Themis Legal Consulting - PAIA Manual

Effective 25 August 2026

Prepared for a private body in terms of the Promotion of Access to Information Act 2 of 2000, as amended, and relevant provisions of POPIA

This Manual is intended to assist persons wishing to request access to records held by Themis Legal Consulting Proprietary Limited and to describe, at a practical level, the categories of records held and the procedures applicable to requests.

1Particulars of the Private Body

1.1Name of private body: Themis Legal Consulting Proprietary Limited (“Themis”)

1.2Registration number: 2022/730552/07

1.3Enterprise type: Private company incorporated under the Companies Act 71 of 2008

1.4Nature of business: Independent South African commercial and corporate legal consultancy (not a firm of attorneys or an attorneys’ practice)

1.5Registered office and principal place of business: 585 Alendale Street, Elarduspark, Pretoria, Gauteng, 0181

1.6Postal address: 585 Alendale Street, Elarduspark, Pretoria, Gauteng, 0181

1.7Email: info@themislegal.co.za

1.8Telephone: +27 87 149 0522

1.9Information Officer: Ms Llanell Londt (Director), contactable at the details above marked “Information Officer - PAIA”

1.10This Manual is prepared and made available in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”).

2Purpose of this Manual

2.1The purpose of this Manual is to identify the records held by Themis; describe records that may be available without a formal PAIA request where applicable; explain the procedure for requesting access; identify relevant categories of personal information processed under POPIA; and provide sufficient information for a requester to understand how statutory rights of access may be exercised.

3The PAIA Guide

3.1The Information Regulator has made available a Guide explaining how to use PAIA, including the objects of PAIA, contact details of Information Officers, the manner and form of requests, assistance available from the Information Regulator, remedies, fees and other relevant information. The current Guide and prescribed forms should be obtained from the Information Regulator’s official website or offices.

4Records Available Without a Formal Request

4.1Certain records may be publicly available on Themis’s website or may be supplied voluntarily without requiring a formal PAIA request, subject to confidentiality, privilege, intellectual-property rights, third-party rights and applicable law. These may include:

4.2The fact that a category is listed above does not mean that every record within that category is automatically available or that Themis waives any lawful ground of refusal.

5Categories of Records Held

5.1Corporate and statutory records

5.2Financial and accounting records

5.3Client, prospective client and matter records

5.4Supplier and service-provider records

5.5Personnel and contractor records

5.6Information technology and security records

5.7Intellectual property and business records

5.8Regulatory, compliance and risk records

6Legislation in Terms of Which Records May Be Held

6.1Depending on applicability, Themis may hold records in accordance with legislation including the Companies Act 71 of 2008, Income Tax Act 58 of 1962, Tax Administration Act 28 of 2011, Value-Added Tax Act 89 of 1991, Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Employment Equity Act 55 of 1998, Unemployment Insurance legislation, Compensation for Occupational Injuries and Diseases Act 130 of 1993, Occupational Health and Safety Act 85 of 1993, Electronic Communications and Transactions Act 25 of 2002, Consumer Protection Act 68 of 2008 where applicable, POPIA, PAIA, and other legislation applicable to Themis’s operations from time to time.

6.2This list is indicative and not exhaustive. Inclusion does not constitute an admission that a particular statute applies in every respect or that a record exists.

7Processing of Personal Information under POPIA

7.1Purpose of processing

7.2Categories of data subjects

7.3Categories of personal information

7.4Recipients

7.5Cross-border flows

7.6Security measures

8How to Request Access to a Record

8.1A requester seeking access under PAIA must use the prescribed request form applicable to a request for access to a record and submit it to the Information Officer using the contact details in this Manual. The request must contain sufficient particulars to enable Themis to identify the requester, the requested record, the form of access required and the right that the requester seeks to exercise or protect, together with an explanation of why the requested record is required for the exercise or protection of that right where PAIA so requires.

8.2Where a request is made on behalf of another person, satisfactory proof of authority must be provided. Themis may request reasonable proof of identity and may require clarification where a request is vague, excessively broad or does not contain the information required by law.

9Fees

9.1A requester must pay any request, access, reproduction, search, preparation, postage or other fee prescribed by PAIA and its regulations, where applicable. Themis may require payment of a prescribed deposit before further processing a request, and is entitled to suspend the running of any statutory response period for the period between requesting and receiving payment of a prescribed fee or deposit, to the extent permitted by PAIA. No fee will be charged where a statutory exemption applies. The applicable prescribed fee schedule should be confirmed from the Information Regulator’s current PAIA materials.

10Decision on a Request

10.1Themis will consider a request and communicate its decision within the period prescribed by PAIA, subject to any lawful extension. If access is granted, the notice may specify the access fee, form of access and steps required. If access is refused, the requester will be informed of the refusal and available remedies to the extent required by law.

11Grounds for Refusal

11.1Access may or must be refused where PAIA or another law permits or requires refusal. Without limiting the statute, relevant grounds may concern the privacy of third parties; commercial information of third parties; confidential information; safety of individuals or property; records privileged from production in legal proceedings; commercial information of Themis; research information; records protected by other legislation; and requests that are manifestly frivolous, vexatious or would involve an unreasonable diversion of resources where the statutory requirements are met.

11.2Themis will not disclose information merely because it appears in a listed record category. Each request will be assessed on its facts and applicable law, including mandatory-protection provisions and any public-interest override.

12Severability of Records

12.1Where a record contains information that may lawfully be disclosed together with information that must or may be refused, Themis will consider whether access can be granted to the reasonably severable portion in accordance with PAIA.

13Records that Cannot Be Found or Do Not Exist

13.1If reasonable steps have been taken to find a requested record and there are reasonable grounds to believe that the record does not exist or cannot be found, Themis may respond in the manner contemplated by PAIA, including by way of the prescribed affidavit or affirmation where required.

14Remedies

14.1As Themis is a private body, a requester who is dissatisfied with a decision may use the remedies available under PAIA, including lodging a complaint with the Information Regulator and/or approaching a competent court, subject to applicable statutory procedures and time periods. The current prescribed complaint forms and procedures should be obtained from the Information Regulator.

15Availability of this Manual

15.1This Manual will be made available on the Themis website and, where required, at Themis’s principal place of business. Themis will update the Manual when reasonably necessary to reflect material changes in its operations, records, Information Officer details or applicable legal requirements.

16Interpretation

16.1In this Manual, headings are for convenience only and do not affect interpretation; the singular includes the plural and vice versa; a reference to a person includes a natural or juristic person; and the words “include”, “includes” and “including” are not words of limitation.

17Limitation of Liability

17.1To the maximum extent permitted by law, Themis will not be liable for any loss or damage arising from a lawful refusal, deferral or limitation of access to a record in accordance with PAIA, or from the loss, unavailability or destruction of a record where this occurred despite Themis’s reasonable record-keeping and security practices. Themis’s liability arising from or in connection with this Manual is limited to loss directly caused by Themis’s own unlawful conduct and excludes indirect, incidental, special, punitive or consequential loss of any kind.

18Severability

18.1If a provision of this Manual is found by a competent authority or court to be invalid, unlawful or unenforceable, that provision will be severed to the minimum extent necessary and the remaining provisions will continue in full force and effect.

19Governing Law

19.1This Manual is governed by the laws of the Republic of South Africa. Any dispute concerning this Manual that is not resolved through the Information Regulator’s statutory processes is subject to the jurisdiction of the South African courts.