PAIA Manual

1. Introduction and purpose

This manual is published by linqEV (Pty) Ltd in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"). PAIA gives effect to the constitutional right of access to information and sets out the procedure by which a person may request access to a record held by a private body.

linqEV (Pty) Ltd operates an electric-vehicle charging network in the Republic of South Africa. Its business includes the operation of public AC and DC charging stations, the linqNRG mobile application through which Drivers locate chargers and pay for charging sessions, and the "Host a Linq" partner programme, under which businesses host chargers and share in the resulting revenue.

The purpose of this manual is to inform requesters of the records held by linqEV (Pty) Ltd, the procedure for requesting access to those records, and the rights and remedies available under PAIA. This manual is available free of charge on our website at linqev.co.za, at our registered office during normal business hours, and on request.

The blanket exemption that previously relieved certain private bodies of the obligation to compile a PAIA manual has lapsed. Accordingly, linqEV (Pty) Ltd publishes this manual as required by PAIA.

2. Particulars of the private body

3. Head of the private body, Information Officer and Deputy Information Officer

In terms of PAIA, the head of a private body that is a juristic person is the chief executive officer or equivalent officer, or the person acting in that capacity. The head of linqEV (Pty) Ltd, acting jointly, and the Information Officer responsible for the administration of this manual and for deciding requests for access to records, are:

The Information Officer and Deputy Information Officer are registered with the Information Regulator (South Africa) in terms of section 55 of the Protection of Personal Information Act 4 of 2013 under registration number 2026-023870, dated 4 June 2026. All requests for access to records must be directed to the Information Officer at the contact details above.

4. The Information Regulator's PAIA Guide

The Information Regulator has, in terms of section 10 of PAIA, compiled a guide in an accessible form to assist a person who wishes to exercise a right of access to information. The guide is available in each of the official languages and explains how to use PAIA to obtain access to a record. The guide may be obtained from the Information Regulator at the contact details below:

Information Regulator (South Africa)

5. Categories of records held by linqEV (Pty) Ltd

The following categories of records are held by linqEV (Pty) Ltd. The list is indicative and not exhaustive, and not all records within a category will necessarily be available for access — access to any record remains subject to the grounds for refusal set out in section 9 of this manual and in PAIA.

6. Records available without a formal request

The following records are available to the public without the need to submit a formal PAIA request, and may be accessed free of charge on our website:

• Privacy Policy
• Terms of Service
• This PAIA Manual
• Published tariffs and fees
• Marketing and product information published on the website

7. Records accessible in terms of other legislation

Certain records held by linqEV (Pty) Ltd are accessible in accordance with, and subject to the requirements of, other legislation, including but not limited to: the Companies Act 71 of 2008; the Income Tax Act 58 of 1962; the Value-Added Tax Act 89 of 1991; the Basic Conditions of Employment Act 75 of 1997; the Labour Relations Act 66 of 1995; the Consumer Protection Act 68 of 2008; and the Protection of Personal Information Act 4 of 2013. Access to records under those laws is governed by the procedures set out in the relevant legislation.

8. How to request access to a record

A request for access to a record held by linqEV (Pty) Ltd must be made as follows:

1. Complete the prescribed request form. A request by a person for access to a record of a private body must be made on the form prescribed for that purpose under PAIA (the request form for access to a record of a private body).
2. Submit the completed form to the Information Officer at privacy@linqev.co.za, or by delivery to the physical address set out in section 2 of this manual.
3. Provide sufficient particulars to enable the Information Officer to identify the record requested and to identify the requester, and specify the form of access required.
4. Specify the postal address, email address or other means by which the requester wishes to be informed of the decision on the request.
5. Where the request is made on behalf of another person, submit proof of the capacity in which the requester is making the request, to the satisfaction of the Information Officer.
6. Where access is requested in order to exercise or protect a right other than a right of access to the requester's own personal information, identify the right that the requester is seeking to exercise or protect and explain why the record is required to exercise or protect that right.
7. Pay the prescribed request fee and, where applicable, the prescribed access fee (see section 10 of this manual).

The Information Officer will decide the request within 30 days of receipt, unless that period is extended in the circumstances permitted by PAIA, in which case the requester will be notified of the extension. If the request for access is refused, the requester will be given reasons for the refusal and informed of the right to lodge a complaint or bring an application as set out in section 11 of this manual.

