PAIA MANUAL

1. Purpose and Status of This Manual

Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA") requires the head of every private body to compile a manual explaining what records the body holds and how a person may request access to them. The exemption that previously excused smaller private bodies from doing so lapsed on 1 January 2022, and no private body is exempt today.

This is the manual of G 1 Healthcare (Pty) Ltd. It is published here in English, free of charge, and a copy is available on request from the Information Officer. It is reviewed at least annually and whenever our records or contact details change.

A shorter summary of your rights is on our PAIA Notice page. This manual is the operative document.

2. Particulars of the Private Body (section 51(1)(a))

All PAIA requests, and all POPIA requests, must be addressed to the Information Officer at the address or email above.

3. The PAIA Guide Published by the Information Regulator (section 51(1)(b))

The Information Regulator has compiled a guide, in each official language, containing the information a person reasonably requires in order to exercise their rights under PAIA. The guide is available from:

The Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 — inforeg@inforegulator.org.za — inforegulator.org.za

4. Records Available Without a PAIA Request (section 51(1)(c) and section 52)

We have not submitted a notice under section 52(2) of PAIA. However, the following records are voluntarily available to anyone, free of charge, without any formal request:

• our Terms and Conditions of Sale and Business Account Terms;
• our Privacy Policy and Cookie Policy;
• our Returns & Refunds Policy and Shipping & Delivery Policy;
• our Product Safety, Adverse Event & Recall Policy and any current recall notices;
• our Website & Medical Device Disclaimer;
• product information, specifications, regulatory classification and, where applicable, UDI codes, on each product page;
• regulatory documentation on our Compliance & Certifications page, including ISO 10993 biocompatibility test reports and material safety data sheets. Our company registration certificate, Memorandum of Incorporation and SAHPRA licence are available there for on-screen verification rather than download, to guard against misuse; and
• this manual.

Registered customers can retrieve their own order records and invoices at any time from their account dashboard, without making a PAIA request. Track My Order additionally shows delivery progress against an order number and email address.

5. Records Available in Terms of Other Legislation (section 51(1)(d))

Records held by G1 Healthcare may be accessible under, among others:

• Companies Act 71 of 2008
• Consumer Protection Act 68 of 2008
• Electronic Communications and Transactions Act 25 of 2002
• Protection of Personal Information Act 4 of 2013
• Medicines and Related Substances Act 101 of 1965 and the Medical Devices Regulations
• National Health Act 61 of 2003
• Income Tax Act 58 of 1962, Value-Added Tax Act 89 of 1991 and Tax Administration Act 28 of 2011
• Basic Conditions of Employment Act 75 of 1997 and Labour Relations Act 66 of 1995
• Compensation for Occupational Injuries and Diseases Act 130 of 1993
• Unemployment Insurance Act 63 of 2001 and Skills Development Act 97 of 1998
• Occupational Health and Safety Act 85 of 1993
• Customs and Excise Act 91 of 1964

Access under any of these Acts is dealt with under that Act, not under PAIA. Requesting a record under another Act does not exclude a PAIA request for the same record, and the reverse is also true.

6. Subjects and Categories of Records Held (section 51(1)(e))

The table below describes the subjects on which we hold records and the categories of record under each subject. Listing a record here does not by itself entitle you to access it — the grounds for refusal in Chapter 4 of Part 3 of PAIA still apply, and are summarised in clause 9.

7. How to Request Access to a Record

7.1 Use the prescribed form. A request for access to a record of a private body must be made on Form C prescribed by regulation 10 of the PAIA Regulations, in terms of section 53(1) of PAIA. Form C is available from the Information Regulator's website, and we will email you a copy on request. A request that is not made on the prescribed form may be refused.

7.2 Send it to the Information Officer at support@g1healthcare.co.za, or to our physical address above.

7.3 Your request must:

• give enough particulars to allow the Information Officer to identify the record and to identify you;
• identify the right you are seeking to exercise or protect, and explain why the record is required to exercise or protect that right — section 50(1)(a) of PAIA makes this a substantive requirement for a private body, and a request that omits it will be refused;
• state the form of access you prefer and how you wish to be notified;
• be accompanied by proof of identity; and
• where you are acting for somebody else, be accompanied by proof of your authority in a form acceptable to the Information Officer.

