Registration Number: 2017/021295/07

Prepared in accordance with the Promotion of Access to Information Act

Version 1.0 | 2025


1. Interpretation

1.1 The headings of clauses are for convenience only and shall not affect interpretation.

1.2 Unless the context indicates otherwise:
1.2.1 words importing any gender include the others;
1.2.2 a natural person includes a juristic person and vice versa;
1.2.3 the singular includes the plural and vice versa.

1.3 Definitions:
1.3.1 “Act” means the Promotion of Access to Information Act, 2 of 2000;
1.3.2 “Client” means a natural or juristic person receiving services from the Company;
1.3.3 “Company” means Unahina Business Solutions (Pty) Ltd (2017/021295/07);
1.3.4 “Guide” means the guide published by the Information Regulator in terms of section 10 of the Act;

1.3.5 “Information Officer” means the person designated in terms of the Act;
1.3.6 “Manual” means this document compiled in terms of section 51 of the Act;
1.3.7 “Minister” means the Cabinet member responsible for the administration of justice;
1.3.8 “Personal Information” as defined in POPIA;
1.3.9 “POPIA” means the Protection of Personal Information Act;
1.3.10 “Record” means any recorded information regardless of form;
1.3.11 “Requester” means any person requesting access to records;
1.3.12 “RSA” means the Republic of South Africa;
1.3.13 “Special Personal Information” as defined in POPIA.


2. Introduction

2.1 This manual is compiled in accordance with section 51 of the Act.

2.2 The Company is a private body as defined in the Act and this manual contains the required information to facilitate access to records.

2.3 The Company participates in structured, transaction-based commercial funding arrangements aligned to verified commercial opportunities, including purchase order funding, invoice discounting and tender-related project funding.


3. Purpose

The purpose of this manual is to:

3.1 Facilitate requests for access to records held by the Company;
3.2 Outline the procedure for requesting access;
3.3 Provide transparency regarding the types of records held.


4. Contact Details

4.1 The Company

Full Name: Unahina Business Solutions (Pty) Ltd
Registration Number: 2017/021295/07
Business Address: 210 Amarand Avenue, Menlo Park, Pretoria, 0181
Telephone: 087 153 5655
Email: info@unahinasolutions.co.za
Website: www.unahinasolutions.co.za

4.2 Information Officer

The Company has nominated an Information Officer in accordance with applicable legislation.

Contact details for the Information Officer:
Email: info@unahinasolutions.co.za
Telephone: 087 153 5655


5. Availability of this Manual

5.1 This manual is available for inspection during normal business hours at the Company’s premises.

5.2 A copy may be requested via email from the Information Officer.

5.3 The Manual is available on the Company’s website and may also be requested from the Information Officer using the contact details set out in this Manual.


6. Updating of Manual

The Company will update this manual at least every twelve (12) months or as required.


7. PAIA Guide

7.1 A Guide on how to use the Promotion of Access to Information Act is available from the Information Regulator of South Africa.
7.2 The Guide and prescribed PAIA forms are available from the Information Regulator’s website at www.inforegulator.org.za.
7.3 Further information regarding PAIA requests and procedures may be obtained directly from the Information Regulator.


8. Records Available Without Formal Request

8.1 No notices have been published in terms of section 52(2) of the Act.

8.2 The following records may be available without formal request:
8.2.1 Marketing and promotional material;
8.2.2 Website content;
8.2.3 General company information;
8.2.4 Published policies and procedures (where applicable).


9. Information Available in Terms of Other Legislation

Records are held in accordance with applicable legislation, including:

9.1 Basic Conditions of Employment Act, 1997
9.2 Companies Act, 2008
9.3 Compensation for Occupational Injuries and Diseases Act, 1993
9.4 Criminal Procedure Act, 1977
9.5 Electronic Communications and Transactions Act, 2002
9.6 Employment Equity Act, 1998
9.7 Income Tax Act, 1962
9.8 Insolvency Act, 1936
9.9 Labour Relations Act, 1995
9.10 Occupational Health and Safety Act, 1993
9.11 Prevention and Combating of Corrupt Activities Act, 2004
9.12 Protection of Personal Information Act, 2013


10. Description of Records Held by the Company

10.1 Administration

10.1.1 Incorporation documents and memorandum of incorporation
10.1.2 Shareholder records and share register
10.1.3 Minutes of meetings and resolutions

10.2 Financial and Management

10.2.1 Accounting records, journals, and ledgers
10.2.2 Financial statements
10.2.3 Bank statements
10.2.4 Tax records
10.2.5 Invoices, receipts, and vouchers

