Our Policies

Complaints Policy

1. Introduction

The Financial Advisory & Intermediary Services Act 2002 deals with complaints in some length. Specifically, section 27(1) Receipt of Complaints, prescription, jurisdiction and investigation

All licensed financial service providers FSP’s will be required to have systems in place for the purpose of timeous and efficient resolution of complaints within the specified timeframes.

2. Definition of Complaint

Complaint means a specific complaint relating to a financial service rendered to the client on or after the date of commencement of FAIS, alleging that we:

Contravened or failed to comply with a provision of FAIS and that, as a result, The client has suffered financial prejudice or damage.
Willfully or negligently rendered a financial service to the client which was caused prejudice or damage to the client or which is likely to result in such prejudice or damage; or
Treated the client unfairly.

3. Complaints procedure

We deal with complaints as follows:

3.1. Log the date and contents of the complaint in the Complaints Register.

3.2. If a complaint is not in writing, ask the client to lodge the complaint in writing.

3.3. Acknowledge receipt of the complaint in writing within 5 days of receipt and give the client the name(s) and contact details of the staff responsible for the resolution of the complaint.

3.4. Investigate the complaint to ascertain whether the complaint can be resolved immediately.

3.5. If the complaint can be resolved immediately, take the necessary action and advise the client accordingly.

3.6. If the complaint cannot be resolved immediately, send the client a written summary of the steps to be taken to resolve the matter and the expected date of resolution.

3.7. If unable to resolve the complaint within 3 weeks of logging the complaint with the Complaints Register, notify the client by means of a written acknowledgement. This will outline the current status of the complaint and the expected date of final resolution.

3.8. If unable to resolve the complaint within a further 3 weeks of the written acknowledgement (6 weeks since complaint logged), notify the client giving full written reasons as to why the outcome was not favourable, and advise the client of their right to seek legal redress by referring the complaint to the Office of the Ombudsman – Kasteel Park Office Park, Orange Building, 2nd Floor, 546 Jochemus Street, Erasmus Kloof, Pretoria, 0048.

3.9. Notify the complainant that he/she has 6 months of receipt of such notification to refer the matter to the Financial Ombud. The Ombud’s name, address and other contact details must be provided.

3.10. Update the register with all developments/activities.

4. Complaints process flow

  1. Client lodges
  2. If complaint is not in writing, ask for a written complaint
  3. Complaint received, validated and logged as a new Complaint on Complaint register
  4. Acknowledge receipt of complaint in writing within 5 days
  5. Complaint assigned & investigated
  6. Resolve the complaint immediately or take the necessary action and advise the client of steps taken and expected date of resolution
  7. Update the complaints register with all developments/ activities
  8. Inform client in writing of the resolution of the complaint and the outcome
  9. Notify the client if complaint is not resolved within 3 weeks –advise on status of the complaint
  10. Notify the client of final outcome. This must be no later than 6 weeks since the complaint was logged/ Advise client of other options

5. Complaints Register.

The register should contain the following fields:

Received: This field will reflect the date on which the letter was received. The receipt period starts its calculations here.

Date Captured: The date of the day on which the complaint is captured.

Received From: The name and designation of the person that submitted the complaint must be entered here. It may be a client or a client’s representative.

Complaint Reference Number: This field contains the clients’ reference number linked to an internal system

Client Surname and Initials: Enter the surname of the client making the complaint.

Complaint Description/Type: Short summary of the complaint

Captured by: The name of the person who captured the complaint.

Responsible person internally: Who will deal with the complaint and ensure that it is resolved.

Activity Update: Log all developments and movements.

Outcome of Complaint: Summary of what decisions was taken.

Date of Final Communication to client: Date of letter to the client.

Compliance Officer Final Sign Off Designated: compliance officer to sign off a complaint as finalised

Learnings: This is a field where any possible lessons learned from the handling of this complaint can be entered.

TCF Policy

1. Introduction

The overriding principle central to Geddes Capital’s culture and ethos is that clients come first. Geddes Capital is committed to the fair treatment of all clients, irrespective of size or vehicle through which they access our products and services. Geddes Capital recognises that client satisfaction is the foundation on which to build a Business which is sustainable over the long term. Delivering optimal customer outcomes is an enterprise-wide responsibility and requires participation from all parts of the business. Apart from any legislative or regulatory obligations, treating customers fairly is a business imperative. Without clients we have no business.

2. Client Charter and Values

Our client centric business model is reflected in our “Client Charter” and “Values”:

Client Charter:

We strive to always put the interests of clients first;

We have an unwavering commitment to the building of long–term sustainable client relationships;

We focus on producing investment performance over meaningful periods that meets our clients’ investment objectives and expectations;

We are uncompromising about applying ethics and good governance across all areas of our business.

  • Ownership
  • Always put clients first
  • Long-term thinking
  • Team-based organisation
  • Always act with integrity
  • Strong performance culture
  • Our Client Charter and Values, established since the start of our business are key drivers of our strategy as well as our day-to-day dealings with clients.

3. Treating Customers Fairly: The Financial Services Conduct Authority (FSCA)

The FSCA published its “Treating Customers Fairly (“TCF”) Roadmap” in March 2011 as a first step towards achieving TCF fairness outcomes and culture framework requirements. In particular, the FSBCA requires firms to measure their activities against six TCF fairness outcomes (the “Outcomes”) that aim to reduce market conduct risks and protect consumers of financial products:

Outcome 1 (“Culture”): customers are confident that they are dealing with a financial services provider where the fair treatment of customers is central to its culture;

Outcome 2 (“Products and Services”): products and services marketed and sold in the retail market are designed to meet the needs of identified customer groups and are targeted accordingly;

Outcome 3 (“Clear and Appropriate Information”): customers are given clear information and are kept appropriately informed before, during and after the time of contracting;

Outcome 4 (“Customer Advice”): where customers receive advice, the advice is suitable and takes account of their circumstances;

Outcome 5 (“Product Performance Expectations”): customers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect;

Outcome 6 (“Post Sale Barriers”): customers do not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint.

