PAIA Manual

1. Introduction

1.1 Purpose of This Manual

This manual is compiled in accordance with Section 14 of the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000) ("PAIA") and the Protection of Personal Information Act, 2013 (Act No. 4 of 2013) ("POPIA").

The purpose of this manual is to:

• Foster a culture of transparency and accountability within TIS Holdings Pty Ltd
• Give effect to the constitutional right of access to information
• Provide information on the categories of records held by TIS Holdings
• Outline the procedure for requesting access to records
• Inform requesters of their rights and remedies

1.2 Legislative Framework

This manual is prepared in terms of:

• The Constitution of the Republic of South Africa, 1996 (Section 32)
• Promotion of Access to Information Act, 2000 (Act No. 2 of 2000)
• Protection of Personal Information Act, 2013 (Act No. 4 of 2013)
• Regulations made under PAIA

1.3 Definitions

Personal Information: Information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person.

Private Body: A natural person who carries or has carried on any trade, business, or profession, but only in such capacity; a partnership which carries or has carried on any trade, business, or profession; or any former or existing juristic person (such as TIS Holdings Pty Ltd).

Record: Any recorded information regardless of form or medium, including written, electronic, or any other form.

Requester: Any person making a request for access to a record of TIS Holdings.

2. Company Information

2.1 Company Details

2.2 Nature of Business

TIS Holdings Pty Ltd is a leading provider of AI-powered Environmental, Social, and Governance (ESG) compliance solutions. The company specializes in:

• ESG-GRC (Governance, Risk & Compliance) automation platforms
• AI-driven supplier risk assessment and monitoring
• ISO standards compliance (ISO 14001, 45001, 50001, 27001)
• GISTM tailings management compliance
• ISSB climate disclosure reporting
• JSE sustainability requirements compliance
• Mining sector ESG solutions
• Data center sustainability assessments

2.3 Key Products and Services

TIS-IntelliMat ESG Navigator Platform: An AI-powered platform featuring 9 specialized agents for comprehensive ESG compliance management, supplier risk assessment, and regulatory reporting.

Strategic Partnerships:

• IBM Business Partner Plus (IBM Watsonx AI orchestration)
• Anthropic AI Partnership (Claude API integration)
• ISO Standards4Sustainability (1 of 3 global organizations selected)
• AWS Cloud Services (serverless infrastructure)
• DRATA (SOC2 Type II compliance certification pathway)

3. Records Available Without Request

3.1 Company Registration Documents

Memorandum of Incorporation, Certificate of Incorporation, and company registration details are available from the Companies and Intellectual Property Commission (CIPC).

3.2 Privacy Policy

Available at: https://esgnavigator.ai/privacy.html

3.3 This PAIA Manual

Available at: https://esgnavigator.ai/paia.html

3.4 Terms of Service

Available on request and via the company website.

3.5 Marketing and Public Information

Product brochures, case studies, and public marketing materials are available on the company website and social media channels.

3.6 Corporate Governance Documents

• Code of Conduct
• Ethics Policy
• Supplier Code of Conduct

3.7 Compliance Certifications

• ISO certifications (where applicable)
• SOC2 certification (in progress via DRATA)
• B-BBEE certificates

3.8 Public Reports

ESG performance reports, sustainability disclosures, and thought leadership publications (as made publicly available).

3.9 Information Technology Records

System architecture documentation, access control policies, data security frameworks (publicly shareable versions only).

3.10 Financial Records

Annual financial statements (as required by law to be publicly available).

3.11 Human Resources Records

General employment policies, health and safety policies (employee-facing versions).

4. Records Available in Terms of Other Legislation

TIS Holdings maintains records as required by various South African legislation, including but not limited to:

5. Request Procedure

5.1 Access Request Form

All requests for access to records must be made using the prescribed Form A as set out in Annexure A of the PAIA Regulations. The form is available:

• On our website: https://esgnavigator.ai/paia.html
• From the Information Officer upon request
• At the South African Human Rights Commission (SAHRC) website

5.2 Submission of Request

Completed request forms must be submitted to:

5.3 Information Required in Request

To enable efficient processing, your request must include:

• Sufficient detail to identify the record(s) requested
• Your identity number or registration number
• Postal address, email address, or fax number
• The form in which access is required (inspection, copy, transcript)
• If requesting on behalf of another person, proof of capacity to make the request
• The right you are seeking to exercise or protect, and explanation of why the record is required

5.4 Processing Timeline

TIS Holdings will respond within 30 days from receipt of the request. This period may be extended by a further 30 days if necessary, with written notice to the requester.

