Prepared in terms of Section 51 of the

Promotion of Access to Information Act 2 of 2000, as amended

(Applicable provisions of the Protection of Personal Information Act 4 of 2013 are included in this PAIA Manual)










































Download the PDF document – Kyron Group PAIA Manual


In this document, clause headings are for convenience and shall not be used in its interpretation unless the context clearly indicates a contrary intention –

      • 1.1  an expression which denotes –
      • 1.1.1 any gender includes the other genders;
      • 1.1.2 a natural person includes an artificial or juristic person and vice versa;
      • 1.1.3 the singular includes the plural and vice versa;
      • 1.2  the following expressions shall bear the meanings assigned to them below and cognate expressions bear corresponding meanings –
      • 1.2.1 “Access Fee” this is the fee paid by the Requester to the Company to cover the costs of finding and copying the records the Requester is seeking. The fee that can be charged is prescribed by regulation;
      • 1.2.2 this “Manual” means this document regarding the promotion of access to and protection of Personal Information together with all of its annexures, as amended from time to time prepared in terms of section 51 of PAIA;
      • 1.2.3 the “Company” means {insert company registered name}, duly incorporated under Registration Number {insert company registration number};
      • 1.2.4 “Data Subject” has the meaning ascribed to it in terms of section 1 of the POPIA;
      • 1.2.5 “PAIA” means the Promotion of Access to Information Act No. 2 of 2000, as amended from time to time, including the regulations promulgated in terms thereof;
      • 1.2.6 “Personal Information” has the meaning ascribed to it as set out in section 1 of the POPIA; 
      • 1.2.7 “POPIA” means the Protection of Personal Information Act No. 4 of 2013, as amended from time to time, including the regulations promulgated in terms thereof;
      • 1.2.8 “Information Officer” means the designated Information Officer/s or head of the body, as described in this Manual, responsible for discharging the duties and responsibilities assigned to the Information Officer as prescribed in terms of PAIA and POPIA;
      • 1.2.9 “Requester” has the meaning ascribed to it as set out in section 1 of the PAIA which includes a natural or juristic person making a request on behalf of the Data Subject;
      • 1.2.10 “Special Personal Information” has the meaning ascribed to it as set out in section 1 of the POPIA;
      • 1.3  any reference to any statue, regulation or other legislation shall be a reference to that statute, regulation or other legislation as at the signature date, and a amended or substituted from time to time;
      • 1.4  if any provision in a definition is a substantive provision conferring a right or imposing an obligation on any party, then notwithstanding that it is only in a definition, effect shall be given to that provision as if it were a substantive provision in the body of this Manual;
      • 1.5  where any term is defined within a particular clause other than this, that term shall bear the meaning ascribed to it in that clause wherever it is used in this Manual;
      • 1.6  where any number of days is to be calculated from a particular day, such number shall be calculated as excluding such particular day and commencing on the next day. If the last day of such number so calculated falls on a day which is not a business day, the last day shall be deemed to be the next succeeding day which is a business day;
      • 1.7  any reference to days (other than a reference to business days), months or years shall be a reference to calendar days, months or years, as the case may be;
      • 1.8  the use of the word “including” followed by a specific example/s shall not be  construed as limiting the meaning of the general wording preceding it and the eiusdem generis rule shall not be applied in the interpretation of such general wording or such specific example/s;
      • 1.9  insofar as there is a conflict in the interpretation of or application of this Manual and PAIA or POPIA, the legislation shall prevail;
      • 1.10 this Manual does not purport to be exhaustive of or comprehensively deal with every procedure provided for in PAIA or POPIA. A requester is advised to familiarise his/her/itself with the provisions of PAIA and POPIA before lodging any request with the Company.


2. Introduction

The Promotion of Access to Information Act, No 2 of 2000 (“PAIA”) was enacted on 3 February 2000 and came into operation on the 09 March 2001, giving effect to the constitutional right in terms section 32 of the Bill of Rights contained in the Constitution of the Republic of South Africa of access to any information that is held by another person and that is required for the exercise or protection of any rights. This Manual has been prepared in terms of section 51 of PAIA and regulation 4(1)(c) of the Regulations relating to the POPIA, for the Company. The intention is to ensure that the Company complies with PAIA and POPIA and also instils the principles of other relevant privacy legislation of South Africa by fostering the culture of transparency and accountability and giving effect to the right to information. In addition, the Manual explains how to access, or object to, or request correction or deletion of, Personal Information held by the Company in terms of sections 23, 24 and 25 of POPIA and its regulations.