Geddes Capital fully supports the FSCA’s TCF Outcomes, to the extent relevant to our business and our role in the investment product value chain. Most of the principles that support the Outcomes are expressed in our Client Charter and Values, referenced above.

We have a process in place whereby we periodically evaluate ourselves against the Outcomes and we always strive to improve the manner in which we live and/or evidence our adherence to the TCF principles. The TCF principles are a business imperative, embedded in our strategy, governance and daily processes, as more fully described below:


Service excellence: consistent with our Client Charter and Values, which encapsulates the culture that guides our behaviour, putting clients’ needs at the forefront of what we do is a key priority.

Engagement with our institutional clients takes place on an ongoing basis through frequent interaction at client meetings, investment report-backs and operational due diligences, as well as via the monthly and quarterly reporting process. Dedicated client relationship managers and fund managers ensure that client requests for information are attended to timeously.

Within the retail business, a team of client service professionals respond to all client queries in accordance with strictly monitored turnaround times. We aim to provide excellent levels of service to all our clients, measured through ongoing client experience surveys with our direct retail investors and annual qualitative research within the independent financial advisor market. The key principles of our retail client service philosophy are accessibility, accuracy and simplicity. We have therefore set demanding client service benchmarks to ensure that our client service team remains focused on delivering on these principles.

Client Data: Geddes Capital recognises that technology, although playing a vital role in enabling channels of business, also presents a risk of exposing confidential client and company data. Geddes Capital is dedicated to the protection of clients’ personal information, and therefore ensures that business processes are protected by appropriate governance and controls. Geddes Capital uses external providers to assess its customer security framework to ensure that appropriate information security considerations, process architecture frameworks and standards are properly identified, managed, understood and embedded throughout all transactional interactions with clients.

Product Information and Communication: Geddes Capital assesses, in aggregate, not in isolation, the cumulative impact of all client communications, for consistency of messaging and its impact on clients. To ensure consistency of messaging, all formal communication to clients goes through a rigorous review and sign-off process.

Clients receive regular communication covering a range of topics. We host comprehensive meetings and presentations throughout the course of the year and conduct focused research at multiple customer touch points.

Post-sale barriers: Geddes Capital is committed to ensuring the clients do not face unreasonable post-sale barriers to changing products, switching providers or making complaints. Geddes Capital does not impose any exit penalties, surrender fee or other charges to discourage clients to withdraw from products, where the aim is to balance the interests of short-term liquidity seeking and long-term investors. All product related features are disclosed during the purchase process. The only access constraints applied are those required by law.

Client criticism, both positive and negative, is a crucial feedback mechanism in prioritising our focus and resources. Geddes Capital has a formal “Complaints Procedures: Guidelines for Clients” that is available to clients on our website. Geddes Capital is committed to handling client complaints in a timely and fair manner and has implemented systems and procedures to satisfy this commitment (see the Complaints Policy for more detail). Geddes Capital provides a number of avenues for clients to provide feedback and/or log a complaint, namely: walk-in facility; email; post, and/or through their relationship consultant (if applicable). Geddes Capital also conducts surveys at the point of client interaction to assess the quality of the interaction and an annual “Financial Advisor Survey” to analyse longitudinal trends with respect to service levels, product performance and opinion. Clients are kept updated throughout any complaints process to ensure that their expectations are managed throughout.

Other example of where the TCF principles evidenced in our approach to daily business:

Geddes Capital has a consistent fee methodology that is reviewed across all product vehicles and mandate spectrums.


Geddes Capital maintains a robust corporate governance framework, effected through a unitary board, various subcommittees, management forums, the appointment of an independent Compliance officer and other independent assurance providers. The regulatory environment continues to evolve, both in South Africa and internationally. We are proactive in shaping a safer financial sector as contemplated in National Treasury’s “A safer financial sector to serve South Africa better, and direct engagement with our regulators.

Geddes Capital continues to place a high priority on ensuring it complies with all regulatory and statutory obligations, as well as industry best practice. The principles supporting the TCF Outcomes are at the centre of the board’s decision-making processes.


At the heart of the Geddes Capital DNA are our people.

Staff enjoy an open-door policy, providing for ongoing dialogue with management on any aspect of the business.

Staff compensation is directly linked to the strength, performance and service delivery to clients. Variable compensation is utilised to reward staff for their contribution towards the success of the company, including acknowledgment of exceptional performance. We rate and reward our people on their ability to add value to our clients and the business.

Regulators and Industry Bodies

We undertake to always engage in an open and transparent manner with our regulators. We engage with the following regulatory bodies in the various jurisdictions in which we operate:

Financial Services Board (South Africa)/ (FSCA)

Through our membership of industry bodies, we are able to lobby our views on proposed legislation and potentially influence legislation, with the aim of ensuring that the interests of investors and the industry are taken into consideration.


All key focus areas of our business combine in the execution of our strategy to create shareholder value. The sustainability of our business lies in our ability to produce consistent superior long-term investment performance, provide client service excellence, ensure client retention and the integrity of our business.


The TCF framework designed by the FSCA is a set of principles/norms that will find their way into law via existing legislation, regulation and guidelines. There are many examples of the TCF Outcomes already incorporated into the existing regulatory framework, however the FSCA is considering a “Conduct of Business Act” with specific “Codes of Conduct” to give further legislative effect to their stated goals.

On the basis that regulation around TCF is yet to be fully defined, this Policy will be subject to routine review as the regulatory environment becomes clearer.

Conflict of Interest Policy

1. Introduction

This policy applies to all levels of management, inclusive of shareholders and directors, as well as all employees and consultants.

