PAIA Manual

Introduction

Section 51 of the Promotion of Access to Information Act, 2 of 2000 ("PAIA") requires every private body to compile a manual describing the categories of records it holds and the procedure for requesting access to those records.

This manual is published by Banabatau Projects (Pty) Ltd in compliance with section 51 of PAIA. It is available on our website and, on request, in other formats.

1. Contact Details of the Company

2. Information Officer

In terms of PAIA, the head of a private body is designated as the Information Officer. All PAIA requests must be directed to the Information Officer.

There is no Deputy Information Officer currently appointed. All PAIA correspondence should be directed to the Information Officer above.

3. The South African Human Rights Commission

The South African Human Rights Commission ("SAHRC") has published a guide on how to use PAIA. This guide is available at no charge from the SAHRC.

4. Categories of Records Held

Banabatau Projects (Pty) Ltd holds the following categories of records:

4.1 Corporate and Legal Records

• Memorandum of Incorporation and company registration documents
• Shareholder and director records
• Minutes of board meetings
• CIDB registration certificate and grading records
• NHBRC registration records
• Professional association memberships (MBA North, GBCSA)
• Insurance and indemnity records

4.2 Financial Records

• Annual financial statements
• Accounting records and general ledger
• Tax returns and SARS correspondence
• Bank statements and financial agreements
• Invoices, purchase orders, and supplier records

4.3 Human Resources Records

• Employee contracts of employment
• Payroll records
• Leave records and attendance
• Performance and disciplinary records
• Health and safety training records
• UIF and PAYE records

4.4 Client and Project Records

• Client contracts and scope of work documents
• Quotations and proposals
• Project correspondence
• Site instructions, variation orders, and completion certificates
• Subcontractor agreements
• Project photographs and as-built documentation

4.5 Operational Records

• Health and safety files and incident reports
• Equipment registers
• Supplier and subcontractor records
• Correspondence (email and written)
• Website and marketing materials

5. Records Available Without a Formal PAIA Request

The following records are publicly available and can be obtained without making a formal PAIA request:

• General company information available on our website
• This PAIA Manual
• Our Privacy Policy and Terms of Use
• General pricing and service information on request by phone or email

6. How to Make a PAIA Request

To request access to records held by Banabatau Projects (Pty) Ltd, you must submit a written request using the prescribed Form C as set out in the PAIA regulations.

Form C is available from the South African Human Rights Commission at www.sahrc.org.za.

Your completed form must be submitted to the Information Officer by:

• Email: admin@banabatauprojects.co.za
• Post: 210 Amarand Ave, Pegasus Building 1, Menlyn Maine, Pretoria 0081

Your request must include:

• Your full name and contact details
• A description of the record(s) you are requesting
• The form of access you require (for example, a copy or inspection)
• The right you are exercising or protecting, and why access to the record is necessary to do so
• If you are requesting on behalf of someone else, proof of authorisation

7. Request Fees

The following fees apply in terms of the PAIA regulations:

Fees are payable before access to the records is granted. Indigent requestors may apply for a waiver of fees in terms of section 54(8) of PAIA.

8. Processing Time

We will respond to your PAIA request within 30 days of receiving the request and the prescribed request fee. In exceptional circumstances this period may be extended by a further 30 days, in which case you will be notified.

9. Grounds for Refusal

Access to records may be refused on the grounds set out in Chapter 4 of PAIA, including but not limited to:

• Protection of personal information of third parties
• Protection of commercial information (trade secrets, confidential financial information)
• Records subject to legal privilege
• Records whose disclosure would prejudice law enforcement or safety of persons
• Records pertaining to third-party research

If your request is refused, you will be notified in writing with reasons and informed of your right to appeal or seek judicial review.

10. Remedies if Request is Refused

If your request for access is refused or not responded to within the required timeframe, you may:

• Apply to the Information Regulator for relief in terms of section 56 of PAIA
• Apply to the relevant High Court for relief in terms of section 82 of PAIA

11. Updates to This Manual

This manual will be reviewed and updated annually, or sooner if required by changes in legislation or company operations. The current version is Version 1.0, published April 2026.