3. Contact Details of the Company

Company details:

Kyron Group Pty Ltd

Registration number: 1997/016380/07

Address: 41 Parkview Street, Highway Business Park, Rooihuiskraal, Centurion 0157

Company CEO: Dr Jan Hendrik Wentzel

Physical Address: 41 Parkview Street, Highway Business Park, Rooihuiskraal, Centurion 0157

Postal Address: 41 Parkview Street, Highway Business Park, Rooihuiskraal, Centurion 0157

Tel: 012 661 4076



Information Officer: Ms. Roxanne Conradie

Tel: 011 416 8346



4. Guidance on PAIA and POPIA

4.1 Purpose

This Manual is intended to foster and proclaim the Company’s commitment to fostering a culture of transparency and accountability within the Company as a whole, by giving effect to the right to access information that is required for the exercise or protection of any right and to actively promote a society in which the people of South Africa have effective access to Personal Information to enable them to more fully exercise and protect their rights. The purpose of this Manual is to facilitate requests for access to records of the Company as provided for in PAIA, and to inform Data Subjects on the types of information the Company collects and processes, and how a Data Subject may request access to his/her Personal Information.
PAIA provides that a person, other than a government department or agency, may only request Personal Information in terms of the Act. Personal Information will therefore not be furnished unless a Requester clearly provides sufficient particulars on the request form to enable the Company’s Information Officer to identify the record and the Requester. The Requester should also indicate which form of access is required and indicate if he or she wishes to be informed in any other manner and state the necessary particulars to be so informed.


4.2 Guidance on how to use PAIA

The Information Regulator has, in terms of section 10(1) of PAIA, updated and made available the revised Guide on how to use PAIA (“Guide”).  The Guide has been designed to be a guiding, user-friendly and accessible tool for any person who wishes to exercise any right contemplated in PAIA and the POPIA.  A copy of this Guide can be obtained from the website of the Information Regulator (

This Guide will assist people i.e. Data Subjects on how to access his/her Personal Information and in understanding how to challenge the granting of access to their records or how to participate in the process of accessing their records. Data Subjects and Requesters should familiarise themselves with the provisions contained in the Guide.


4.3 Objectives of this Manual

With the above provisions in mind, the Company compiled this Manual to set out the procedure to be followed by Requesters when requesting access to Personal Information from the Company as contemplated in terms of PAIA, as well as to set out the protection that the Company provides to any Personal Information in the Company’s possession, in accordance with both PAIA and the POPIA.

Please note: This Manual is not exhaustive, nor does it comprehensively deal with, every procedure provided for in POPIA and PAIA. Requesters are advised to familiarise themselves with the provisions of these Acts before making any requests to the Company in terms of these Acts.


4.4 Availability of this Manual

This Manual is published on the Company’s website at / / / or alternatively, a copy can be requested from the Company’s Information Officer.
This Manual may be amended and updated from time to time and the final/latest version of the Manual will be publicly available.


4.5 Who may request access to Personal Information

In terms of section 1 of PAIA, a “Requester”, may act on behalf of a Data Subject in making a request for a record.
In terms of section 53(2)(d) of PAIA, the Requester when making a request for access must identify the right the Requester is seeking to exercise or protect and provide an explanation of why the requested record is required for the exercise or protection of that right.
Requests can be made:

  • as a personal request;
  • as an agent of a Data Subject ; and
  • as a third-party seeking information.


All Company clients are allowed to access their own Personal Information without having to go through the formal information request process provided that the Personal Information is not to be used in any legal action.


5. Classes of records

5.1 Records automatically available to the Public – Section 51 (1) (b) (ii)

No category of notice(s), except as indicated herein below, are automatically available to any person, and as such, no category of records has been published as being automatically available. Any request for records must be made by the Requester by completing Form 1 in Annexure A hereto. The following Records of the Company are available without a person having to request access by completing Form 1 as attached:

  • Records of a public nature;
  • Non-confidential records, such as product and promotional brochures, newsletters, pamphlets and other literature intended for public viewing;
  • Company Banking details; Information on the Company website
  • Statutory records relating to the Company which is held by the Companies and Intellectual Property Commission(“CIPC”);
  • This Manual.