2. What is a conflict and when may it arise

A conflict is defined by the company as a difference in what is being performed by all representatives and what is required from the corporation in terms of the mandate of operations. These types of conflict may arise in the ordinary course of business and all representatives of the business are susceptible too.

3. How we manage conflicts of interest

Financial interests- cash, voucher, gift, discount, advantage, benefit, domestic or foreign travel, hospitality, accommodation, sponsorship, training is all documented and reviewed quarterly by management at the compliance meetings

Immaterial financial interests- Gifts & hospitality (Under R5,000) is not required to be documented, but is required to be verbally discussed.

All Ownership interests are fully disclosed.

4. Geddes Capital Conflict of interest Policy

1. Introduction

This document details Geddes Capital – Conflicts of Interest Management Policy

A short summary of this policy is included in the “Letter of Introduction” document, issued and explained to clients at the beginning of the sales process. The full Management Policy document is also available on request.

This policy applies to all employees of Geddes Capital (Pty) Ltd.

2. What is a Conflict of Interest and when may it arise?

A conflict of interest may arise where a company, or one of its employees, is providing a financial service to its clients and may entail a material risk of damage to those clients interests, and whether the company or its employee:

  • Is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
  • Has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
  • Has a financial or other incentive to favour the interest of another client, or group of clients, over the interests of the client;
  • Carries on the same business as the client; or
  • Receives or will receive from a person other than the client, an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service.
3. How we manage conflicts of interest

The following are examples of conflicts of interest and how we manage these conflicts:

Contracts, proposed contracts and similar transactions or arrangements

A conflict of interest may arise where an employee has a direct, or indirect interest in a transaction. This may be where the employee has a connection with the other party to the transaction, or where the employee’s family has a connection. The connection may be from a directorship, significant shareholding, employment or consultancy.

Geddes Capital (Pty) Ltd requires disclosure of any connection which could or could be seen to have the effect of compromising the judgment of any of our employees. Employees are required to notify Management of any such potential conflicts of interest, who will then decide if the employee can be involved in the transaction. Management will also ensure that the relevant provisions have been met.

Gifts, Hospitality & Inducements

Inducements, gifts and hospitality are all issues that could lead to potential Conflicts of Interest. Geddes Capital (Pty) Ltd has a strict policy regarding such issues, which is documented in the Company’s operational policy guide. All Employees must act with the highest standards of integrity to avoid any allegations of Conflicts of Interest.

Employees must not accept any cash payments, significant gifts or hospitality. Token gifts may be accepted, providing they have not been solicited, have not been given as a business inducement and will not compromise management’s integrity. A register is kept of any gifts, or hospitality received.

Employees cannot attend hospitality events, without the proper management approval. Where an invitation could be construed as being a business inducement, it must be declined.

4. Conflict of interest employee policy

Management expects all its employees to maintain the highest standards in carrying out their business activities, adhering to legislative requirements and our policies on business conduct. Management expects its employees to act professionally, honestly and ethically in all their dealings with clients, colleagues and third parties. has a clear policy on Conflicts of interest;

  • Conflicts of Interest should always be avoided, wherever possible.
  • Conflicts or potential Conflicts of Interest must always be disclosed. Geddes Capital (Pty) Ltd will not tolerate non-disclosure by its employees.

PAIA Manual

Download PAIA Manual


The purpose of this Manual is to assist persons wishing to access information in terms of the Promotion of Access Information Act (PAIA), promulgated in March 2001 from Geddes Capital (Proprietary) Limited.

This manual is not exhaustive nor does it comprehensively deal with every procedure provided for in the Act. Requesters are therefore advised to familiarise themselves with the provisions of the Act.

The manual provides an overview of records held by Geddes Capital and the processes that needs to be adopted to access such records.


All requests for access to information (other than information freely available to the public) should be directed to the Head of the Organisation: Chief Executive Officer, +27 (0) 82 619 2700 or brent@geddescapital.co.za


3.1 Organisation

Geddes Capital

3.2 Person

Refers to a natural or juristic person.

3.3 Head

In terms of the Act:

head’ of or in relation to a juristic person means-

(i) the chief executive officer or equivalent officer of the juristic person or any, person duly authorised by that officer; or

(ii) the person who is acting as such or any person duly authorised by such acting person.


Geddes Capital was founded in Cape Town in 2017 by Brent Geddes, Carnel Botha and Warren Deats. Carnel, a Chartered Accountant, Brent, an Investment Banker and Trader and Warren, a Global Equity Trader and Investor who has spent the previous 17 years in various divisions of investment banking and professional services in Johannesburg, London, Hong Kong and Tanzania. The unique skill set of the team and their desire to return to Cape Town to take advantage of the many opportunities that South Africa has to offer was the cornerstone for the creation of the business.

Geddes Capital operates several different business units that leverage the unique skill-set of the team to add value in specific areas.


Geddes Capital (Proprietary) Limited
Physical address
16 Kreupelbosch Way
Republic of South Africa
Telephone Number
+27(0) 82 619 2700
Email: brent@geddescapital.co.za
Website: www.geddescapital.co.za


Mr B Geddes
Chief Executive Officer
Contact Details
T: +27 82 619 2700
E: brent@geddescapital.co.za

Mr W Deats
Chief Investment Officer
Contact Details
T: +27 79 594 6767
E: warren@geddescapital.co.za


7.1 Records in terms of Section 51(1) (d))

The company also maintains records in terms of the following legislations (please note that this is not an exhaustive list):

