REFINITIV SA, INCORPORATED IN
SWITZERLAND
Registration Number of Company: 2001/004570/10
Manual in terms of section 51 of Act No. 2 of 2000, Promotion of Access to Information Act) (the “Act")

Document Version 1.0
Date of issue: 1st November 2023

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Contents
1

INTRODUCTION .................................................................................................................................................................................................... 3

2

ABOUT LSEG ........................................................................................................................................................................................................ 3

3

INTERPRETATION ................................................................................................................................................................................................ 3

4

AIM......................................................................................................................................................................................................................... 45

COMPANY DETAILS ............................................................................................................................................................................................. 4

6

CONTACT DETAILS OF THE CHIEF PRIVACY OFFICER AND INFORMATION OFFICE ................................................................................... 4

7

HOW TO OBTAIN ACCESS TO THE GUIDE......................................................................................................................................................... 58RECORDS THAT ARE AUTOMATICALLY AVAILABLE TO EITHER EMPLOYEES ONLY OR THE GENERAL PUBLIC AND EMPLOYEES ...... 59

OTHER TYPES OF RECORDS HELD BY THE COMPANY AS CONTEMPLATED IN SECTION 51(1)(C) ........................................................... 5

10RECORDS HELD BY THE COMPANY IN TERMS OF OTHER LEGISLATION AS CONTEMPLATED IN SECTION 51(1)(D) OF THE ACT ........ 7

11

PROCESS OF REQUESTING INFORMATION NOT AUTOMATICALLY AVAILABLE........................................................................................... 7

12

FEES PAYABLE..................................................................................................................................................................................................... 9

13

INFORMATION OR RECORDS NOT FOUND ....................................................................................................................................................... 9

14

INFORMATION REQUESTED ABOUT A THIRD PARTY ...................................................................................................................................... 9

15

PROCESSING OF PERSONAL INFORMATION ................................................................................................................................................... 9

16

AVAILABILITY OF THE MANUAL ........................................................................................................................................................................ 1017

UPDATING OF MANUAL ..................................................................................................................................................................................... 10

FORM C ........................................................................................................................................................................................................................ 11A.

Particulars of private body .........................................................................................................................................11

B.

Particulars of person requesting access to the record ..........................................................................................11C.

Particulars of person on whose behalf request is made .......................................................................................11D.

Particulars of record ....................................................................................................................................................11E.

Fees ..............................................................................................................................................................................12

F.

Form of access to record ............................................................................................................................................12G

Particulars of right to be exercised or protected ....................................................................................................13

H.

Notice of decision regarding request for access ....................................................................................................13

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1

INTRODUCTION
This information manual is in respect of Refinitiv SA, incorporated in Switzerland hereinafter referred toas “LSEG”, who is a member of the London Stock Exchange Group of companies (“LSEG Group”). This
information manual (“Manual”) provides an outline of the types of records held by LSEG and explains
how one may submit requests for access to these records in terms of the Promotion of Access toInformation Act, 2 of 2000 (the “Act”).
The Act gives effect to everyone’s constitutional right of access to information held by private sector
bodies or public bodies that is required for the exercise and/or protection of the requester’s rights.
This Manual is available to view at LSEG premises as well as on its website.

2

ABOUT LSEG
LSEG provides Services to financial industry, compliance and risk professionals, helping them withefficiency tools and data to assess and improve risk and compliance management, analyze and accessfinancial transactions, generate better returns and create efficient, reliable business infrastructure.

3

INTERPRETATIONIn this document, clause headings are for convenience and shall not be used in its interpretation unlessthe context clearly indicates a contrary intention –3.1

an expression which denotes -3.1.1

any gender includes the other genders;

3.1.2

a natural person includes an artificial or juristic person and vice versa;

3.1.3

the singular includes the plural and vice versa;

3.2

the following expressions shall bear the meanings assigned to them below and cognate
expressions bear corresponding meanings -3.2.1“this document” – this document together with all of its annexures, as amended from time
to time;3.2.2“the company” – Refinitiv SA (Incorporated in Switzerland);3.2.3“the Act” – Promotion of Access to Information Act No. 2 of 2000, as amended from time totime including the regulations promulgated in terms of the Act;

3.2.4

“Information officer” - the person duly authorised by the Chief Privacy Officer and appointed
by the company to facilitate or assist the Chief Privacy Officer with any request in terms of
the Act;

3.2.5“POPIA” – Protection of Personal Information Act No. 4 of 2013.

