PAIA Manual

Prepared in accordance with Section 51 of the Promotion of Access to Information Act, No. 2 of 2000 (PAIA) and the Protection of Personal Information Act, No. 4 of 2013 (POPIA). Last Updated: 28 September 2026

​BlackLeaf™ Holdings and its operating subsidiaries function as a Multi-Family Office (MFO) and strategic wealth coordinator. As a private body under PAIA, we are committed to promoting the constitutional right of access to information while rigorously protecting the highly sensitive, multi-generational wealth data of our clients. This manual outlines the categories of records held by BlackLeaf™ and the procedures a requester must follow to access those records.

• Head of the Business / Chief Executive Officer: Daniel du Toit

• Designated Information / Compliance Officer: Talita Clarke, Vice President

• Physical Address: The Loft Office, 439 Diagonal Street, Pringle Bay, Western Cape, 7196

• Compliance Email (For all PAIA Requests): compliance@blackleafwealth.com

• General Enquiries: enquiries@blackleafwealth.com

• Office Telephone: +27 79 203 5844

The Information Regulator has compiled a guide, as required by Section 10 of PAIA, containing information to assist any person who wishes to exercise any right as contemplated in the Act. The guide is available in all official languages of South Africa. Members of the public can access this guide by contacting the Information Regulator directly:

• Website: https://inforegulator.org.za

• Email: enquiries@inforegulator.org.za

• Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

BlackLeaf™ Holdings retains records in compliance with various statutory frameworks, including but not limited to:

• Companies Act No. 71 of 2008

• Financial Intelligence Centre Act No. 38 of 2001 (FICA)

• Protection of Personal Information Act No. 4 of 2013 (POPIA)

• Value Added Tax Act No. 89 of 1991

• Income Tax Act No. 58 of 1962

• Basic Conditions of Employment Act No. 75 of 1997

• Electronic Communications and Transactions Act No. 25 of 2002

We maintain the following categories of records. Please note that access to these records is not automatically granted and is subject to the statutory grounds of refusal outlined in Section 8:

• Corporate & Statutory Records: Memorandums of Incorporation, director registers, share registers, board meeting minutes, and corporate governance frameworks.

• Financial Records: Annual financial statements, internal accounting ledgers, tax returns, banking records, and asset registers.

• Client Records: Signed mandates, Trust Deeds, Ultimate Beneficial Ownership (UBO) declarations, Know Your Customer (KYC) documentation, risk profiles, and multi-asset portfolio reports.

• Personnel/HR Records: Employment contracts, payroll data, disciplinary records, and internal operational policies.

In our capacity as an MFO and Trust and Company Service Provider (TCSP), we process personal information as follows:

• Purpose of Processing: Execution of wealth coordination, M&A advisory, fiduciary structuring, and mandatory Anti-Money Laundering (AML) and sanctions screening.

• Categories of Data Subjects: High-net-worth individuals, family office principals, corporate founders, employees, and third-party vendors.

• Transborder Flows of Information: Client data may be securely transferred to offshore jurisdictions (e.g., Mauritius, the UAE, the USA) for structural coordination, subject to POPIA-compliant safeguards, binding corporate rules, and standard contractual clauses.

Any requester wishing to access a record held by BlackLeaf™ must follow this procedure:

1. The requester must complete the prescribed Form 2 (Request for Access to Record), which is available on the Information Regulator’s website.

2. The form must be submitted to the Information Officer via email at compliance@blackleafwealth.com, or delivered to our physical address in Pringle Bay.

3. The requester must provide sufficient detail on the form to enable the Information Officer to identify the requested record and the requester.

4. The requester must explicitly indicate which constitutional right they are seeking to exercise or protect, and explain why the requested record is required for the exercise or protection of that specific right.

5. If the request is made on behalf of another person, the requester must submit legally binding proof of the capacity in which they are making the request (e.g., Power of Attorney).

Given the nature of our Multi-Family Office operations, BlackLeaf™ is legally obligated to refuse access to specific records under Chapter 4 of PAIA. Access will be definitively refused to protect:

• Client Privacy: Mandatory protection of the privacy of a third party who is a natural person (including deceased individuals), specifically regarding multi-generational wealth data, family registry information, and personal KYC documentation.

• Commercial Confidentiality of Third Parties: Protection of trade secrets, financial configurations, M&A target evaluations, and commercial information supplied in confidence by a third party.

• Legal Professional Privilege: Records containing legally privileged communications, specifically those involving our independent, external legal partners governed by the Legal Practice Council (LPC).

• BlackLeaf’s Commercial Information: Protection of our proprietary business models, strategic MFO frameworks, financial models, and unreleased corporate strategies.

In accordance with the regulations set forth by the Information Regulator, the following statutory fees apply to PAIA requests:

• Request Fee: A standard, non-refundable request fee of R140.00 must be paid upon submitting the Form 2. (Note: A requester is exempt from paying this fee if they are requesting access to their own personal information).

• Search and Preparation Fee: If the request is granted, an access fee of R145.00 applies for each hour (or part of an hour) required to search for and prepare the record. The first hour of search and preparation is free. By law, the total search and preparation fee cannot exceed R435.00.

• Reproduction Fees: Specific rates apply for the physical or digital reproduction of records. For example, the fee is R2.00 per printed A4 page, and R40.00 for records provided on a flash drive.

• Deposit: If the Information Officer anticipates that searching for and preparing the requested records will take more than six (6) hours, a deposit equal to one-third (1/3) of the total estimated access fee will be required upfront. This deposit will be refunded if the request is ultimately refused.

• Payment details will be provided by the Information Officer upon acknowledgment of the submitted Form 2.