  • Public Finance Management Act 1 of 1999
  • Basic Conditions of Employment Act 75 of 1997
  • Compensation for Occupational Injuries and Diseases Act 130 of 1993
  • Competition Act 89 of 1998
  • Financial Advisory and Intermediary Services Act 37 of 2002
  • National Credit Act 34 of 2005
  • Prevention of Corrupt Activities Act
  • Protected Disclosures Act
  • Consumer Protection Act 68 of 2008
  • Electronic Communications and Transactions Act 25 of 2002
  • Employment Equity Act 55 of 1998
  • Financial Intelligence Centre Act 38 of 2001
  • Income Tax Act 58 of 1962
  • Intellectual Property Laws Amendments Act 38 of 1997
  • Labour Relations Act 66 of 1995
  • Occupational Health and Safety Act 85 of 1993
  • Regional Services Councils Act 109 of 1985
  • Skills Development Act 97 of 1998
  • Skills Development Levies Act 9 of 1999
  • Unemployment Insurance Act 63 of 2001
  • Unemployment Insurance Contributions Act 4 of 2002
  • Value Added Tax Act 89 of 1991

7.2 Maintenance of records in terms of Section 51(1) (e)

The following is a list of operational records maintained by Geddes Capital and is utilised in the day to day running and administration of the company:

  • Accounting records
  • Information Technology
  • Intellectual Property
  • Personnel Records
  • Sales and Marketing
  • Statutory Company records
  • Client Databases
  • Internal Phone lists
  • Policies
  • Procedures
  • Work Instructions
  • Standards
  • Directives
  • Minutes of Meetings
  • Administrative information


A request to access information must be made in writing using the attached Request Form as set out in Annexure 1 of this manual. The request form must be marked for the attention of the Head or duly authorised company representative and may be posted, emailed or faxed to the contact details noted in Section 5 & 6 above. The requester must indicate which form of access is required, and identify the right that is sought to be exercised or protected, provide an explanation of which the requested record is required for the exercise or protection of that right and proof of the capacity in which the requester is requesting the information.

On receipt of a written request, the Head or duly authorised company representative will, in writing and as soon as it is reasonably practicable but within 30 days of such receipt, notify the requestor of the following information when the request has been granted:

  • Of any fees payable, if any (see fee section below);
  • The form in which the access will be granted; and
  • That the requestor may lodge an application with a court against the access fee or form of access granted.

On receipt of a written request, the Head or duly authorised company representative will, in writing and as soon as it is reasonably practicable but within 30 days of such receipt, notify the requestor of the following information when the request has been denied:

  • State adequate reasons for the refusal; and
  • State that the requestor may lodge an application with a court against the refusal of the request and the procedure for lodging the application.


A person who requires a copy of this manual can access it on Geddes Capital website www.geddescapital.co.za or alternatively a hard copy may be obtained free of charge at our offices in Cape Town.

Physical Address
Cape Town
16 Kreupelbosch Way

This manual is available for inspection by the general public upon request during office hours and there is no charge for viewing the manual at any of our offices located at the above-mentioned address.

Copies of this manual may also be requested from the South African Human Rights Commission at the address indicated below.

The South African Human Rights Commission (PAIA Unit)

Research and Documentation Department

Private Bag 2700



Phone: 011 484 8300

10. FEES

A fee will be required by the head (contact person) before further processing of the request in terms of S54 of the Act.

A requester fee of R5,000 should be paid, this amount will be refunded should the request for access be refused.

A portion of the access fee (not more than one third) may be required before the request is considered.

The head may withhold a record until the requester has paid the applicable fees.


The South African Human Rights Commission has compiled a guide containing such information as may be required by a person who wishes to exercise any right contemplated in the Act. The guide to this Act may be accessed at the SAHRC website at the address noted below.

The contact details of the Commission are:

The South African Human Rights Commission (PAIA Unit)
Research and Documentation Department
Private Bag 2700
Phone: 011 484 8300
Fax: 011 484 0582
Email: PAIA@sahrc.org.za

Privacy Policy & Website User Terms

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We understand that your personal information is important to you and that you may be apprehensive about disclosing it. Your privacy is just as important to us and we are committed to safeguarding and processing your information in a lawful manner.

We also want to make sure that you understand how and for what purpose we process your information. If for any reason you think that your information is not processed in a correct manner, or that your information is being used for a purpose other than that for what it was originally intended, you can contact our Information Officer.

You can request access to the information we hold about you at any time and if you think that we have outdated information, please request us to update or correct it.

The Privacy Policy and the User Policy contained herein are policies for Geddes Capital (Pty) Ltd and all affiliated entities or subsidiaries of this entity and any reference to one entity shall be deemed to be a reference to other entities within the group, to the extent the context required (“Geddes”).

Geddes may amend the provisions of this Privacy Policy and User Policy to comply with any changes in the law, and/or pursuant to any changes to its information processing activities or privacy practices. Such amendments will be published on the website and will become operable from the date of such publication.


1.1. Agreement between user and Geddes:

The Geddes website is offered to you on condition of your acceptance without modification of the terms, conditions, and notices contained herein. Your use of the Geddes website constitutes your agreement to all such terms, conditions, and notices.

1.2. Modification of these terms of use:

Geddes reserves the right to change the terms, conditions, and notices under which the Geddes website is offered, including but not limited to the charges associated with the use of the Geddes website.

1.3. Links to third party sites:

The Geddes website may contain links to other websites (“Linked Sites”). The Linked Sites are not under the control of Geddes and Geddes is not responsible for the contents of any Linked Site, including without limitation any link contained in a Linked Site, or any changes or updates to a Linked Site. Geddes is not responsible for webcasting or any other form of transmission received from any Linked Site. Geddes is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by Geddes of the site or any association with its operators.

1.4. No unlawful or prohibited use:

As a condition of your use of the Geddes website, you warrant to Geddes that you will not use the website for any purpose that is unlawful or prohibited by these terms, conditions, and notices. You may not use the website in any manner which could damage, disable, overburden, or impair the website or interfere with any other party’s use and enjoyment of the website. You may not obtain or attempt to obtain any materials or information through any means not intentionally made available or provided for through the website.

1.5. Materials provided to Geddes:

Materials or information uploaded to on the Geddes website may be subject to posted limitations on usage, reproduction and/or dissemination.