10.3 Human Resources

10.3.1 Employment contracts
10.3.2 Personal records, including disciplinary records and performance evaluations
10.3.3 Payroll and employee tax records
10.3.4 Recruitment records and applications
10.3.5 Health and safety records
10.3.6 Employment equity plans
10.3.7 Codes of conduct and training materials

10.4 Clients and Transactions

10.4.1 Funding applications
10.4.2 Purchase orders and contracts
10.4.3 Tender documentation
10.4.4 Invoice discounting agreements
10.4.5 Due diligence and risk assessments
10.4.6 Client correspondence
10.4.7 Personal and special personal information
10.4.8 Affiliate and referral programme records

10.5 Suppliers and Third Parties

10.5.1 Supplier agreements
10.5.2 Verification documents
10.5.3 Correspondence

10.6 Operational Records

10.6.1 Internal communications
10.6.2 IT systems and records
10.6.3 Marketing and business development records


11. Processing of Personal Information

11.1 The Company processes personal information in accordance with POPIA.

11.2 Personal information is collected and processed for purposes including:
11.2.1 Assessing prospective transactions, commercial viability and risk;
11.2.2 Verifying identity and business information;
11.2.3 Managing client and supplier relationships;
11.2.4 Complying with legal and regulatory obligations;
11.2.5 Internal risk management and due diligence.

11.3 Personal information may be shared with third parties where necessary for the provision of services, including funding partners, suppliers, verification providers, professional advisors, IT service providers, and affiliate partners, or as required by law.

11.4 Personal information may be processed or stored outside the Republic of South Africa, subject to appropriate safeguards in accordance with applicable data protection laws.

11.5 The Company takes reasonable technical and organisational measures to protect personal information.

11.6 Complaints regarding the processing of personal information may be directed to the Information Regulator of South Africa. Current contact details are available at www.inforegulator.org.za.


12. Grounds for Refusal of Access

12.1 Access may be refused in accordance with Chapter 4 of the Act, including:

12.1.1 Protection of personal information of a third party (section 63);
12.1.2 Protection of commercial information of a third party (section 64);
12.1.3 Protection of confidential information (section 65);
12.1.4 Protection of safety and property (section 66);
12.1.5 Records subject to legal privilege (section 67);
12.1.6 Protection of commercial information of the Company (section 68);
12.1.7 Protection of research information (section 69).

12.2 In terms of section 70 of the Act, access must be granted where disclosure would reveal a substantial contravention of the law or an imminent and serious public safety or environmental risk, and the public interest outweighs the harm.

12.3 Where a request involves a third party, the Company will notify such party and allow representations.

12.4 Requests that are frivolous, vexatious, or that unreasonably divert resources may be refused.


13. Remedies

13.1 No internal appeal procedure exists.

13.2 Requesters may apply to a court of competent jurisdiction.


14. Records Not Found

14.1 If a record cannot be found, the Company will notify the requester by affidavit or affirmation.

14.2 The steps taken to locate the record will be provided.

14.3 If the record is later found, access will be granted unless refusal is justified.


15. Request Procedure

15.1 Requests must be made in terms of section 50 of the Act using the prescribed Form 02: Request for Access to Record.

15.2 The request must be submitted to the Company using the contact details in section 4.

15.3 The requester must:
15.3.1 Provide sufficient detail to identify the record;
15.3.2 Provide proof of identity;
15.3.3 Identify the right being exercised;
15.3.4 Explain why the record is required.

15.4 The Information Officer must decide within thirty (30) days.

15.5 If granted, the requester will be informed of fees and access format.

15.6 If refused, written reasons will be provided.

15.7 If no response is received within thirty (30) days, the request is deemed refused in terms of section 58 read with section 56(1) of the Act.

15.8 The period may be extended by a further thirty (30) days where:
15.8.1 A large number of records is requested; or
15.8.2 Records are not located at the main office.

15.9 Where a request affects a third party, the Company will notify such party and allow representations.


16. Prescribed Fees

Fees are payable as prescribed under the Act.

Further details are available from:
www.justice.gov.za


17. Adoption

This manual is adopted by Unahina Business Solutions (Pty) Ltd.


Authorised Signatory

Date: _______________________


ANNEXURE A – FORM 02: REQUEST FOR ACCESS TO RECORD

The prescribed Form 02: Request for Access to Record is available from the Information Regulator of South Africa at www.inforegulator.org.za.