MNOMBO WETHU CONSULTANTS (PTY) LTD PAIA Manual As prepared in terms of section 51 of the Promotion of Access to Information Act, 2000 ("PAIA") and the Protection of Personal Information Act, 2013 ("POPIA").
Mnombo Wethu Consultants (Pty) Ltd PAIA Manual v1 (October 2025)
-
Preamble and Objectives of this PAIA Manual
The purpose of PAIA is to address the constitutional right of natural and/or juristic persons to access records held by either a private or public body, subject to certain limitations, in order to enable them to exercise or protect their rights.
PAIA provides that a person may only request information if the information is required for the exercise or protection of a right. Information will therefore not be furnished to any person unless that person clearly provides sufficient particulars to enable Mnombo Wethu Consultants (Pty) Ltd ("Mnombo") to identify the right the requester is seeking to protect as well as an explanation of why the requested information is required for the purpose of protection of that right.
POPIA gives effect to the constitutional right to privacy. One of the data processing principles under POPIA is that of data subject participation, which allows for data subjects to access and correct their personal information held by a responsible party. This PAIA Manual provides for a data subject to request his/her personal information from Mnombo.
Section 51 of PAIA obliges private bodies to compile a manual which would assist a person to obtain access to information held by such a private body and stipulates the minimum requirements a manual has to comply with. This PAIA Manual thus seeks to: (i) give a description of the records held by and on behalf of Mnombo; (ii) set out the requirements with regard to who may request information in terms of PAIA as well as the grounds on which a request may be denied; and (iii) to outline the procedure to be followed and the fees payable when requesting access to any of these records.
This PAIA Manual will be updated in terms of section 51(2) of PAIA as and when required. A copy of this PAIA Manual is available -
on the Corporate / Corporate Governance tab of the following website:
https://www.platinumgroupmetals.net;
for public inspection during normal business hours at the physical address as specified under paragraph 3 below;
to any person upon request and upon the payment of a reasonable prescribed fee; and
at the Information Regulator upon request.
-
Company Overview
Mnombo is a Broad-Based Black Economic Empowerment company.
Mnombo is a subsidiary of Platinum Group Metals (RSA) (Pty) Ltd ("PTM RSA"), a wholly owned subsidiary of Platinum Group Metals Ltd., which is a Canadian mining company mainly focused on the production of platinum and palladium through PTM RSA and its subsidiaries in South Africa. Its Waterberg Project is located on the Northern Limb of the Bushveld Complex.
The Waterberg Project is a joint venture between PTM RSA, Impala Platinum Holdings Ltd., Japan Organization for Metals and Energy Security (JOGMEC) (through Tiger Gate Platinum (RF) (Pty) Ltd), Hanwa Co. Ltd., HJ Platinum Metals Company Ltd. and Mnombo. The joint venture has been incorporated into a private company, Waterberg JV Resources (Pty) Ltd., in which Platinum Group Metals Ltd. and its South African subsidiaries collectively hold the majority share.
-
Company Details: Mnombo Wethu Consultants (Pty) Ltd
Information Officer:
Mlibo Mgudlwa
Email:
POPIA@platinumgroupmetals.co.za
Address:
1st Floor, Rosebank Terrace,
23-25 Sturdee Avenue, Rosebank, Johannesburg,
2196
Postal Address:
1st Floor, Rosebank Terrace, 23-25 Sturdee Avenue, Rosebank, Johannesburg,
2196
Telephone Number:
011 214 7800
Website:
https://www.platinumgroupmetals.net
Deputy Information Officers:
Email:
POPIA@platinumgroupmetals.co.za
Address:
1st Floor, Rosebank Terrace,
23-25 Sturdee Avenue, Rosebank, Johannesburg,
2196
Postal Address:
1st Floor, Rosebank Terrace, 23-25 Sturdee Avenue, Rosebank, Johannesburg,
2196
Telephone Number:
011 214 7800
Website:
https://www.platinumgroupmetals.net
Schalk Engelbrecht
Jennifer de Vos
-
Information Regulator's Guide
A person who makes a request for a record in terms of this PAIA Manual is referred to the Guide in terms of Section 10(1) of PAIA, which will contain information for the purposes of exercising Constitutional Rights. The Guide has been compiled by the South African Human Rights Commission, will be updated from time to time by the Information Regulator and is
available from the Information Regulator. The Guide is available in each of the official languages and in braille.