Geddes does not claim ownership of the materials you provide to Geddes (including credit applications) or post, upload, input or submit to any Geddes website or its associated services (collectively “Submissions”). However, by posting, uploading, inputting, providing or submitting your Submission you are granting Geddes, its affiliated companies and necessary sub-licensees permission to use your Submission in connection with the operation of their internet businesses including, without limitation, the rights to: copy, distribute, transmit, publicly display, publicly perform, reproduce, edit, translate and reformat your Submission; and to publish your name in connection with your Submission.

No compensation will be paid with respect to the use of your Submission, as provided herein. Geddes is under no obligation to post or use any Submission you may provide and may remove any Submission at any time in Geddes’ sole discretion.

By posting, uploading, inputting, providing or submitting your Submission you warrant and represent that you own or otherwise control all of the rights to your Submission as described in this section including, without limitation, all the rights necessary for you to provide, post, upload, input or submit the Submissions.

1.6. Liability disclaimer:

The information, software, products, and services included in or available through the Geddes website may include inaccuracies or typographical errors. Changes are periodically added to the information herein. Geddes and/or its suppliers may make improvements and/or changes in the Geddes website at any time. Any advice received via the Geddes website should not be relied upon for personal, legal or financial decisions and you should consult an appropriate professional for specific advice tailored to your situation.

Geddes and/or its suppliers make no representations about the suitability, reliability, availability, timeliness, and accuracy of the information, software, products, services and related graphics contained on the Geddes website for any purpose. To the maximum extent permitted by applicable law, all such information, software, products, services and related graphics are provided “as is” without warranty or condition of any kind. Geddes and/or its suppliers hereby disclaim all warranties and conditions with regard to this information, software, products, services and related graphics, including all implied warranties or conditions of merchantability, fitness for a particular purpose, title and non-infringement.

To the maximum extent permitted by applicable law, in no event shall Geddes and/or its suppliers be liable for any direct, indirect, punitive, incidental, special, consequential damages or any damages whatsoever including, without limitation, damages for loss of use, data or profits, arising out of or in any way connected with the use or performance of the Geddes website, with the delay or inability to use the Geddes website or related services, the provision of or failure to provide services, or for any information, software, products, services and related graphics obtained through the Geddes website, or otherwise arising out of the use of the Geddes website, whether based on contract, delict, negligence, strict liability or otherwise, even if Geddes or any of its suppliers has been advised of the possibility of damages. Because some jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages, the above limitation may not apply to you. If you are dissatisfied with any portion of the website, or with any of these terms of use, your sole and exclusive remedy is to discontinue using the website.

1.7. Termination or restriction to access:

Geddes reserves the right, in its sole discretion, to terminate your access to the website and/or the related services or any portion thereof at any time, without notice.

1.8. Interception and monitoring:

You agree that your communications on this website may be intercepted, as defined in the Regulation of Interception of Communications Act, No. 70 of 2002 (as amended), by Geddes or any other competent authority.

1.9. Copyright and trademarks:

Geddes reserves the right, in its sole discretion, to terminate your access to the website and/or the related services or any portion thereof at any time, without notice.

1.10. Cookies:

“Cookies” are small text files transferred by a webserver to your hard drive and thereafter stored on their computer. The types of information a Cookie collects includes your username, the date and time of your visits to the website, your browsing history and preferences. Geddes may use Cookies on this website to: distinguish one user from another on the website ;remember your last session when you return to the website; estimate the website’s audience size and usage patterns; store information about your preferences (which allows Geddes to customize the website and content according to your individual preferences); and speed up searches on the website.

The provisions of this clause are only applicable to Cookies used by Geddes. In some instances, third-party service providers may use Cookies on the website. Geddes cannot and does not control or access Cookies used by third party service providers and takes no responsibility therefor.

You have the right and ability to either accept or decline the use of Cookies on your computer’s web browser, whether you are logged in as a user, or simply casually visiting the website. However, declining the use of Cookies may limit your access to certain features on the website.

1.11. Miscellaneous:

These terms and conditions will be governed and construed in accordance with the law of the Republic of South Africa without reference to any conflict of law provisions and you agree that the South African courts shall have exclusive jurisdiction to determine any matter or dispute in connection with or arising out of this website and these terms of use.

You agree that no joint venture, partnership, employment, or agency relationship exists between you and Geddes as a result of these terms of use or use of the Geddes website.

Geddes performance under these terms of use is subject to existing laws and legal process, and nothing contained in these terms is in derogation of Geddes right to comply with governmental, court and law enforcement requests or requirements relating to your use of the Geddes website or information provided to or gathered by Geddes with respect to such use.

If any part of these terms are determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the warranty disclaimers and liability limitations set forth above, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the terms shall continue in effect.

Unless otherwise specified herein, these terms constitute the entire agreement between the user and Geddes with respect to the Geddes website and it supersedes all prior or contemporaneous communications and proposals, whether electronic, oral or written, between the user and Geddes with respect to the Geddes website.

A printed version of these terms and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to these terms to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.

It is the express wish to the parties that these terms and all related documents are drawn up in English.


2.1. Protection of Personal Information Act, 2013 (POPIA)

You acknowledge that by using the Geddes website and by transacting with Geddes you will be providing Geddes with personal data, which may be protected by data protection legislation, including inter alia, the Protection of Personal Information Act, 2013 (POPIA). You authorise us to process all such personal data and to transmit any such personal data to any Affiliate (which Affiliate may also process such personal data) for the purposes of performing the contract and in furtherance of Geddes’ legitimate interests including statistical analysis, marketing of our services and credit control. You also authorise us to process and transmit your personal data in the manner contemplated below in this Privacy Policy.

For purposes of this Privacy Policy, “Affiliate” means any member of the Geddes Capital group of companies, including without limitation, any subsidiary, sub-subsidiary, holding company, fellow subsidiary of any holding company of Geddes Capital (Pty) Ltd. You authorise Geddes to furnish information, which may be protected by data protection legislation, including inter alia, POPIA, regarding your account and trading history to any person we reasonably determine to be seeking a credit reference (including other Geddes trading companies) in good faith for any lawful purpose. For purposes of this Privacy Policy, “you” or “your” shall mean the natural person using this website and/or transacting with Geddes but shall also include any natural/juristic person or business on whose behalf the natural person is acting in relation to any transactions with Geddes.

2.2. Collection of your personal information:

As far as possible, we shall always collect personal information about you or your business directly from you. Personal information may be collected in any of the following ways –

  • during the process of registering as a user/applicant on our website;
  • provided by you as part of your profile pages on the website;
  • when requesting further services or information from Geddes;
  • provided by you when affixing the necessary supporting documents to any credit application; and/or
  • when completing any forms (including application forms) whether in hard copy or on our website.

In certain circumstances, we may also collect information about you from other sources. These circumstances include instances where personal
information about you or your business is provided to Geddes by brokers or other external third parties. Where Geddes collects personal
information from a source other than you, it shall record in writing the details of that source, including the full names and contact details of that
source where applicable.

By using this website or transacting with Geddes, you consent to Geddes requesting and obtaining credit information pertaining to you and/or
your business from any reputable credit reporting agency or institution for the purpose of concluding any transaction offered by Geddes.

2.3. Consent

To the extent you have not already signed a separate consent form, by using this website or transacting with Geddes you hereby consent to
the processing of your personal information in terms of the provisions of this Privacy Policy.
You acknowledge and agree that such consent has been given voluntarily after you have read and understood the provisions of this Privacy
Notice, in particular, regarding the following:

  • the types of personal information to be processed;
  • the specific processing activities to be undertaken;
  • the specific purpose/s for such processing; and
  • the possible consequences for you that may arise from such processing.

Should you wish to withdraw any consent previously given by you, you must notify Geddes’ information officer in writing. You have the right to withdraw any consent at any time, demand that the processing of the personal data be terminated and the gathered personal data be deleted or closed, provided that you do not have any valid finance agreements in place with Geddes or any open or failed credit/loan application(s) in with Geddes.

2.4. Purpose for Processing your Information:

We collect, hold, use and disclose your personal information to operate the Geddes website, to provide you with access to the services and products that we provide and to transact with you.

Geddes may also use your personally identifiable information to inform you of other products or services available from Geddes and its affiliates. Geddes may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

Geddes shall only collect your (or your business’s) personal information for a specific, explicitly defined and lawful purpose relating to a function or activity of the Geddes business. We will only process your information for a purpose you would reasonably expect, including –

  • to make the decision whether or not to enter into a contract with you;
  • to perform any obligations under a contract with you;
  • to comply with a legal obligation;
  • to protect a legitimate interest of yours (unless you have specifically objected in writing to all or some of the processing activities on
    reasonable grounds);
  • to pursue its own legitimate interests or the legitimate interests of a third party who it is sharing the information with (unless you have specifically objected in writing to all or some of the processing activities on reasonable grounds);
  • to process personal information for credit reporting purposes;
  • to process personal information for direct marketing purposes (unless you have opted out of receiving any direct marketing material);
  • to present content to you in the most effective way for you and your viewing device and browser;
  • to customise and display content including, but not limited to products, articles, listings and advertisement to you in a way that Geddes feels may interest you or be most beneficial to you;
  • to send content including, but not limited to products, articles, listings and advertisement content to you via email or other electronic media, where you have consented to be contacted by Geddes with such content;
  • to enable you to voluntarily participate in interactive features on the website;
  • to notify You about changes to the website;
  • providing you with products and services that suit your needs as requested;
  • to verify your identity and to conduct credit reference searches;
  • to issue, administer and manage your insurance policies where these are provided as collateral/security;
  • to notify you of new products or developments that may be of interest to you; and/or
  • to confirm, verify and update your details.

Some of your personal information that we hold may include the following –

  • initials, first name, surname or registered full name;
  • identity or registration number and/or date of birth;
  • physical and postal address;
  • email address, telephone and cell-phone numbers;
  • gender, nationality (residency status), ethnic and social origin, age, language preference;
  • financial information about you (your investments, assets, liabilities, insurance, income, expenditure and your banking details).
  • your personal opinions, views or preferences;
  • correspondence sent by you which is of a private or confidential nature;
  • the views or opinions of others about you or your business;
  • your credit information and history; and
  • any other personal information that may be provided by you to Geddes or obtained by Geddes or required by Geddes in relation to the
    provision of the services of Geddes to you or your business.

Save as detailed below, the supply of personal information by you to Geddes is voluntary and not mandatory. However, if you refuse to supply any personal information, certain consequences may naturally flow from such a refusal, such as preventing Geddes from concluding or performing any contract with you, or preventing Geddes from complying with one or more of its obligations in law.

Some of the aforementioned personal information may be mandatory to provide within the context of transacting with Geddes as requirements and disclosures. Failing to provide compulsory information may lead to our organisation’s inability to carry out the functions necessary to perform as an authorised financial services provider.

2.5. Third parties and your personal information

We may need to share your information to third parties provide the products or services that you have requested or for purposes of concluded or performing any transaction with you. Where we share your information, we will take all precautions to ensure that the third party will treat your information with the same level of protection as required by us.

These third parties who perform certain processing activities on behalf of Geddes may include:

  • banks or other financial institutions where you maintain or have maintained bank accounts, loan accounts or other financial or investment
    accounts and insurers or insurance brokers;
  • credit bureau service providers;
  • service providers who provide Geddes with legal assistance, accounting or auditing services, payroll services and/or other utilised to effectively operate the Geddes business;
  • delivery and courier service providers;
  • Payment Gateway Providers;
  • Bulk email delivery providers (where applicable);
  • your employer (where applicable);
  • the Compliance Officer of the organisation (where applicable);
  • analytics and search engine providers assisting in the enhancement of our websites;
  • information technology specialists assisting us with data storage, security, processing, analytics, etc;
  • auditors of Geddes; and/or
  • regulatory or governmental authorities such as the Financial Sector Conduct Authority and the Prudential Authority.

Geddes shall ensure that in any contracts entered into with third party operators who process personal information on Geddes’ behalf, include the following obligations:

  • the operator shall not process any personal information without Geddes’ knowledge and authority;
  • the operator shall treat all personal information given to it as confidential and shall not disclose it to any unauthorised third parties;
  • the operator shall establish and maintain adequate security measures which are the same or offer similar protection over the personal information as that employed by Geddes;
  • the operator shall notify Geddes immediately where there are reasonable grounds to believe that any personal information has been leaked to or accessed by any unauthorised person;
  • if the operator is situated in another country, it must comply with the data protection laws in that country and be able to provide verification that it is so compliant;
  • if an operator is legally obliged to disclose any personal information processed by them on Geddes’ behalf to other parties, it must notify Geddes beforehand to enable Geddes and/or you to protect your rights if necessary.

2.6. The transfer of your personal information outside of the Republic of South Africa

Subject to the clause below, Geddes does not intend sharing your personal information with a third party in another country.

Geddes may transfer personal information to another country in the following circumstances, to which you consent:

  • the transfer is necessary for the performance of a contract that Geddes has with you or the performance of services offered by Geddes to you;
  • the transfer is necessary for the implementation of pre-contractual measures taken in response to your request;
  • the transfer is necessary for the conclusion or performance of a contract with a third party which is for the benefit of or in the interest of you;
  • the transfer is otherwise for the benefit of you;
  • you have consented to the transfer of your information; or
  • to store your personal information electronically in a secure database, which shall be done by electronically transmitting your personal information via a secure connection to, and storing your personal information electronically in, a secure database hosted in an ISO27001 certified environment.

The service providers to which Geddes discloses your personal information in terms of the above clause and/or the User Policy above have the right to electronically transmit your personal information via a secure connection to, and store your personal information electronically in, a secure database hosted outside the Republic of South Africa, provided they have security and privacy policies and procedures providing at least the same level of protection as Geddes does.

2.7. Further processing

Geddes shall not process your personal information for any purpose not previously specified except in the following circumstances –

  • where you have consented to such further processing;
  • where the further processing is necessary for the exercise of any contractual rights or the fulfilment of any obligations between Geddes and you;
  • where the further processing activities are linked to or compatible with the original purpose;
  • where the further processing is necessary for the prevention, detection, investigation, prosecution and punishment of an offence;
  • where the further processing is necessary to enforce any law;
  • where the further processing is necessary for the conduct of legal proceedings in any court or tribunal that have commenced or are reasonably contemplated;
  • where the further processing is necessary to prevent or mitigate a serious and imminent threat to the life or health of you or another individual; or
  • where the further processing is necessary for historical, statistical or research purposes.

Geddes shall ensure that if it intends processing personal information for other purposes not previously specified, it shall notify you of such further purposes and the possible consequences of the intended further processing for you.

2.8. Storage and security of your personal information

Geddes secures your personal information from unauthorized access, use or disclosure. Geddes secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. These servers are always kept up to date with the latest security updates and are contained in industry recognised standard environments, keeping the data they store secure.

Any software written by, or on behalf of Geddes, is written using the most recent technologies available and implementing the most modern design patterns to ensure that deprecation and security prone features are not in the software stack.

When personal information (such as a bank account details) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. Geddes shall ensure that all personal information on its systems is properly backed-up and that back-up copies are stored separately from the live files.

Geddes shall ensure that, regardless of the stated purpose/s for processing personal information, the rights and interests of users such as you will not be unnecessarily prejudiced or infringed, unless it cannot be avoided, and then in such cases, it shall ensure that its own rights and/or interests justify such prejudice or infringement taking place.

Geddes takes steps to continually identify and document any risks to the personal information it has in its possession or under its control and that appropriate security safeguards are in place against those risks.

As the internet is not a secure medium of communication, Geddes cannot guarantee the security of any information you input on the Geddes website or otherwise send to Geddes via the internet. Geddes is not, and will not be, responsible for any damages you or others may suffer as a result of the loss of confidentiality of any such information.

Once Geddes has achieved the purpose for the collection of your personal information, it will destroy or delete such information, unless you have directed otherwise in writing, Geddes needs to keep a record of such information for another lawful purpose, or Geddes is required by law to retain the information for a longer period of time. If Geddes no longer needs to process personal information to achieve the purpose originally specified, it will stop using that information. Where Geddes is no longer authorised to retain a record of any personal information, it shall either: ensure that the information is permanently destroyed or deleted as soon as reasonably practicable; or return the information to you or transfer it to a third party, if requested by you in writing to do so.

2.9. Law authorising or requiring collecting of the personal information:

As an authorised financial services provider, we are obligated in terms of the following legislation to collect your personal information insofar as it relates to the rendering of the relevant financial services to you:

  • Financial Advisory and Intermediaries Services Act 37 of 2002;
  • Financial Intelligence Centre Act 38 of 2001;
  • Insurance Act 18 of 2017;
  • Short-Term Insurance Act 53 of 1998;
  • Long-Term Insurance Act 52 of 1998.

2.10. Accuracy of personal information

Geddes shall take reasonably practicable steps to ensure that the personal information kept by it about you is complete, accurate, not misleading and is updated when necessary.

However, if you are aware of any personal information in Geddes’s custody that is incorrect, inaccurate or which needs to be updated, you must make a written request to Geddes’s information officer to update or correct the relevant information.

If you have contested the accuracy of any personal information being used by Geddes, it shall immediately stop using that information until its accuracy has been verified.

Geddes reserves its right to only adhere to a request from you in terms hereof if the correction or updating of that information will result in the personal information being correct and accurate.