If the above Records are not available on the Company’s website, where a person may download it, he/ she may request a copy telephonically or by sending an email or a letter to the Information Officer.

If a copy is requested, a payment of the prescribed fee as set out in this Manual for reproduction is required.

If a person only wants to inspect the Records, it can be arranged with the Information Officer/ Deputy Information Officer at the head office of the Company during normal office hours.


5.2 Records available in accordance with other legislation – Section 51 (1) (b) (iii)

Where applicable to its operation, the Company also retains records and documents in terms of legislation listed below for the relevant periods as provided in the applicable legislation. Please note that the records referred to on the listed legislation below are not exhaustive and as such, each request for access to a record will be treated uniquely with consideration of applicable legislation, procedure and policy.
Unless disclosure is prohibited in terms of legislation, regulations, contractual agreement or otherwise, records that are required to be made available in terms of this legislation shall be made available for inspection by interested parties in terms of the requirements and conditions of the PAIA.
A non-exhaustive list of records kept by the Company in accordance with other legislation:


Applicable legislation

Employee-Employer Relationship

Basic Conditions of Employment Act 75 of 1997

Compensation of Occupational Injuries and Diseases Act 13 of 1993

Disaster Management Act 57 of 2002

Employment Equity Act 55 of 1998

Labour Relations Act 66 of 1995

Occupational Health and Safety Act 85 of 1993

Unemployment Insurance Act 30 of 1966

Skills Development Act 97 of 1998

Pension Funds Act 24 of 1956

Animal Health Act 7 of 2002

Revenue/ Income

Value Added Tax Act 89 of 2001

Income Tax Act 58 of 1962

Skills Development Levies Act 9 of 1999

Taxation Laws Amendment Acts

Unemployment Contributions Act 63 of 2001


National Credit Act 34 of 2005

Promotion of Access to Information Act 2 of 2000

Protection of Personal Information Act 4 of 2013

Broad-Based Black Empowerment Act 46 of 2003

Companies Act 71 of 2008

Constitution of the Republic of South Africa Act 108 of 1996

Copyright Act 98 of 1978

Competition Act 89 of 1998

Electronic Communications and Transaction Act 25 of 2002

Consumer Protection Act 68 of 2008

Financial Intelligence Centre Act 31 of 2001


5.3 Categories of Personal Information Records held by the Company – Section 51 (1) (b) (iv)

The table below contains a non-exhaustive list and description of the subjects on which the Company holds records and the categories of records which may be held in respect of such a subject. Some of these records are not automatically available without a request in terms of PAIA. A request made in terms of PAIA for records in any of the categories below may be refused in accordance with any of the grounds of refusal as set out in PAIA.


Categories of records

Statutory Records

Company incorporation documents


Memorandum of Incorporation

Records lodged with the Companies and Intellectual Property Commission

Minutes of Meetings


Company Register

Share Register

Retirement Fund Records

Fund Rules

Fund Account Records

Minutes of Meetings of Pension/Provident Fund Trustees

Actuarial Valuation Report

Contribution Reports

Annual Accounts

Fixed Property

Title Deeds


Building Plans

Mortgage Bonds or other encumbrances to fixed property

Operational And Transactional Records




Brochures, Newsletters and Advertising Material


Company Policies and Procedures

Domestic and Export orders

Legal Records


Documentation pertaining to Litigation or Arbitration

Agreements and Contracts

Licenses and permits

Insurance Records


Insurance Policies


Marketing, Suppliers and Products


Marketing and Advertising Records

Brochures and other Promotional Information

Supplier details, including Terms and Conditions

Product Orders and – Specifications

Customer Records and Credit Services


Application Forms

Customer details, including Payments

Transaction Records

Statutory Records

Records provided by a Third Party


Information Technology


Business and Data Information

Domain Name Registrations

IT Technology Capabilities

Intellectual Property


Trademarks, Trade Names, Designs and Protected Name

Agreements and Patents pertaining to Intellectual Property

Human Resources and Financial Division

Employee Records

Employment Contracts

Employee Disability Records

Recruitment Records

Audited Financial Statements

Tax records (Company & Employees)

Management Accounts

Asset Register


5.4 Categories of Data Subjects and Personal Information records held by the Company – Section 51 (1) (c) (ii)

The table below contains a non-exhaustive list and description of the categories of Data Subjects and of the information or categories of information relating thereto which the Company holds in accordance with section 51(1)(c)(ii) of PAIA. Personal Information is classified and grouped according to records relating to the following categories of Data Subjects.

Categories of Data Subjects


 Personal Information

Personnel Records

“Personnel” refers to any person. who works for or provides services to or on behalf of the Company and receives or is entitled to receive remuneration and any person who assists in carrying out or conducting the business of the Company. This includes without limitation, Company directors, (executive and non-executive), all permanent, temporary and part-time Company employees as well as contract workers.

Record of employee life cycle, e.g., name, surname, identity number/ passport number, address, qualifications, employment history, medical history, financial history, marital status, dependents, nationality, pregnancy. Social origin, well-being, disability, culture, language, gender, race, personal opinions, preferences and views, salary, etc.

Customer Related Records

A “customer” refers to any natural or juristic entity that receives products or services from the Company. 

Record of client life cycle, e.g., name, registration number or identity number, trade secrets, financial and criminal history, ownership, governance, risk and compliance management frameworks, structures and Records, statutory records, directors, management and staff’s Personal Information, employment status, symbol, e-mail address, physical address, telephone number, location information and/ or online identifier, relevant management Records, organograms, whistle blower reports, minutes of meetings, audit findings and reports, Personal Information impact assessments, policies and procedures, confidential correspondence, etc.

Suppliers and Service Providers (Natural or juristic persons)

Providers of services and/or their products to the Company.

Record of supplier or service provider life cycle, e.g., name, products, services, registration number or identity number, trade secrets, financial and criminal history, ownership, governing body, employment status, bank details, symbol, e-mail address, physical address, telephone number, location information and/ or online identifier, etc.


6. Processing of Personal Information

Chapter 3 of POPIA provides for the minimum conditions for lawful processing of Personal Information. These conditions may not be derogated from unless specific exclusions apply as outlined in POPIA. The Company processes Personal Information in accordance with POPIA. In terms of this Manual, the Company will ensure that all processing conditions of POPIA are complied with at the time of processing of Personal Information. The Company processes Personal Information of both living and juristic persons.

These conditions apply to all Personal Information, including those relating to Company employees and third parties, as well as information received from third parties.

The process only applies to Personal Information that exists at the time of the request and it does not require the Company to create a record which does not exist.


6.1Data Subject rights

A Data Subject has the right to:

  • request the Company to confirm, free of charge, whether the Company holds Personal Information about such Data Subject;
  • request from the Company the record or a description of the Personal Information about him/ her or it, held by the Company, including information about the identity of all third parties, or categories of third parties, who have, or have had, access to the Personal Information, at a prescribed fee,;
  • request the Company to correct or delete Personal Information about him/ her or it in its possession or under its control that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully;
  • request the Company to destroy or delete a record of Personal Information about him/ her or it that the Company is no longer authorised to retain; or
  • object to the processing of their Personal Information.

The Company will take all reasonable steps to confirm a Data Subject’s identity before providing details of their Personal Information or making changes to their Personal Information.

If a Data Subject is required by the Company to pay a fee for services provided to the Data Subject to enable the Company to respond to a request, the Company –

  • will give the Requester a written estimate of the fee before providing the services and may require the Requester to pay a deposit for all or part of the fee.
  • may or must refuse to disclose any Personal Information requested on the same grounds for refusal of access to records as set out in this Manual.


6.2 Special Personal Information

We will only process your Special Personal Information, such as religious or philosophical beliefs, political persuasion, health or sex life, in accordance with the provisions of POPIA, for example:

  • Where the Data Subject consents to the processing.
  • Where it may be necessary for Us to establish, exercise, or defend a right or obligation in law.
  • If it is necessary to comply with international public law.
  • Processing is for historical, statistical, or research purposes in the public interest.
  • Where the Data Subject made the Special Personal Information public.

The Company will generally treat information relating to its employees’ health or sex life as confidential, unless it is required by law or in connection with its duties to communicate the information to other parties who are authorised to process such information in accordance with Section 32(1) of the POPIA.

Special Personal Information and Personal Information relating to Company employees will be processed in accordance with the rules established in compliance with labour legislation.