3.3

any reference to any statute, regulation or other legislation shall be a reference to that statute,regulation or other legislation as at the signature date, and as amended or substituted from time
totime;3.4

if any provision in a definition is a substantive provision conferring a right or imposing an obligation
on any party then, notwithstanding that it is only in a definition, effect shall be given to that provision
as if it were a substantive provision in the body of this document;

3.5

where any term is defined within a particular clause other than this, that term shall bear the meaning
ascribed to it in that clause wherever it is used in this document;

3.6

where any number of days is to be calculated from a particular day, such number shall becalculated as excluding such particular day and commencing on the next day. If the last day ofsuch number so calculated falls on a day which is not a business day, the last day shall be deemed
to be the next succeeding day which is a business day;3.7

any reference to days (other than a reference to business days), months or years shall be a reference
to calendar days, months or years, as the case may be;

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3.8

the use of the word “including” followed by a specific example/s shall not be construed as limiting
the meaning of the general wording preceding it and the eiusdem generis rule shall not be appliedin the interpretation of such general wording or such specific example/s;

3.9

insofar as there is a conflict in the interpretation of or application of this document and the Act, theAct shall prevail;3.10

this document does not purport to be exhaustive of or comprehensively deal with every procedureprovided for in the Act. A requester is advised to familiarise his/her/itself with the provisions of the
Act before lodging any request with the company.

AIM
To facilitate the requests for access to records of the company as provided for in the Act. This document
does not purport to be exhaustive of or comprehensively deal with every procedure provided for in theAct. A requester is advised to familiarise him/her/itself with the provisions of the Act before lodging any
request with the company.

5

COMPANY DETAILSFull name:

Refinitiv SA Incorporated in Switzerland;

Registration No.

:

2001/004570/10

Company Head:

Nadim Najjar

Postal Address:

P.O Box 2662
Johannesburg
2000

Physical address::

3rd Floor,
The Chelsea
138 West Street Sandton
2196

6

Telephone:

011 775 3000

Website:www.lseg.com

CONTACT DETAILS OF THE CHIEF PRIVACY OFFICER AND INFORMATION OFFICE

6.1

Global Data Privacy Officer of the company is Helen Allen. Her contact details are –Privacy Office, LSEG
AddressEmail6.2

10 Paternoster Square, London EC4M 7LS,
England, United Kingdom
privacy.enquiries@lseg.com

The Information Officer authorised to facilitate requests in terms of the Act is Miss Silindile Mbuli. Her
contact details are –EmailTelephone

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silindile.mbuli@lseg.com+ 27 11 775 3000

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HOW TO OBTAIN ACCESS TO THE GUIDE
7.1

The Information Regulator has amended, updated and made available a revised guide, as
contemplated in section 10(1) of the Act, containing information to assist any person who wishes
to exercise any right as contemplated in the Act and POPIA.

7.2

Members of the public can inspect or make copies of the Guide from the offices of the public andprivate bodies, including the office of the Regulator, during normal working hours.

7.3

The Guide can also be obtained –

7.3.1
7.3.2
7.4

7.4.1

8

A copy of the Guide is also available in the following two official languages, for public inspection
during normal business hours –English and [Zulu].

RECORDS THAT ARE AUTOMATICALLY AVAILABLE TO EITHER EMPLOYEES ONLY OR THE GENERAL
PUBLIC AND EMPLOYEES
8.1

The following records are automatically available to all employees and need not be requested inaccordance with the procedure outlined in paragraph 11 -8.1.1

personnel records are available to the employee whose file it is;

8.1.2

records of disciplinary hearings and related matters are available to the employee
concerned;

8.1.3

the company's policies and procedures manual;

8.1.4

the company's document format manual.

8.2

9Upon request to the Information Officer;
From the website of the Regulator (https://www.justice.gov.za/inforeg/ ).

The following records are automatically and freely available to the general public and all
employees on www.lseg.com and need not be requested in accordance with the procedure
outlined in paragraph 11.