9. Grounds for refusal of access

linqEV (Pty) Ltd may, and in certain cases must, refuse a request for access to a record on the grounds set out in PAIA. In summary, and without limiting those grounds, access may be refused where granting it would involve:

• the unreasonable disclosure of personal information about a third party who is a natural person, including a deceased person (mandatory protection of the privacy of a third party);
• the disclosure of commercial information of a third party, such as trade secrets, financial, commercial, scientific or technical information the disclosure of which could harm that third party;
• a breach of a duty of confidence owed to a third party in terms of an agreement;
• the endangerment of the life or physical safety of an individual, or prejudice to the security of property;
• the disclosure of a record that is privileged from production in legal proceedings;
• prejudice to the commercial activities of linqEV (Pty) Ltd, including its trade secrets, financial, commercial, scientific or technical information, and information that could put it at a disadvantage in contractual or other negotiations or prejudice it in commercial competition;
• the disclosure of research information of linqEV (Pty) Ltd or a third party where disclosure would expose the researcher or the subject matter to serious disadvantage.

A request may also be refused where it is manifestly frivolous or vexatious, or where the work involved in processing it would substantially and unreasonably divert the resources of linqEV (Pty) Ltd. Where a ground for refusal applies only to part of a record, access will be given to the remainder in so far as it can reasonably be severed.

10. Fees

Request and access fees are those prescribed in the regulations made under PAIA. A requester may be required to pay a request fee before the request is processed, and an access fee for the reproduction, search and preparation of the record and, where applicable, for postage. The requester will be notified of the access fee payable before the request is processed, and may lodge a complaint against the tender or payment of that fee. No request fee is payable where a requester seeks access to a record containing their own personal information.

11. Remedies available to a requester

A requester or third party who is dissatisfied with a decision of the Information Officer may lodge a complaint with the Information Regulator, on the form prescribed for that purpose, within 180 days of the decision. A requester or third party may thereafter, or instead, apply to a court for appropriate relief. The Information Regulator's contact details are:

Information Regulator (South Africa)

12. Availability and updates of this manual

This manual is available, free of charge: on our website at linqev.co.za; at the registered office of linqEV (Pty) Ltd during normal business hours; and from the Information Regulator. This manual will be updated as and when necessary to reflect changes in the operations of linqEV (Pty) Ltd, the records it holds, or the applicable law.

13. Contact details

Registered with the Information Regulator (South Africa) in terms of section 55 of POPIA under registration number 2026-023870, dated 4 June 2026.

Annexure A — What a request for access must contain

A request for access to a record held by linqEV (Pty) Ltd must be made on the form prescribed under PAIA for a request for access to a record of a private body. The prescribed form is published by the Information Regulator and may be downloaded free of charge from the Regulator's website at inforegulator.org.za. A copy will also be provided on request from the Information Officer at privacy@linqev.co.za.

Whichever form is used, section 53 of PAIA requires the request to contain the following. A request that does not contain these particulars may be delayed or refused.

1. The requester's full name, identity number, and contact details, including a postal address or email address in the Republic to which a decision may be sent.
2. Sufficient particulars of the record requested to enable the Information Officer to identify it. Where the requester does not know how a record is described, a description of the subject matter and the approximate period it relates to will assist.
3. The form of access required — for example an electronic copy, a printed copy, or an inspection of the record.
4. The manner in which the requester wishes to be informed of the decision on the request, and the necessary particulars for that manner of notification.
5. Where the request is made on behalf of another person, proof of the capacity in which the requester is making the request, to the satisfaction of the Information Officer.
6. Where access is requested for a purpose other than access to the requester's own personal information, an identification of the right the requester is seeking to exercise or protect, and an explanation of why the requested record is required to exercise or protect that right.
7. Where the requester wishes to be assisted because of a disability, a statement of that disability and of the manner in which the request is made and access is required.

Send the completed request to the Information Officer at privacy@linqev.co.za, or by delivery to the address in section 2 of this manual. The Information Officer will confirm receipt, notify the requester of any fee payable before processing begins, and decide the request within 30 days, subject to any extension permitted by PAIA.