6.3  Personal Information of Children

The Company does not as part of the general nature of the business it conducts process Personal Information relating to children.  The Company will only process the Personal Information of its employees’ children for purposes of the employees’ employment benefits.


If, upon request by the Company, the Information Regulator grants authorisation, the Company will comply with the conditions imposed on it with regard to how it will, upon request of a competent person provide a reasonable means for that person to-

  • review the Personal Information processed; and
  • refuse to permit its further processing.


6.4  Guidance on Completion and Submission of Prescribed Access Forms

There are prescribed fees (payable in advance) for requesting and accessing information in terms of the Act. Details of these fees are contained herein below.

To request a record in terms of PAIA, the Requestor must complete the prescribed form contained as in Annexure A.This request must be sent to the Information Officer at the addresses provided herein.

For requests to access, object to, correct or delete the processing of personal information, the request must be made in writing on the applicable prescribed, Form 1 (access) or Form 3 (objection) or Form 4 (correction or deletion), which are attached to this Manual and contained in Annexure A.

To facilitate the processing of your request, kindly:

  • Use the prescribed Form and its annexures as contained in Annexure A below and complete in full,
  • Provide sufficient detail to enable the Information Officer to identify the record(s) requested and the Requestor,
  • Indicate which form of access is required,
  • Identify the right that the Requester is seeking to exercise or protect AND provide an explanation of why the requested record is required for the exercise or protection of that right.
  • If the request is made on behalf of another person, the Requestor must submit proof of the capacity in which the Requestor is making the request, to the reasonable satisfaction of the Information Officer.

The completed Form and its annexures, if applicable, must be submitted via courier or email and must be addressed to the Information Officer.


6.5 Applicable time periods

PAIA makes provision for certain grounds upon which a request for access to Personal Information must be refused. On this basis, the Information Officer will decide whether or not to grant a request for access to the Personal Information.

The Company will inform the Requester within 30 (thirty) days, after a request has been received or after the particulars required in terms of paragraph 6.4 above has been received, of its decision whether or not to grant the request, including adequate reasons for the refusal per Annexure A Form 2. The 30 (thirty)-day period may be extended by a further period of not more than 30 (thirty) days if the request is for a large number of records or requires a search through a large number of records and compliance with the original period would unreasonably interfere with the activities of the Company or the records are not located at the office of the Company, or consultations with another private body is required.


6.6  Disclosure of Personal Information to third parties

We may disclose your personal information to third parties such as our employees, associates and service providers (i.e., Operators), for legitimate business purposes, in accordance with applicable law and subject to the applicable professional and regulatory requirements regarding confidentiality.

Should the Company disclose your Personal Information to third parties, the latter will be obliged to use that Personal Information for the reasons and purposes the Personal Information was disclosed for.


6.7  Trans-border/Cross border flows of Personal Information

We may transfer and store your Personal Information to recipients and servers outside of the Republic of South Africa. However, the Company complies with the conditions for the transborder flow of Personal Information as provided by section 72 of POPIA.


6.8  Security

The Company takes reasonable, appropriate and adequate technical and organisational measures to ensure that your Personal Information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction, damage, alteration, disclosure or unauthorized access. We contractually mandate any third parties to which your Personal Information is transferred to keep your Personal Information secure in accordance with the provisions of POPIA.

The Company regularly reviews our security controls and related processes to ensure that your Personal Information is secure. However, where there are reasonable grounds to believe that your Personal Information has been accessed or acquired by any Unauthorised person, we will notify the Information Regulator and you, unless the Information Regulator or a public body responsible for detection, prevention or investigation of offences, informs us that notifying you will impede a criminal investigation.


7Refusal of Access to records


7.1  Grounds for refusal


In terms of section 62 to 69 of PAIA, the Information Officer may refuse access to a record if:

  • the disclosure would be an unreasonable disclosure of Personal Information about a third party, including a deceased individual;
  • the request for access will be refused if the record contains trade secrets, financial, commercial, scientific or technical information of the body or a third party that is likely to harm or prejudice the Company or third party;
  • information supplied in confidence by a third party;
  • if disclosure would constitute an action for breach of the duty of confidence owed to a third party in terms of an agreement;
  • if disclosure would constitute a violation of any law or statute, such as the Copyright Act, 1978;
  • disclosure could reasonably be expected to endanger the life, physical safety or property of the individual;
  • it is for the protection of records which would be regarded as privileged in any legal proceedings, unless the person so entitled to privilege waives the privilege;
  • the disclosure of research information of the Company or a third party on behalf of the Company would expose the third party, the Company, the researcher or the subject matter of the research to serious disadvantage; and
  • the Information Officer is of the opinion that processing requests will be unreasonably time-consuming and lead to a waste of resources. In addition, the Information Officer may refuse access to a record if the request is seen to be made by a Requester to unnecessarily annoy or provoke.

