COI PURPOSE

GAEL is committed to ensuring that all business is conducted in accordance with good business practice. To this end, GAEL conducts business in an ethical and equitable manner and in a way that safeguards the interests of all stakeholders to minimise and manage all actual or potential conflict of interest (“COI”). Therefore, GAEL and its representative must avoid (or mitigate where avoidance is not possible) any COI between GAEL and a client or its representative and a client.

OBJECTIVES

• Provide guidance on the behaviours expected under GAEL standards

• Promote transparency and to avoid business-related COI

• Ensure fairness in the interests of employees and GAEL

• To document the process for the disclosure, approval and review of activities that may amount to actual, potential or perceived COI

• To provide a mechanism for the objective review of personal outside interests.

TCF PURPOSE

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CONDITIONS

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PURPOSE

The purpose of the Protection of Personal Information Act (“POPIA”) is to protect people from harm by protecting their personal information. POPIA applies to the processing of personal information entered in a record by or for a responsible party that is domiciled in South Africa. However, POPIA may also apply to a responsible party not domiciled in South Africa where that responsible party makes use of automated or non-automated means within South Africa.

CONDITIONS

POPIA sets conditions for when it is lawful for someone to process someone else’s personal information.

Condition 1: Accountability

Condition 2: Processing Limitation

Condition 3: Purpose Specification

Condition 4: Further Processing Limitation

Condition 5: Information Quality

Condition 6: Openness

Condition 7: Security Safeguards

Condition 8: Data Subject Participation

POPI PURPOSE

The purpose of the Protection of Personal Information Act (“POPIA”) is to protect people from harm by protecting their personal information. POPIA applies to the processing of personal information entered in a record by or for a responsible party that is domiciled in South Africa. However, POPIA may also apply to a responsible party not domiciled in South Africa where that responsible party makes use of automated or non-automated means within South Africa.

CONDITIONS

POPIA sets conditions for when it is lawful for someone to process someone else’s personal information.

Condition 1: Accountability – GAEL must ensure compliance for the lawful processing of personal information.

Condition 2: Processing Limitation – Personal information must be processed lawfully and in a reasonable manner, and only if it is adequate, relevant and not excessive given the purpose for which it is processed.

Condition 3: Purpose Specification – Personal information must be collected for a specific, explicitly defined, and lawful purpose related to a function or activity of GAEL and should not be retained for longer than is necessary to achieve that purpose.

Condition 4: Further Processing Limitation – Further processing of personal information should be compatible with the purpose for which it was collected.

Condition 5: Information Quality – GAEL is required to take steps to ensure that the personal information is complete, accurate, not misleading and updated where necessary.

Condition 6: Openness – GAEL is required to take reasonably practicable steps to ensure that the data subject is aware of what personal information is being collected, the source of information, the purpose for which it is being collected, and the name and address of GAEL.

Condition 7: Security Safeguards – GAEL is required to secure the integrity and confidentiality of personal information in its possession or under its control.

Condition 8: Data Subject Participation – The data subject has a right to request GAEL to confirm whether personal information is held about the data subject and be provided with the record or a description of the information held. A data subject may further request GAEL to correct or delete personal information about the data subject that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully.