1. Introduction and how to read this document

1.1 These Payment Terms explain how money moves when you buy or sell on the Platform: how you pay, where your money sits while an Order is being fulfilled, when it is released, what it costs, and what happens when something goes wrong.

1.2 We have written these Payment Terms in plain language, as section 22 of the Consumer Protection Act 68 of 2008 requires. Where a clause is important, or where it limits our liability, places a risk on you, or allows us to hold or recover money, we have marked it in bold. Please read those clauses carefully.

1.3 Three things matter more than anything else in this document:

1.3.1 We are an intermediary. Your contract of sale is with the Vendor, not with us. Clause 6 of the Terms & Conditions explains this in full.

1.3.2 We do not hold your money. The Escrow Provider does. Clause 5 of this document explains exactly whose money it is at each stage.

1.3.3 If you pay outside the Platform, you have no escrow, no Acceptance Window and no Dispute process. Clause 4.5 explains this.

1.4 These Payment Terms form part of the Platform Terms and are incorporated into the Terms & Conditions by reference. They must be read with the Terms & Conditions, the Shipping Policy, the Returns & Refunds Policy, the Marketplace Rules and — if you are a Vendor — the Vendor Agreement.

1.5 This document supersedes all earlier payment terms published by us.

2. Definitions

2.1 In these Payment Terms, unless the context requires otherwise:

2.1.1 "Platform" means the List Secure website at listsecure.co.za, its subdomains, mobile applications and related services.

2.1.2 "User" means any person who accesses or uses the Platform.

2.1.3 "Buyer" means a User who purchases or offers to purchase an Item through the Platform.

2.1.4 "Vendor" means a User approved by List Secure to list Items for sale on the Platform.

2.1.5 "Item" means any product or goods listed for sale on the Platform.

2.1.6 "Listing" means a Vendor's offer of an Item, including all text, images and specifications.

2.1.7 "Order" means a Buyer's accepted offer to purchase an Item.

2.1.8 "Escrow Provider" means TradeSafe, or such other escrow provider as List Secure may appoint.

2.1.9 "Escrow Account" means the trust/escrow account in which Order funds are held.

2.1.10 "Payment Provider" means PayFast, or such other payment service provider as we may appoint.

2.1.11 "Purchase Price" means the price of the Item excluding Delivery Charges.

2.1.12 "Delivery Charges" means the charge for delivery of the Item, as calculated and displayed on the checkout page before you pay.

2.1.13 "Order Total" means the Purchase Price plus Delivery Charges plus any applicable fees and VAT.

2.1.14 "Commission" means the fee payable by the Vendor to List Secure on each completed Order.

2.1.15 "Acceptance Window" means the period after delivery within which a Buyer must confirm acceptance or lodge a Dispute, failing which acceptance is deemed.

2.1.16 "Dispute" means a Buyer/Vendor disagreement lodged through the Platform before the Acceptance Window closes.

2.1.17 "Business Day" means any day other than a Saturday, Sunday or South African public holiday.

2.1.18 "Personal Information" has the meaning given to it in the Protection of Personal Information Act 4 of 2013 ("POPIA").

2.1.19 "Content" means any material a User uploads, posts or transmits through the Platform.

2.1.20 "Platform Terms" means the Terms & Conditions, the Privacy Policy, the Cookies Policy, the Shipping Policy, the Returns & Refunds Policy, these Payment Terms, the Marketplace Rules and the Vendor Agreement, read together.

2.2 Words in the singular include the plural and the other way round. A reference to a statute is a reference to that statute as amended or replaced from time to time. Headings are for convenience only and do not affect interpretation.

3. Scope — who these Payment Terms bind, and how they fit with the other documents

3.1 These Payment Terms bind every Buyer and every Vendor who transacts on the Platform, and they bind you from the moment you place an Order, list an Item for sale, or receive a payout.

3.2 What this document covers: payment methods, the escrow mechanism, deemed acceptance, fees and charges, Vendor payouts and payout holds, VAT and tax, chargebacks, failed and erroneous payments, refunds, fraud and financial-crime controls, and the complaint routes available to you on a payment matter.

3.3 What this document does not cover:

3.3.1 delivery, dispatch timeframes, tracking, risk in transit and delivery claims — those are in the Shipping Policy;

3.3.2 your right to return an Item and the grounds on which a refund is granted — those are in the Returns & Refunds Policy;

3.3.3 the Commission rate, Vendor performance standards, Vendor termination and the full payout arrangement between us and a Vendor — those are in the Vendor Agreement;

3.3.4 how we process your Personal Information, including your payment and verification data — that is in the Privacy Policy.

3.4 Order of precedence. Clause 5.3 of the Terms & Conditions governs. In short: on a matter specific to a Vendor's relationship with us as a Vendor, the Vendor Agreement prevails; on the processing of Personal Information, the Privacy Policy prevails; on all other matters the Terms & Conditions prevail; and no document in the Platform Terms may be read to remove or reduce a right that the Consumer Protection Act 68 of 2008, the Electronic Communications and Transactions Act 25 of 2002 ("ECTA") or POPIA gives you and that cannot lawfully be removed or reduced.

3.5 Third-party terms are not part of the Platform Terms. The terms of the Escrow Provider and the Payment Provider apply to you separately and in addition. Clause 5.7 deals with this.

