegulator.org.za Telephone: 010 023 5200 Email: enquiries@inforegulator.org.za Requesters are encouraged to consult the PAIA guide before submitting a request for access to records.

7. Requesting Access to Records

A person may request access to a record held by Nova if the record is required for the exercise or protection of a right. A request must:

• be made in the prescribed form;

• provide sufficient detail to identify the requester;

• provide sufficient detail to identify the record requested;

• state the right that the requester seeks to exercise or protect;

• explain why the requested record is required for the exercise or protection of that right;

• indicate the preferred form of access;

• provide contact details for correspondence;

• be submitted to Nova’s Information Officer.

Requests should be submitted to: info@novainsurance.co.za Nova may require proof of identity or proof of authority where a request is made on behalf of another person or entity.

8. Request Procedure

All requests for access to records must follow the procedure set out below.

8.1 Submission of Request

The requester must submit the prescribed PAIA request form to Nova’s Information Officer. The request must include:

• the requester’s full name and contact details;

• proof of identity;

• details of the record requested;

• the right the requester seeks to exercise or protect;

• reasons why the record is required;

• the preferred format for access;

• any relevant supporting information.

8.2 Requests on Behalf of Another Person

Where a request is made on behalf of another person, the requester must provide proof of authority to act on that person’s behalf. Nova may refuse to process the request until the authority is provided.

8.3 Assistance to Requesters

Nova will provide reasonable assistance to requesters where required to help them comply with the request procedure.

8.4 Fees

Where applicable, the requester may be required to pay prescribed request or access fees before the request is processed or before access is granted. Nova will notify the requester of any applicable fees.

8.5 Format of Access

Access may be provided in a reasonable and available format, including:

• inspection of the record;

• electronic copy;

• printed copy;

• email transmission;

• another reasonable format agreed with Nova.

Access in the requested format may depend on the form in which the record is held and whether access may lawfully be granted in that form.

9. Considering the Request

Nova will consider a PAIA request in accordance with PAIA, POPIA and any other applicable legal, regulatory, contractual or confidentiality obligations. Nova may consult internally or with relevant third parties before deciding whether to grant or refuse access. Where the requested record relates to legal proceedings, the requester may be required to use the applicable rules and procedures relating to discovery or production of documents in those proceedings. Nova may refuse requests that are unlawful, incomplete, vague, excessive, unreasonable, vexatious or otherwise not compliant with PAIA.

10. Decision on Request

Nova will notify the requester of its decision within the period prescribed by PAIA. The response may state whether:

• access is granted;

• access is partially granted;

• access is refused;

• additional information is required;

• a fee is payable;

• the requested record cannot be found or does not exist;

• the request period must be extended where permitted by law.

If access is refused, Nova will provide reasons for the refusal where required.

11. Grounds for Refusal

Nova may refuse access to records where PAIA permits or requires refusal. This may include where access would result in:

• unreasonable disclosure of personal information of a third party;

• disclosure of confidential information of a third party;

• disclosure of trade secrets or commercial information;

• breach of legal privilege;

• prejudice to legal proceedings;

• prejudice to safety or security;

• disclosure of information supplied in confidence;

• unlawful disclosure of client, insurer, service provider or business information;

• disclosure prohibited by law.

Each request will be assessed on its own facts and in line with applicable law.

12. Right to Challenge

If a requester is not satisfied with Nova’s decision, the requester may have the right to lodge a complaint with the Information Regulator or approach a court with jurisdiction. Information Regulator South Africa Website: www.inforegulator.org.za Telephone: 010 023 5200 Email: PAIAComplaints@inforegulator.org.za

13. Records Available Without a Formal PAIA Request

Certain records may be available on Nova’s website or on request without a formal PAIA request. These may include:

• Privacy Policy;

• POPIA Policy;

• PAIA Manual;

• Complaints Management Policy;

• Conflict of Interest Policy;

• website terms or legal notices;

• general company information;

• general product or service information;

• client forms and templates made publicly available.

Availability of these records may change from time to time.

14. Records Held by Nova

Nova may hold the following categories of records.

14.1 Company and Corporate Records

• company registration documents;

• director records;

• statutory records;

• shareholder records;

• governance documents;

• resolutions and meeting records;

• company policies.