8.2.1

Media Releases

8.2.2

Feature Product Brochures

OTHER TYPES OF RECORDS HELD BY THE COMPANY AS CONTEMPLATED IN SECTION 51(1)(C)
These records are not automatically available without a request in terms of the Act. A request in terms ofthis section is subject to section 63(1) of the Act, which provides that the head of a company must refuse
a request for access to a record of the company if the disclosure of the record would involve theunreasonable disclosure of personal information about a third party including a deceased individual.
9.1

Statutory Business Records

9.1.1

Certificate of Incorporation

9.1.2

Memorandum of Incorporation

9.1.3

Records relating to the authority of the local authorised signatory

9.2

Financial records

9.2.1

financial statements

9.2.2

general ledger

9.2.3

tax returns and assessments

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9.2.4

bank statements

9.2.5

electronic banking records

9.2.6

asset register

9.2.7

rental agreement

9.2.8

Invoices

9.2.9

credit agreements

9.2.10

Customer and supplier statements and invoices

9.3

Employees’ Tax Records:

9.3.1

PAYE records

9.3.2

Records of payments made to SARS on behalf of employees

9.4

Statutory compliance documents

9.4.1

VAT certificate

9.4.2

UIF registration

9.4.3

Skills Development Levies

9.4.4

Workmen’s Compensation

9.5
9.5.1
9.6

Information Technology
infrastructure and system records
Insurance

9.6.1

Claim records

9.6.2

Policies

9.7

Legal agreements and contracts

9.7.1

Supplier contracts

9.8

Environment, Health and Safety

9.8.1

Emergency response plan

9.8.2

Employee public health emergency action plan

9.8.3

Noise exposure records

9.9

Personnel Records

9.9.1

Letters of appointment

9.9.2

Employment contracts

9.9.3

Employee information records

9.9.4

Arbitration awards

9.9.5

Pension Fund Records

9.9.6

Disability scheme

9.9.7

Funeral insurance scheme

9.9.8

Group life

9.9.9Group personal accident

9.9.10

Health and Safety records

9.9.11

Disciplinary records

9.9.12

Salary Records

9.9.13

Leave records

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79.9.14Training and development records

9.9.15

Employee evaluation and performance records

9.9.16

Employment equity plan

9.9.17

Staff loan agreements

9.9.18

Employee Incentive schemes

9.9.19

IRP5 and IT3 certificates9.9.20Staff records after employment

9.9.21

Internal policies and procedures

10 RECORDS HELD BY THE COMPANY IN TERMS OF OTHER LEGISLATION AS CONTEMPLATED IN SECTION
51(1)(D) OF THE ACT
The following records are not automatically available without a request in terms of the Act 10.1

all statutory returns -10.1.1VAT;

10.1.2

workmen's compensation;

10.1.3UIF;

10.1.4

regional services levies; and10.1.5Skills development levies.

10.2

documents concerning compliance by the company, insofar as it may be necessary, with legal
obligations under the following legislation -10.2.110.2.2

Attorneys Act, 1979
Basic Conditions of Employment Act, 1997

10.2.3

Broad-based Black Economic Empowerment Act, 2003

10.2.4Companies Act, 2008 (as amended)

10.2.5Compensation for Occupational Injuries and Diseases Act, 1997

10.2.6

Electronic Communications Act, 2005

10.2.7

Electronic Communications and Transactions Act, 2002

10.2.8

Employment Equity Act, 1998

10.2.9Immigration Act, 2002

10.2.10

Income Tax Act, 1962 (as amended)

10.2.11

Labour Relations Act, 1995

10.2.12

Occupational Health and Safety Act, 1993

10.2.13

Promotion of Access to Information Act, 2000

10.2.14

Protection of Personal Information Act, 2013

10.2.15

Protection of Information Act, 1982

10.2.16

Skills Development Amendment Act, 2008

10.2.17

Unemployment Contributions Act, 2002

10.2.18

Unemployment Insurance Act, 2001

10.2.19

Value-Added Tax Act, 1991

11 PROCESS OF REQUESTING INFORMATION NOT AUTOMATICALLY AVAILABLE
11.1

A request shall be made on the prescribed form. A copy of the form is attached marked “Form C”(“the prescribed form”). The prescribed form is also available from the website of the Information
Regulator, or the website of the Department of Justice and Constitutional Development at
www.doj.gov.za.

11.2

The prescribed form shall be submitted to the Information Officer at her address or e-mail address,

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who shall hand it to the Privacy Officer.
11.3

The same procedure as set out in 11.1 and 11.2 applies if the requester is requesting information
on behalf of another person or on behalf of a permanent employee of the company.

11.4

The Privacy Officer, as soon as reasonably possible and within thirty days after the request has
been received, shall decide whether or not to grant the request.