The Company may withhold a record until the Requester has paid the applicable fee (if any).


7.2  Remedies available when the Company refuses a request.


7.2.1 Internal remedies

The Company does not have any internal appeal procedures that may be followed after a request to access information has been refused. As such, the decision made by the Information Officer, as approved by the CEO is final.

Requestors will have to exercise such external remedies at their disposal if the request for Personal Information is refused and the Requestor is not satisfied with the answer supplied by the Information Officer.


7.2.2 External remedies

Subject to the provisions of PAIA, a Requester that is dissatisfied with a decision regarding a request for Personal information, may within 180 (one hundred and eighty) days of notification of the decision, submit a complaint, alleging that the decision was not in compliance with the PAIA, to the Information Regulator in the prescribed manner and form for appropriate relief or apply to a Court having competent jurisdiction.

The above provisions apply to a third party dissatisfied with the Information Officers decision.

A complaint form [Regulation 10], can be found on the website of the Information Regulator


7.3  Payment of Prescribed Fees

Subsequent to a complete and valid request being made, the Information Officer shall by notice inform the Requester whether their request has been granted or refused and pay the prescribed request fee (if any) before further processing of the request.

PAIA provides for two types of fees, namely:

  • A Request Fee, which will be a standard non-refundable administration fee, payable prior to the request being considered; and
  • An Access Fee, payable when access is granted which must be calculated by taking into account reproduction costs, search and preparation time and cost, as well as postal costs.

Prescribed Fees as published under PAIA Regulations can be found in Annexure B of this Manual.

If the search for a record of the Company in respect of which a request for access has been made and the preparation of the record for disclosure, including any arrangements to provide it in the required form would, in the opinion of the Information Officer, require more than six hours, the Information Officer/ Deputy Information Officer shall notify the Requester to pay a deposit as set out in Annexure B (“Notice”).

This Notice will state-

  • the amount of the deposit payable, if applicable;
  • that the Requester may lodge a complaint to the Information Regulator or an application with a court against the tender or payment of the Request Fee, or the tender or payment of a deposit, as the case may be; and
  • the procedure (including the period) for lodging the complaint to the Information Regulator or the application.

If a deposit has been paid in respect of a request for access which is refused, the Information Officer/ Deputy Information Officer will repay the deposit to the Requester.

The Information Officer/ Deputy Information Officer shall withhold a record until the Requester has paid the required fees.

A Requester whose request for access to a record of the Company has been granted must pay an Access Fee for reproduction and for search and preparation, respectively, for any time reasonably required in excess of six hours to search for and prepare (including making any arrangements to provide it in the requested form) the record for disclosure.

The actual postage is payable when a copy of a record must be posted to a Requester.


8. Records that cannot be found or do not exist

If all reasonable steps have been taken to find a record requested and there are reasonable grounds for believing that the record is in the Company’s possession but cannot be found or it does not exist, the managing executive of the Company shall, by way of affidavit or affirmation, notify the Requester that it is not possible to give access to that record. (This will be regarded as a decision to refuse a request for access to the record concerned.)

This affidavit or affirmation will give a full account of all steps taken to find the record in question or to determine whether the record exists including all communications with every person who conducted the search on behalf of the Company.

If, after notice is given, the record in question is found, the Information Officer/ Deputy Information Officer will give access to the Requester concerned to the record unless access is refused on a ground for refusal contemplated in this Manual.


9.   Revision history

·       Approved date

·       Approved by and resolution reference

·       Revision no

·       Description of change



·       1

·       Initial creation

·       26/04/2022

·       Social and Ethics Committee

·       2

·       Annual review

·       03/08/2023

·       Compliance, Social and Ethics Committee

·       3

·       Annual review

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