14.2 Financial and Accounting Records

• accounting records;

• tax records;

• invoices;

• payment records;

• bank-related records;

• management accounts;

• budget records;

• audit or review records where applicable.

14.3 Human Resources and Employment Records

• employee records;

• contractor records;

• role descriptions;

• employment agreements;

• service provider agreements;

• training records;

• disciplinary records where applicable.

14.4 Client and Insurance Records

• client contact information;

• client policy records;

• needs analysis records;

• quotation records;

• proposal records;

• advice records;

• policy schedules;

• endorsement records;

• renewal records;

• claims records;

• complaints records;

• client correspondence;

• insurer correspondence;

• underwriting information;

• supporting client documents.

14.5 Compliance Records

• FAIS-related records;

• disclosure records;

• representative records;

• compliance policies;

• complaints records;

• conflict of interest records;

• POPIA and PAIA records;

• audit and compliance review records;

• regulatory correspondence.

14.6 Operational and System Records

• atWork records;

• SharePoint records;

• workflow documents;

• email records;

• system access records;

• document storage records;

• operational process records.

14.7 Marketing and Website Records

• website content;

• enquiry records;

• lead records;

• campaign records;

• brand and marketing documents;

• website form submissions;

• communication templates.

14.8 Third-Party Records

Nova may hold records relating to third parties, including:

• insurers;

• underwriting managers;

• administrators;

• compliance service providers;

• back-office providers;

• suppliers;

• service providers;

• assessors;

• repairers;

• contractors;

• professional advisers.

Access to third-party records may be subject to confidentiality, legal, contractual and PAIA limitations.

15. Records Available in Terms of Other Legislation

Nova may hold records in terms of applicable legislation, including but not limited to:

• Companies Act, 2008;

• Financial Advisory and Intermediary Services Act, 2002;

• Financial Sector Regulation Act, 2017;

• Protection of Personal Information Act, 2013;

• Promotion of Access to Information Act, 2000;

• Basic Conditions of Employment Act, 1997;

• Labour Relations Act, 1995;

• Employment Equity Act, 1998, where applicable;

• Occupational Health and Safety Act, 1993, where applicable;

• Compensation for Occupational Injuries and Diseases Act, 1993, where applicable;

• Income Tax Act, 1962;

• Value-Added Tax Act, 1991, where applicable;

• Electronic Communications and Transactions Act, 2002;

• any other legislation applicable to Nova’s business.

16. Records That Cannot Be Found or Do Not Exist

Where Nova has taken reasonable steps to locate a requested record and the record cannot be found or does not exist, Nova will notify the requester. Where required, Nova may confirm this by affidavit or affirmation in accordance with PAIA.

17. Third-Party Notification

Where a requested record relates to or affects a third party, Nova may be required to notify that third party. The third party may be given an opportunity to make representations before Nova decides whether to grant access. Nova will follow the applicable PAIA process when dealing with third-party information.

18. Protection of Personal Information

Nova processes personal information in accordance with POPIA. Details of Nova’s approach to personal information are set out in Nova’s Privacy Policy and POPIA Policy. Requests relating to personal information may be handled under PAIA, POPIA or both, depending on the nature of the request.

19. Availability of This Manual

This PAIA Manual is available:

• on Nova’s website;

• by request to info@novainsurance.co.za;

• from Nova’s Information Officer.

The manual may be updated from time to time.

20. Contact for PAIA Requests

All PAIA requests should be sent to: NovaOne Advisory (Pty) Ltd For attention: Brad Rimmer Information Officer Email: info@novainsurance.co.za Direct Email: brad@novainsurance.co.za Website: www.novainsurance.co.za

21. Prescribed Forms and Fees

Requests must be made using the applicable prescribed PAIA form. Where applicable, prescribed fees may apply for request processing, reproduction of records, access to records or delivery of records. Nova will advise the requester of any applicable fees before processing or releasing records.

22. Changes to This Manual

Nova may update this PAIA Manual from time to time to reflect changes in law, business operations, records, systems, contact details or regulatory requirements. The latest version will be made available on the Nova website or on request.