Regulatory Compliance Declaration

Global Manufacturing Africa (Pty) Ltd ("GMA") is committed to operating in full compliance with all applicable laws and regulations in South Africa and the jurisdictions in which it operates. This declaration sets out GMA's current compliance obligations and status.

1. South African Legal Compliance

• Companies Act 71 of 2008: GMA is registered as a private company (Pty) Ltd. The company maintains its statutory registers, minute books, and financial records as required.
• Income Tax Act 58 of 1962 & VAT Act 89 of 1991: GMA is registered with SARS for income tax and VAT (where applicable). All returns are filed timeously.
• Labour Relations Act 66 of 1995 (LRA) & Basic Conditions of Employment Act 75 of 1997 (BCEA): GMA maintains lawful employment contracts and complies with minimum conditions of employment, disciplinary procedures, and fair dismissal requirements.
• Consumer Protection Act 68 of 2008 (CPA): GMA's terms of sale, warranty terms, and product documentation are aligned with CPA requirements. Consumers' rights to disclosure, safety, fair dealing, and redress are respected.
• Protection of Personal Information Act 4 of 2013 (POPIA): GMA has appointed an Information Officer and implemented a POPIA compliance programme. A Privacy Policy is published and available on the GMA website.
• Broad-Based Black Economic Empowerment (B-BBEE): GMA is committed to B-BBEE compliance and transformation. The company's B-BBEE status is measured annually by an accredited verification agency.

2. Financial and Trade Compliance

• Financial Intelligence Centre Act 38 of 2001 (FICA) & Anti-Money Laundering (AML): GMA conducts customer due diligence and KYC checks for all business partners and high-value transactions in accordance with FICA requirements.
• Prevention and Combating of Corrupt Activities Act 12 of 2004: GMA maintains a zero-tolerance policy towards bribery and corruption. No facilitation payments are made to public officials or private parties.
• Export Controls and Sanctions: GMA complies with South African export control regulations and applicable international sanctions regimes. The Aftrak AFT-e1 and associated products are subject to export classification review prior to international sale.
• Competition Act 89 of 1998: GMA does not engage in prohibited restrictive practices, price-fixing, or market allocation. Reseller and distributor pricing structures are compliant with competition law.

3. Product Regulatory Compliance

• Product Safety: GMA products are designed and tested in accordance with applicable South African National Standards (SANS) and international standards where relevant.
• ICASA (Independent Communications Authority of South Africa): GMA's products incorporating wireless/cellular technologies (including the Aftrak AFT-e1 IoT module) are subject to ICASA type approval requirements. GMA ensures that all wireless devices meet applicable approval requirements prior to sale in South Africa.
• GPS and Geospatial Compliance: GMA's precision farming products incorporating GPS technology comply with applicable South African geospatial regulations and the regulations of the countries in which the products are used.

4. Data and Privacy Compliance

• GMA processes personal information in accordance with POPIA and, where applicable, the EU General Data Protection Regulation (GDPR) and UK GDPR.
• GMA's full Privacy Policy is available at /legal/privacy-policy.
• GMA's POPIA-specific Privacy Notice is available at /legal/privacy.
• GMA's PAIA Manual and data access request procedure are available at /legal/paia.

5. Employment and Equity Compliance

• Employment Equity Act 55 of 1998 (EEA): GMA is committed to equal opportunity employment and, as it scales, will comply with employment equity plan and reporting requirements as they become applicable.
• Equity Compensation (ESOP / SARs): GMA's employee equity and share appreciation rights (SARs) programmes are structured in compliance with South African tax law (Section 8C Income Tax Act) and, where applicable, Exchange Control Regulations governing employee equity schemes.
• Unemployment Insurance Fund (UIF) & Compensation for Occupational Injuries and Diseases Act (COIDA): GMA registers employees with the UIF and COIDA as required.

6. Declaration

GMA's board of directors confirms that, to the best of their knowledge and belief, GMA is conducting its business in material compliance with applicable laws and regulations as at the effective date of this declaration. GMA is committed to maintaining and improving its compliance posture as the company grows and as regulatory requirements evolve.

This declaration does not constitute legal advice. GMA obtains professional legal counsel in respect of its compliance obligations.

7. Contact

For compliance queries, contact: [email protected]