Additional Documentation Requirements

Section 4

Documentation requirements for authorised signatories in terms of Anti-Money Laundering legislation

In terms of the Financial Intelligence Centre Act, 2001 ("FICA") Computershare has a duty to identify and verify client details. In addition, Strate Directive SDD requires clients to provide their own bank account details and these details should be verified by the bank.

It is also necessary that in the case of non-individuals or individuals not being able to represent themselves (institutions, minors, physically challenged individuals, etc.), the persons acting on their behalf are properly identified and their authority to do so, properly established.

Therefore, Computershare must have, where applicable, the documentation listed in this section on record before a shareholder can be marked as "verified". Shareholders were informed individually in September 2004 whether they still had to be verified or not, or what the final cut off dates for their verification were.

Once the deadlines for verification were reached, the share accounts of unverified shareholders were frozen for any share transactions, until such time as their details had been verified.

Thereafter, verified shareholders only need to send in the applicable documentation when they instruct Computershare to change any of the verified information items, or when they want to sell their shares and any of the verified information items have changed since verification. Shareholders must then send in certified documentation verifying the information item(s) to be changed, and the instruction must be accompanied by a certified copy of the ID of the person having signed it.

Individuals

• An original certified copy of the shareholder's identity document;

• To verify the shareholder's physical address details, an original certified copy of his service bill e.g. rates account/electricity bill or telephone bill bearing his name and current residential address (or erf/stand number and suburb) dated within the preceding 3 months;

• An original certified copy of a document issued by SARS to verify the shareholder's tax number (where one has been issued). If a tax number has not been issued, this must be confirmed in writing;

• An original bank statement of the shareholder, printed on authentic bank stationery or an original certified copy of the shareholder's bank statement (not an internet bank statement or cancelled cheque) dated within the preceding 3 months, to verify the bank account details. Alternatively, Computershare will accept a signed and stamped letter from the shareholder's bankers on a letterhead confirming the shareolder's bank account details. Computershare will not accept third party banking details or credit card accounts.

Deceased Shareholder

• An original certified copy/copies of the executor/s identity document/s;
• An original certified copy of the Letters of Executorship or Letters of Authority;
• An original certified copy of the Death Certificate;
• An instruction on the executor's letterhead advising of the death of the shareholder and requesting that Computershare update their records accordingly. If the estate is not being administered by an attorney or an institution, then Computershare will require a service bill reflecting the residential address (or erf/stand number and suburb) dated within the preceeding 3 months, in order to verify the physical address of the executor/executrix;

• An original bank statement of the estate, printed on authentic bank stationery or an original certified copy of the estate's bank statement (not an internet bank statement or cancelled cheque) dated within the preceding 3 months, to verify the estate's bank account details. Alternatively, Computershare will accept a signed and stamped letter from the estate's bankers on a letterhead confirming the estate's bank account details. The bank account must be in the name of the estate.

Shareholders under curatorship/liquidation

• Any forms or instructions must be signed by the administrator appointed by the Master of the High Court;

• An original certified copy of the Letter of Appointment;

• An original certified copy of the administrator's identity document;

• An original certified copy of the shareholder's identity document;

• Where the administrator is an attorney or an institution, the administrator's letterhead in order to verify their physical address. Alternatively, if the administrator is an individual then Computershare will require an original certified copy of a service bill reflecting the administrator's residential address (or erf/stand number and suburb) dated within the preceding 3 months to verify his address;

• An original bank statement, printed on authentic bank stationery or an original certified copy of the bank statement to verify the bank account details concerned. Alternatively, Computershare will accept a signed and stamped letter from the bankers on a letterhead confirming the shareholder's bank account details concerned.

Minors

•  If the shares are registered in the name of a minor, Computershare requires written confirmation from the natural guardian, stating the capacity in which he is signing or in the case of a legal guardian attach a certified copy of the Letters of Guardianship;

• An original certified copy of the birth certificate of the minor;

• An original certified copy of the identity document of the guardian;

• An original certified copy of the guardian's service bill e.g. rates account/electricity bill or telephone bill bearing the guardian's name and current residential address (or erf/stand number and suburb) dated within the preceding 3 months in order to verify the physical address details;

• An original bank statement of the minor, printed on authentic bank stationery or an original certified copy of the minor's bank statement (not an internet statement or cancelled cheque) dated within the preceding 3 months, to verify the minor's bank account details. Alternatively, Computershare will accept a signed and stamped letter from the minor's bankers on a letterhead confirming the bank account details. The bank account must be in the name of the minor.