7.4 Requests in another form. If a disability prevents you from making a written request, you may make it orally, and the Information Officer will reduce it to writing and give you a copy.

8. Fees

PAIA prescribes two fees for private bodies. A request fee is payable before the request is processed. An access fee covers reproduction, search and preparation, and postage, and is payable before the record is released. Current amounts are those set out in the PAIA Regulations from time to time; we do not add a margin to them.

• No request fee is payable where you are requesting a record about yourself as a personal requester.
• The Information Officer will notify you of the access fee in writing, with a breakdown, before doing the work. You may lodge an internal appeal or a court application against that decision.
• Where the preparation of a record will take more than the prescribed hours, a deposit of not more than one third of the access fee may be required.

9. Grounds on Which Access May or Must Be Refused

Chapter 4 of Part 3 of PAIA obliges or permits us to refuse access in defined circumstances. The grounds most likely to arise are:

• Section 63 — privacy of a third party. We must refuse access to a record that would involve the unreasonable disclosure of another person's personal information. This protects other customers' health information, prescriptions and order histories.
• Section 64 — commercial information of a third party, including trade secrets, and financial, commercial, scientific or technical information whose disclosure would harm a third party's commercial or financial interests.
• Section 65 — information supplied in confidence, where disclosure would constitute an actionable breach of a duty of confidence.
• Section 66 — safety of individuals and protection of property.
• Section 67 — records privileged from production in legal proceedings.
• Section 68 — our own commercial information, including trade secrets, research, and information whose disclosure would put us at a disadvantage in negotiations or in commercial competition.
• Section 69 — research information of ours or a third party.
• Section 70 — the public interest override. Access must nevertheless be granted where disclosure would reveal a substantial contravention of the law or an imminent and serious public safety or environmental risk, and the public interest in disclosure clearly outweighs the harm. We apply this override in good faith, and it weighs heavily where product safety is at stake.

Where a record contains both refusable and disclosable material, we grant access to a severed copy of the parts that may be disclosed, as section 28 read with section 55 requires.

10. Our Decision and Your Remedies

The Information Officer will decide the request and notify you within 30 days of receipt of a complete request. That period may be extended once, by not more than 30 days, where the request is for a large number of records or a search through records held elsewhere is necessary; we will tell you in writing if it is.

If access is refused, we will give you written reasons, the provisions of PAIA relied on, and information about your remedies. There is no internal appeal against the decision of a private body. You may:

• lodge a complaint with the Information Regulator in terms of section 77A of PAIA, within 180 days; or
• apply to a court in terms of section 78 of PAIA for appropriate relief, within 180 days of the decision.

If we do not respond within the prescribed period, the request is regarded as having been refused, and the same remedies apply.

11. Requests for Your Own Personal Information Under POPIA

A request under section 23 of POPIA for a record of the personal information we hold about you is processed through the PAIA mechanism described above, but as a personal requester, meaning no request fee is payable.

Requests to correct or delete personal information are not PAIA requests. Use Form 2 of the POPIA Regulations and send it to the Information Officer. Objections to processing use Form 1. See clause 14 of our Privacy Policy.

12. Availability of This Manual (section 51(3))

This manual is available:

• on this website, at www.g1healthcare.co.za/paia/manual, free of charge;
• at our registered office, for inspection during business hours, free of charge;
• by email from the Information Officer on request; and
• to the Information Regulator, as required.

A printed copy may be requested at the prescribed fee for reproduction. If you require this manual in another official language or in an accessible format, contact the Information Officer.

13. Contact the Information Officer

The Information Officer, G 1 Healthcare (Pty) Ltd

3 Inglenook Road, Riverside Lifestyle Estate, House 14, Nahoon Valley Park, Eastern Cape, 5202, South Africa

Email: support@g1healthcare.co.za

WhatsApp: +27 84 498 6840