11.5

The requester will be notified of the decision of the Privacy Officer or the Information officer in themanner indicated by the requester.

11.6

If the request is granted, the requester shall be informed by the Privacy Officer or the Information
officer in the manner indicated by the requester in the prescribed form.

11.7

Notwithstanding the foregoing, the company will advise the requester in the manner stipulated by
the requester in the prescribed form of -11.7.1the access fee to be paid for the information (in accordance with paragraph 12);11.7.2the format in which access will be given; and11.7.3the fact that the requester may lodge an appeal with a court of competent jurisdiction against
the access fee charged or the format in which access is to be granted.

11.8

After access is granted, actual access to the record requested will be given as soon as reasonably
possible.

11.9

If the request for access is refused, the Privacy Officer or the Information officer shall advise therequester in writing of the refusal. The notice of refusal shall state -11.9.1adequate reasons for the refusal;

11.9.2that the requester may lodge an appeal with a court of competent jurisdiction against therefusal of the request (including the period) for lodging such an appeal.

11.10

Upon the refusal by the Privacy Officer or the Information officer, the deposit paid by the requester
will be refunded.

11.11

If the Privacy Officer or the Information officer fails to respond within thirty days after a request has
been received, it is deemed, in terms of section 58 read together with section 56(1) of the Act,
that the Privacy Officer or the Information officer has refused the request.

11.12

The Privacy Officer may decide to extend the period of thirty days (“original period”) for anotherperiod of not more than thirty days if -11.12.1

the request is for a large number of records;

11.12.2

the search for the records is to be conducted at premises not situated in the same town orcity as the head office of the company;

11.12.3

consultation among divisions or departments, as the case may be, of the company isrequired;

11.12.4

the requester consents to such an extension in writing; and11.12.5

the parties agree in any other manner to such an extension.

11.13

Should the company require an extension of time, the requester shall be informed in the manner
stipulated in the prescribed form of the reasons for the extension.

11.14

The requester may lodge an appeal with a court of competent jurisdiction against any extension
or against any procedure set out in this section.

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12 FEES PAYABLE
12.1

The fees for reproduction of a record as referred to in section 52(3) are as follows -12.1.112.1.212.1.312.1.412.1.512.1.612.1.7for every photocopy of an A4 size page or part thereof
for every printed copy of an A4-size page or part thereof
for a copy of a compact discfor a transcript of visual images for an A4 size page or part thereof
for a copy of visual images
for a transcript of an audio record, for an A4-size page or part thereof
for a copy of an audio record

12.2

The request fee payable by a requester, other than a personal requester is R50.00.

12.3

If the Privacy Officer or if the Information officer is of the opinion that six hours will be exceeded
to search, reproduce and/or prepare the information requested, a deposit is payable equal to onethird of an amount of R30 for each hour or part thereof, exceeding the six hours.

12.4

A request may be withheld until the fees have been paid.

12.5

The most up to date fee structure is available on the website of the Information Regulator atwww.justice.gov.za/inforeg/ .

R1,10;
R0,75;
R70,00;
R40,00;
R60,00;
R20,00;R30, 00.

13 INFORMATION OR RECORDS NOT FOUND
13.1

If all reasonable steps have been taken to find a record, and such a record cannot be found or if therecords do not exist, then the Privacy Officer or the Information officer shall notify the requester, by
way of an affidavit or affirmation, that it is not possible to give access to the requested record.

13.2

The affidavit or affirmation shall provide a full account of all the steps taken to find the record or todetermine the existence thereof, including details of all communications by the Privacy Officer or
the Information officer with every person who conducted the search.

13.3

The notice, as set out in paragraph 11.1, shall be regarded as a decision to refuse a request foraccess to the record concerned for the purposes of the Act.

13.4

If the record in question should later be found, the requester shall be given access to the recordin the manner stipulated by the requester in the prescribed form unless access is refused by thePrivacy Officer or the Information officer.

13.5

The attention of the requester is drawn to the provisions of Chapter 4 of Part 3 of the Act in termsof which the company may refuse, on certain specified grounds, to provide information to arequester.

14 INFORMATION REQUESTED ABOUT A THIRD PARTY
14.1

Section 71 of the Act makes provision for a request for information or records about a third party.

14.2

In considering such a request, the company will adhere to the provisions of sections 71 to 74 of
the Act.