Power of Attorney

• An original certified copy of the Power of Attorney;
• An original certified copy of the identity document of the registered shareholder;
• An original certified copy of the agent's identity document;
• An original certified copy of a service bill e.g. rates account/ electricity bill or telephone bill bearing the shareholder's name and current residential address (or erf/stand number and suburb) dated within the preceding 3 months in order to verify the physical address details;
• Where the agent is an attorney or an institution, the agent's letterhead in order to verify his physical address. Alternatively, Computershare will require a service bill reflecting the agent's name and residential address (or erf/stand number and suburb) dated within the preceding 3 months;
• An original certified copy of a document issued by SARS to verify the registered shareholder's tax number (where one has been issued). If a tax number has not been issued, this must be confirmed in writing;

• An original bank statement of the shareholder, printed on authentic bank stationery or an original certified copy of the shareholder's bank statement (not an internet bank statement or cancelled cheque) dated within the preceding 3 months, to verify the bank account details. Alternatively, Computershare will accept a signed and stamped letter from the shareholder's bankers on a letterhead confirming the shareholder's bank account details. Computershare will not accept third party banking details.

Unlisted Companies/Close Corporations and other legal entities

• An original certified copy of a board minute/resolution detailing persons authorised to act on behalf of the company/close corporation/legal entity. A principal company officer/member must be appointed to act on behalf of the company/close corporation/ legal entity for share dealing purposes;
• A list of authorised signatories together with specimen signatures on a company letterhead;
• An original certified copy of:
• Companies: the CM1 Certificate of Incorporation, CM22 Certificate of Registered Address and CM29 form bearing the stamp of the Registrar of Companies and signed by the Company Secretary;
• Close Corporations: the CK1/CK2 Founding Statement bearing the stamp of the Registrar and signed by an authorised member;
• Other legal entities: the Constitution or other founding documentation and written confirmation of the residential address of persons authorised to act on behalf of the legal entity;
• Contact particulars for authorised persons (no verification documentation required);
• Original certified copies of the identity documents of the authorised signatories and Chief Executive Officer;
• An original certified copy of a service bill (e.g. rates account/ electricity bill or telephone bill) bearing the business' name and current physical address (or erf/stand number and suburb) dated within the preceding 3 months in order to verify the trade name and physical business address details;
• An original certified copy of a document issued by SARS to verify the business' tax number and VAT number (where one has been issued). If a tax number/VAT number has not been issued, this must be confirmed in writing;
• An original certified copy of the following documentation for any shareholder who holds more than 25% of the voting rights of the investor company:
• Individual: identity document (SA Residents)/passport (Non-Residents);
• Companies and Close Corporations: Certificate of Incorporation (CM1) and Notice of Registered Address (CM22)/CK1) Founding Statement and service bill to verify trade name and physical address of company or close corporation;
• Other legal entity: constitution;
• Contact particulars for any shareholder who holds more than 25% of the voting rights of the company- no verification documentation required;

• An original bank statement of the business, printed on authentic bank stationery or an original certified copy of the business' bank statement dated within the preceding 3 months, to verify the business' bank account details. Alternatively, Computershare will accept a signed and stamped letter from the business' bankers on a letterhead confirming the business' bank account details. Third party banking details will not be accepted.

Unlisted foreign companies

• Same or local equivalent of documentation referred to above for unlisted South African companies. However, Computershare is required to verify the registered name/number/address and trade name/physical address under which the company conducts business in South Africa and in the country of incorporation. If an unlisted company has multiple offices, the physical business address of its head office and the registered shareholder is required;

• Computershare requires written confirmation of the residential address and contact particulars of persons authorised to act on behalf of the company and the Chief Executive Officer - no verification documentation required.

