VDL SYSTEMS — PAIA MANUAL

Manual in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA)

Effective date: 2026-09-14

Summary: This manual describes the records VDL Systems holds, how to request access to them under PAIA, and your remedies. It also covers our POPIA duty to describe the personal information we hold. The complete internal record register is available on request from the Information Officer.

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1. Company details

2. Information Officer

Requests for access to records should be directed to:

Abraham van der Linde — Director / Information Officer Email: abraham@vdlsystems.co.za Postal address: 30A Thomas Leith, Bloemfontein, Free State, 9301

3. Guide to the Act

The South African Human Rights Commission's Guide on how to use PAIA (Section 10 of the Act) is available in all official languages at the Commission and at www.sahrc.org.za, and from the Government Gazette.

4. Categories of records held

The company holds records in the following broad categories. Inclusion here does not mean automatic access — access may be refused on the grounds in Chapter 4 of PAIA (Section 7 below):

• Company governance records — registration documents, Memorandum of Incorporation, annual returns, director and shareholder records, beneficial ownership registers;
• Financial records — invoices, payments, quotations, tax records, payroll and statutory records, budgets;
• Client and project records — contact information, correspondence, agreements, Statements of Work, project documentation and deliverables;
• Personnel records — employment contracts, leave and salary records, evaluations;
• Operational records — customer and supplier records, CRM data, marketing materials, business networking records;
• IT records — system access logs, hosting and configuration records, source code repositories, service-provider records;
• Records held under other legislation — Companies Act, Income Tax Act, VAT Act, labour legislation, POPIA, and ECT Act records.

The detailed register per category is available on request from the Information Officer.

5. Records available without a formal request

• Our Privacy Policy — at vdlsystems.co.za/privacy
• This PAIA Manual — at vdlsystems.co.za/paia
• Publicly available website content and marketing materials

6. How to request access

Who may request: any person, including a juristic person. You do not need to give a reason.

How: submit a request in the prescribed form (Form C, available from the Information Officer on request) or in writing containing the same details: your identity and contact details, the record(s) you want, the form of access you prefer (inspection, copy, or transcript), and the right you are exercising, if applicable.

Where: email abraham@vdlsystems.co.za or post to the registered address above.

Timelines:

Fees: fees are prescribed by PAIA regulation. We will confirm any applicable fee in writing before granting access. There is no charge to request access to your own personal information.

7. Grounds for refusal

Access may be refused on grounds set out in Chapter 4 of PAIA, including protection of a third party's privacy (s34) or commercial information (s36), the company's own commercial interests (s37), confidential third-party information (s38), safety (s40), and privileged information (s41).

If access is refused, we will give you the reasons, the specific PAIA section relied on, and notice of your remedies.

8. Remedies

If you are dissatisfied with a decision, you may:

1. Appeal internally — written appeal to the Information Officer within 30 days;
2. Apply to the High Court for an order compelling access;
3. Complain to the Information Regulator of South Africa — enquiries@inforegulator.org.za, www.inforegulator.org.za.

9. Personal information and POPIA

How VDL Systems processes personal information — the purposes, the data subjects and information categories, recipients, cross-border transfers, security measures, and your rights — is set out in our Privacy Policy and, in full detail, in our POPIA policy available on request from the Information Officer.

10. Availability and amendments

This manual is available free of charge at vdlsystems.co.za/paia and for inspection at our registered address during business hours. It may be amended from time to time; the effective date above shows the current version.