5.5 Third-Party Notification

If the requested record contains information about a third party, TIS Holdings will notify that third party within 21 days of receiving the request, allowing them to make representations regarding access.

6. Fees

6.1 Request Fee

A non-refundable request fee of R50.00 is payable upon submission of the request (except for personal information requests by the data subject themselves).

6.2 Access Fees

If the request is granted, the following fees apply (as per PAIA regulations):

6.3 Payment Methods

Fees must be paid before access is granted. Accepted payment methods:

• Electronic Fund Transfer (EFT) to TIS Holdings bank account
• Bank-guaranteed cheque
• Cash payment at registered office (by prior arrangement)

6.4 Fee Waiver

The Information Officer may waive fees if:

• The requester is indigent and cannot afford the fee
• The record contains information about human rights violations
• It is in the public interest to waive the fee

7. Grounds for Refusal

TIS Holdings may refuse a request for access to records on the following grounds (as provided in PAIA):

7.1 Mandatory Protection of Privacy of Third Parties

If disclosure would involve the unreasonable disclosure of personal information about a third party (PAIA Section 63).

7.2 Mandatory Protection of Commercial Information

• Trade secrets (Section 36)
• Financial, commercial, scientific, or technical information that could harm competitive position (Section 36)
• Information disclosed in confidence (Section 37)

7.3 Protection of Confidential Information

If disclosure would constitute breach of duty of confidence owed to third party (Section 37).

7.4 Safety of Individuals and Protection of Property

If disclosure could endanger life or physical safety of individuals or prejudice security of property (Section 38).

7.5 Protection of Certain Confidential Communications

• Legal professional privilege (Section 39)
• Legal proceedings (Section 40)

7.6 Commercial Information of Private Body

• If disclosure would result in financial loss or gain to TIS Holdings (Section 68)
• If disclosure would prejudice competitive position (Section 68)
• If disclosure would prejudice contractual negotiations (Section 68)

7.7 Research Information

If disclosure would expose TIS Holdings or third party to serious disadvantage in research activities (Section 69).

7.8 Manifestly Frivolous or Vexatious Requests

If the request is manifestly frivolous, vexatious, or involves an unreasonable diversion of resources (Section 45).

7.9 Procedure When Refusing Request

If a request is refused:

• TIS Holdings will provide written notice of refusal within 30 days
• Notice will state adequate reasons for refusal
• Notice will cite applicable provisions of PAIA
• Notice will inform requester of remedies available (internal appeal, court application)

8. Remedies Available

8.1 Internal Appeal

If your request is refused, you may lodge an internal appeal:

• Within: 60 days of notification of refusal
• To: Chief Executive Officer, Dr. Terry Ramabulana
• Address: Same as Information Officer contact details

The CEO will reconsider the decision and respond within 30 days.

8.2 Court Application

You may apply to Court for appropriate relief if:

• Your request is refused
• The internal appeal is unsuccessful
• You are dissatisfied with the access fee charged
• You believe the procedure was not followed correctly

Timeframe: Application must be made within 180 days of exhausting internal remedies.

8.3 South African Human Rights Commission (SAHRC)

You may also approach the SAHRC for assistance:

8.4 Information Regulator (for POPIA-related matters)

9. Information Officer Contact Details

Business Hours

Monday to Friday: 08:00 - 17:00 (South African Standard Time)

Closed: Weekends and South African public holidays

Response Time

Requests received will be acknowledged within 3 business days. Full responses will be provided within 30 days as required by PAIA.

10. Availability of This Manual

10.1 Online Access

This PAIA Manual is available for free download at:

• https://esgnavigator.ai/paia.html

10.2 Physical Copy

A printed copy of this manual is available for inspection, free of charge, at the registered office of TIS Holdings during business hours.

10.3 Request for Copy

A copy of this manual may be requested from the Information Officer. A nominal fee may be charged for printing and delivery.

10.4 SAHRC Submission

This manual has been submitted to the South African Human Rights Commission as required by PAIA Section 14.

10.5 Updates and Revisions

This manual is reviewed annually and updated as necessary.

Current Version: 1.0

Effective Date: February 16, 2026

Last Review Date: February 16, 2026

Next Review Date: February 16, 2027