Listed foreign and South African companies

• A listed company is defined as a limited company whose shares are quoted on a "recognized stock exchange" (refer to Computershare's website for a list of recognized stock exchanges). Computershare is exempted from verifying certain information for public listed companies. This also applies to wholly-owned subsidiaries of the listed companies;

• Computershare requires written confirmation of the registered name, registration number and physical address (no verification documentation required). If the listed company has multiple offices, the physical business address of the head office and the registered investor company is required;

• An original print-out from the Stock Exchange's website or extract from the JSE Handbook confirming listing;

• An original certified copy of the group structure in the annual financial statements or print-out from stock exchange website to prove the link between the listed company and subsidiary for wholly-owned subsidiaries (where applicable);

• An original certified copy of a board minute/resolution detailing persons authorised to act on behalf of the company. A principal company officer must be appointed for share dealing purposes;

• Original certified copies of identity documents/passports for the authorised signatories/persons of foreign listed companies;

• An original bank statement of the business, printed on authentic bank stationery or an original certified copy of the business' bank statement, to verify the business' bank account details. Alternatively, Computershare will accept a signed and stamped letter from the business' bankers on a letterhead confirming the business' bank account details. Third party banking details will not be accepted.

Trusts

Although Sanlam shares may be held in trust, it may not be registered as such in Sanlam's share register. Such shares must be registered in the name of the principal trustee (natural persons, or juristic persons such as a company) who hold the shares in trust, but without noting the fact that they hold the shares in trust.

Trusts still holding Sanlam shares in their own name have to supply the information requested below. However, they will be contacted by Sanlam in the near future regarding the transfer of these shares into the name of a principal trustee of the trust.

Inter Vivos Trusts

(Note: Only registered trusts will be accepted)

• Any form or instruction must be signed or given by the authorised principal trustee;

• An original certified copy of the trustee resolution/power of attorney signed by all the trustees authorising the principal trustee to act on behalf of the trust;

• A list of persons/trustees who are authorised to act on behalf of the trust together with specimen signatures;

• An original certified copy of the Letters of Authority issued by the Master of the High Court and the Trust Deed;

• Original certified copies of the identity documents for all the trustees; the founder of the trust and the beneficiaries of the trust;

• Written confirmation or a service bill e.g. rates account/electricity bill or telephone bill in order to verify the residential address of the:

• authorised trustees;

• the founder of the trust; and

• the beneficiaries of the trust;

• Contact particulars for the trustees, founder of the trust and beneficiaries of the trust - no verification documentation required;

• An original certified copy of a document issued by SARS to verify the Trust's tax number (where one has been issued). If a tax number has not been issued, please confirm this in writing;

• An original bank statement of the trust, printed on authentic bank stationery or an original certified copy of the trust's bank statement dated within the preceding 3 months, to verify the trust's bank account details. Alternatively, Computershare will accept a signed and stamped letter from the trust's bankers on a letterhead confirming the trust's bank account details. Please note that the bank account must be in the name of the trust.

Testamentary Trusts

(Note: Only registered trusts will be accepted)

Testamentary Trusts are exempt in terms of the FICA Requirements. Computershare will, however, require confirmation of the authorised trustees and proof of their authority to act on behalf of the trust in terms of Strate Directive SDD.

• Any form or instruction must be signed or given by the authorised principal trustee;

• An original certified copy of the trustee resolution/power of attorney signed by all the trustees authorising the principal trustee to act on behalf of the trust;

• A list of persons/trustees who are authorised to act on behalf of the trust together with specimen signatures;

• An original certified copy of the Letters of Authority issued by the Master of the High Court and the Trust Deed;

• Original certified copies of the identity documents for all the trustees;

• An original bank statement of the trust printed on authentic bank stationery or an original certified copy of the trust's bank statement dated within the preceding 3 months, to verify the trust's bank account details. Alternatively, Computershare will accept a signed and stamped letter from the trust's bankers on a letterhead confirming the trust's bank account detials. Please note that the bank account must be in the name of the trust.

Note: Please note that Computershare requires sight of the original or an original certified copy of the documentation detailed above. Facsimile copies or photocopies will not be accepted.