14.3

The attention of the requester is drawn to the provisions of Chapter 5 of Part 3 of the Act in termsof which the company is obliged, in certain circumstances, to advise third parties of requests
lodged in respect of information applicable to or concerning such third parties. In addition, theprovisions of Chapter 2 of Part 4 of the Act entitle third parties to dispute the decisions of thePrivacy Officer or the Information Officer by referring the matter to the High Court.

15 PROCESSING OF PERSONAL INFORMATION
15.1

For more details of how the LSEG Group collect, handle, store and protect personal information about
you in the context of our services, please refer to our Privacy Statement available athttps://www.lseg.com/en/policies/privacy-and-cookie-statement.

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16 AVAILABILITY OF THE MANUAL
16.1

A copy of this Manual is available –16.1.1on www.lseg.com;

16.1.2at head office of Refinitiv SA in South Africa, for public inspection during normal business hours;

16.1.3to any person upon request and upon the payment of a reasonable prescribed fee; and16.1.4to the Information Regulator upon request.

16.2

A fee for a copy of the Manual, as contemplated in annexure B of the Regulations, shall be payable
per each A4-size photocopy made.

17 UPDATING OF MANUALThe company may update this Manual at such intervals as may be necessary.

________________________________
Nadim Najjar
Head of MEA

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FORM CREQUEST FOR ACCESS TO RECORD OF PRIVATE BODY
(Section 53(1) of the Promotion of Access to Information Act, 2000
(Act No. 2 of 2000)[Regulation 10]

A.

Particulars of private body

The Head:

B.

Particulars of person requesting access to the record

(a)
(b)
(c)

The particulars of the person who requests access to the record must be given below.
The address and/or fax number in the Republic to which the information is to be sent must be given.
Proof of the capacity in which the request is made, if applicable, must be attached.

Full names and surname:Identity number:
Postal address:
Fax number:
Telephone number:

E -mail address:

Capacity in which request is made, when made on behalf of another person:

C.

Particulars of person on whose behalf request is madeThis section must be completed ONLY if a request for information is made on behalf of another person.
Full names and surname:Identity number:D.

Particulars of record(a) 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.
(b) If the provided space is inadequate, please continue on a separate folio and attach it to this form.
The requester must sign all the additional folios.

1

Description of record or relevant part of the record:

2

Reference number, if available:

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3

Any further particulars of record:

E.

(a)
(b)
(c)
(d)

Fees

A request for access to a record, other than a record containing personal information about yourself, will be processed
only after a request fee has been paid.
You will be notified of the amount required to be paid as the request fee.
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 for exemption.

Reason for exemption from payment of fees:
F.

Form of access to record

If you are prevented by a disability to read, view or listen to the record in the form of access provided for in 1 to 4 hereunder, state
your disability and indicate in which form the record is required.
Disability:

Form in which record is required

Form in which record is required:Mark the appropriate box with an X.
NOTES:(a) Compliance with your request in the specified form may depend on the form in which the record isavailable.
(b) Access in the form requested may be refused in certain circumstances. In such a case you will be
informed if access will be granted in another form.
(c) The fee payable for access for the record, if any, will be determined partly by the form in which accessis requested.

1. If the record is in written or printed form:
copy of record*

inspection of record

2. If record consists of visual images
this includes photographs, slides, video recordings, computer-generated images, sketches, etc)
transcription of theview the images
copy of the images"
images*3. If record consists of recorded words or information which can be reproduced insound:
listen to the soundtracktranscription of soundtrack*audio cassette
written or printed document
4. If record is held on computer or in an electronic or machine-readable form:
printed copy of record*

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printed copy of information
derived from the record"

copy in computer readable form*(stiffy or compact disc)13'If you requested a copy or transcription of a record (above), do you wish thecopy or transcription to be posted to you?
Postage is payable.

G

YES

NO

Particulars of right to be exercised or protected

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

1.

Indicate which right is to be exercised or protected:

2.

Explain why the record requested is required for the exercise or protection of the aforementioned right:

H.

Notice of decision regarding request for access

You will be notified in writing whether your request has been approved/denied. If you wish to be informed in another manner, please
specify the manner and provide the necessary particulars to enable compliance with your request.

How would you prefer to be informed of the decision regarding your request for access to the record?
Signed at…………………………. this………… day of …………………………….20______________________________________
SIGNATURE OF REQUESTER / PERSON ON
WHOSE BEHALF REQUEST IS MADE

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