Where personal information that has been shared by Geddes with a third party is subsequently updated or corrected, Geddes shall ensure that all third parties, with whom that information was shared, receives the updated and/or corrected version of the information as soon as it has been updated and/or corrected.

2.11. Notifications of security breach

If personal information about you is inadvertently leaked or Geddes’ security has been unlawfully breached by any unauthorised party, Geddes shall immediately identify the relevant users who may be affected by the security breach, and shall contact them at their last known email address or contact details or by the quickest means possible.

Geddes shall provide sufficient information to you to allow you to take the necessary protective measures against the potential consequences of the compromise, or shall advise you of the steps to be taken by you and the possible consequences that may ensue from the breach for you.

2.12. Direct marketing

You hereby consent to the processing of your personal information for the purpose of direct marketing by means of electronic communications including automatic calling machines, facsimile machines, SMS’s or electronic mail.

Where you are a pre-existing customer of Geddes, Geddes shall be entitled, without your consent, to sending electronic communications to you for the purpose of marketing similar products or services offered by Geddes.

You may object, free of charge, and without unnecessary formality, to the use of their details either when the information was first collected from you or when each subsequent electronic communication is sent to you by Geddes and/or its subsidiaries.

You can opt out of receiving further marketing communications by un-checking certain boxes on the forms used on the website to collect their personal information, or by contacting Geddes.

2.13. Decisions based on personal information processed

If Geddes is required to make a decision about you using any personal information that has been obtained, it shall ensure that a record of such information and the decision made is kept for a reasonable period of time to give you an opportunity to request access to that record.

Geddes may allow you a reasonable opportunity to make representations before any decision is made solely on the basis of the personal information processed, if that decision will affect your legal position, or will otherwise adversely affect you in some manner or form.

Geddes shall always ensure that the underlying logic behind any decision made pursuant to the automated processing of personal information is sound and that this underlying logic may be able to be communicated to you to enable you to make representations.

If Geddes has made a decision based on incorrect personal information, it shall immediately revisit that decision as soon as it receives notice or becomes aware of the error or inaccuracy of that information

2.14. Changes to this Privacy Policy

The Geddes website is offered to you on condition of your acceptance without modification of the terms, conditions, and notices contained herein. Such changes, updates, additions, removals or amendments will become effective from the date of their publication on this website. It is Your obligation to periodically check the provisions of this Privacy Notice for any such changes, updates, additions, removals or amendments. Your continued use of this website following any changes, updates, additions, removals or amendments to this Privacy Policy will be considered notice of your acceptance to abide by and be bound by this Privacy Policy, as amended

2.15. Your rights in relation to the processing of personal information

As a data subject, you have the right to –

  • access and correct any personal information held by Geddes about you (this can be done by following the process for making such request as detailed in Geddes’ PAIA Manual).
  • request that we consider your objections to the processing of your personal information (please complete Annexure A);
  • lodge a complaint with the Information Regulator (please complete Annexure A).

2.16. The Information Regulator

In the event that your personal information has not been processed in accordance with POPIA es set out above, you have the right to lodge a complaint with the Information Regulator.

For further information regarding the complaints process, please visit the website of the Information Regulator, as indicated below.

Alternatively, you may contact the Information Regulator for further assistance:

The Information Regulator: Adv Pansy Tlakula
Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Email: complaints.IR@justice.gov.za
Website: https://www.justice.gov.za/inforeg/index.html

Email Disclaimer

The following terms shall apply to this e-mail communication, attachments and all subsequent e-mail communications and attachments, collectively referred to as the electronic message, Geddes Capital (Pty) Ltd, Geddes Capital Amethyst (RF) (Pty) Ltd or any of its subsidiaries or other affiliated entities (“Geddes”) may send to you, the receiver.

This e-mail disclaimer (as may be updated form time to time) shall at all times take precedence over any other e-mail disclaimer(s).

1. Confidentiality: This electronic message is confidential, may contain privileged or copyright information and is only intended for the use of the recipient named above. You may not present this electronic message to another party without consent from the sender/Geddes. Should you receive this electronic message in error, please forward it to the sender by replying to this email and delete from all locations on your computer, and you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.

2. Viruses: Neither the sender nor Geddes certifies that this electronic message is free of viruses or defects.

3. Advice: Any views or opinions presented in this electronic message are solely those of the author and do not necessarily represent those of the Geddes. Any actions taken on the basis of this electronic message are at the reader’s own risk.

4. Bank details: Geddes will never advise of a change in banking details via electronic communication. Should you receive an electronic message to this effect, please contact the Geddes Team immediately.

5. Offer and amendments: This electronic message is not a binding agreement and does not conclude an agreement without the express confirmation by the authorised representatives of Geddes that the communication is intended as an agreement. Unless expressly indicated as such, nothing in this electronic communication constitutes an offer, warranty or representation from Geddes. The sender expressly contracts out of sections 22 – 26 of the Electronic Communications and Transactions Act (25 of 2002) (“ECT Act”), to the extent lawfully possible. No electronic communication including any data message such as an e-mail or SMS, sent or received will give rise to a binding legal transaction. All legal transactions which are to be entered into with Geddes must be concluded in accordance with Geddes’ standard contract policies and procedures. Geddes Capital shall not be liable if any variation is effected to any document or correspondence emailed unless that variation has been approved in writing and signed by an authorised company representative.

6. Electronic Signature: No electronic communication or electronic message from Geddes shall be deemed to be an electronic signature (as defined in the ECT Act), unless expressly stated in the data message from a duly authorised representative of Geddes that the communication is intended as an electronic signature.

7. Other: The sender is expressly required not to make any defamatory statements. Any such communication is contrary to company policy and outside the scope of the employment of the individual concerned. Geddes will not accept any liability in respect of such communication, and the employee responsible will be personally liable for any damages or other liability arising therefrom.

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