The contact details of the Information Regulator are:
Postal Address: P.O. Box 31533 Braamfontein Johannesburg 2017
Website: https://inforegulator.org.za/
Complaints Email: PAIAComplaints@inforegulator.org.za
POPIAComplaints@inforegulator.org.za
General Enquiries Email: enquiries@inforegulator.org.za
A copy of the Guide is also available at Mnombo's office in English and Sepedi, for public inspection during normal office hours. A copy of the Guide will also be made available to a person, at no charge, upon receipt by Mnombo of a written request on the prescribed Form (which can be found at: https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form01-Reg3.pdf) as attached hereto as Annexure B for ease of reference. If a request for access to a record is made orally as a result of illiteracy or a disability, the Information Officer will complete the prescribed form on behalf of the person making the request and provide a copy to the person.
-
Availability of Records
Requests in terms of PAIA must be made in accordance with the prescribed procedures and at the rates provided. The forms and fees are dealt with further below and in Regulations 6 and 7 of PAIA.
Please take note that not all of the records and/or information listed in this PAIA Manual will be made available to a person requesting it.
Mnombo may or must refuse a request for information should any of the grounds of refusal, as set out in Part 3, Chapter 4 of PAIA, exist, for instance but not limited to:
the mandatory protection of privacy of a third party who is a natural person;
the mandatory protection of commercial or confidential information (trade secrets, financial or technical information); or
mandatory protection of records privileged from production in legal proceedings.
All requests for access to information will be evaluated on a case-by-case basis in accordance with the provisions of PAIA.
A person who made a request for a record will be notified, in writing and in the prescribed manner (Form 3), within 30 calendar days of Mnombo's receipt of that person's fully completed Request for Access form (Form 2 attached hereto as Annexure C), whether such
a request has been approved, approved in-part, or denied. A person will also be advised if it's not possible for Mnombo to give access to a particular record, for instance, if such record cannot be found or does not exist.
-
Automatic availability of certain Records
Subject to paragraph 5 above, records lodged in terms of Government and/or legislative requirements with various statutory bodies, including the Registrar of Companies are available for inspection, purchase and/or copying.
Some of the records and/or information are therefore automatically available to the public, or may be automatically available to a limited extent, some may voluntarily be made available by Mnombo, or others are not available unless requested under and in terms of this PAIA Manual, which disclosure will be subject to paragraph 5 above.
-
Legislation under which Records may be available
Records or information available in terms of certain provisions of applicable legislation (as they may be amended from time to time), includes but is not limited to:
Broad-Based Black Economic Empowerment Act No. 53 of 2003;
Companies Act No. 71 of 2008;
Competition Act No. 89 of 1998;
Constitution of the Republic of South Africa Act No. 108 of 1996;
Disaster Management Act No. 57 of 2002;
Employment Equity Act No. 55 of 1998;
Income Tax Act No. 58 of 1962;
The Insolvency Act No. 24 of 1936;
The Occupational Health and Safety Act No. 85 of 1993;
The Prescription Act No. 68 of 1969;
Prevention and Combatting of Corrupt Activities Act No. 12 of 2004;
Prevention of Organised Crime Act No. 14 of 1998;
Promotion of Access to Information Act No. 2 of 2000;
The Protection of Personal Information Act No. 4 of 2013;
South African Reserve Bank Act No. 90 of 1989;
Tax Administration Laws Amendment Act No. 33 of 2019;
The Value-Added Tax Act No. 89 of 1991; and
Other legislation which would ordinarily be considered applicable to the business of Mnombo.
-
Record Categories and Subjects
Company Records
Documents of incorporation / to commence business - Voluntarily available
Memorandum of Incorporation - Not disclosed