4. How you pay

4.1 Payment methods

4.1.1 All payments for Orders are made through the Payment Provider, PayFast, at checkout on the Platform.

4.1.2 The payment methods enabled on the Platform are: [INSERT: the actual methods enabled — card (Visa, Mastercard), Instant EFT, SnapScan, Zapper, Capitec Pay, Mobicred, and any others]. The methods available to you are shown on the checkout page. We may add or remove a method at any time.

4.1.3 Card payments are processed by the Payment Provider under the PCI-DSS standard. We do not store your full card number, expiry date or CVV. The Privacy Policy explains what payment data we do hold and for how long.

4.1.4 You must only use a payment method that you are lawfully entitled to use. Using someone else's card or bank account without authority is fraud and may be an offence under the Cybercrimes Act 19 of 2020.

4.2 Currency

4.2.1 All prices, fees and payments on the Platform are in South African Rand (ZAR). Prices are displayed in Rand and payment is taken in Rand.

4.2.2 If you pay with a card issued outside South Africa, your issuer may apply a currency conversion and may charge you a cross-border or conversion fee. Those charges are yours to pay and are outside our control. We do not receive them and we cannot refund them.

4.3 What we do not accept

4.3.1 We do not accept cash. No Order may be paid for in cash, including at a collection.

4.3.2 We do not accept off-platform electronic funds transfers. You must never transfer money directly into a Vendor's bank account.

4.3.3 We do not accept cryptocurrency or any digital asset, and we do not price Items in any currency other than Rand.

4.3.4 We do not accept payment by cheque, money order, voucher issued by a third party, or any store of value not enabled at checkout, unless we say so on the checkout page.

4.4 Payment must succeed before the Order exists

4.4.1 In terms of clause 8.2 of the Terms & Conditions, the contract of sale between you and the Vendor comes into existence at the moment the Escrow Provider confirms receipt of cleared funds for the Order Total into the Escrow Account, and we notify you and the Vendor that the Order has been created.

4.4.2 Adding an Item to a cart, starting checkout, or receiving an automated acknowledgement that a payment is being processed does not create an Order and does not reserve the Item.

4.4.3 An Item may be sold to another Buyer while your payment is still being processed. If that happens, the payment is reversed to you in full.

4.5 Paying outside the Platform — read this

If you pay for an Item in any way other than through the Platform, you lose every protection this document describes.

4.5.1 In plain terms, if you pay a Vendor in cash, by EFT into their bank account, by an instant-money or wallet transfer, by voucher, in cryptocurrency, or in any other way that does not run through checkout on the Platform:

(a) there is no escrow. Your money goes straight to the Vendor and we cannot recall it;

(b) there is no Acceptance Window. Nothing is held back while you inspect the Item;

(c) there is no Dispute process. We cannot review the evidence, we cannot issue a determination, and there is no money for the Escrow Provider to pay back to you;

(d) there is no refund route. We cannot refund money we never received and never held;

(e) your only remedy is against the Vendor personally, in court or through a police report, and in practice that is slow, expensive and often fruitless.

4.5.2 A Vendor who asks you to pay off the Platform is breaking the Marketplace Rules and, very often, is attempting to defraud you. Report it immediately to support@listsecure.co.za. Do not pay.

4.5.3 We will never ask you to make a payment outside the Platform, and we will never send you banking details by email or message. If you receive a message that appears to come from us asking you to pay into an account, it is not from us. Report it.

4.5.4 A Vendor who solicits or accepts off-platform payment commits a material breach of the Vendor Agreement and the Marketplace Rules, and we may suspend or permanently remove that Vendor and recover our losses.

5. The escrow mechanism — how your money is held

This clause explains, honestly and step by step, where your money is at every point in an Order, whose money it is, and who carries the risk.

5.1 The basic position

5.1.1 List Secure does not hold client funds. Order funds are received and held by the Escrow Provider, TradeSafe, in an escrow trust account, separately from our own money. We do not have free use of those funds and we cannot take money out of the Escrow Account for our own purposes.

5.1.2 [CONFIRM: that List Secure at no point receives or holds Buyer funds in its own bank account, including Commission, and that Commission is paid out to List Secure by the Escrow Provider on settlement. If Commission or any fee in fact passes through a List Secure bank account, clauses 5.1.1 and 5.2 must be redrafted, and the statement "we do not hold client funds" must be removed from every document in the pack.]

5.1.3 The Payment Provider processes the payment. The Escrow Provider holds the funds. We operate the Platform, run the Acceptance Window and the Dispute process, and instruct the Escrow Provider on the outcome. Those are three different roles and three different parties.

5.2 The escrow flow, step by step

Stage 1 — You place the Order and pay the Order Total. You pay the full Order Total (Purchase Price plus Delivery Charges plus any applicable fees and VAT) at checkout, through the Payment Provider. Whose money it is: still yours. Who bears the risk: the payment is in transit through the Payment Provider and is governed by the Payment Provider's terms. If the payment fails or is declined, no Order comes into existence and nothing is owed.

Stage 2 — The funds are received into the Escrow Account. The Payment Provider settles the funds to the Escrow Provider, which receives and holds them in its escrow trust account. Whose money it is: held in trust by the Escrow Provider, subject to the Escrow Provider's terms. It is not our money and it is not yet the Vendor's money. Neither you nor the Vendor may deal with it freely. Your entitlement to have it returned, and the Vendor's entitlement to be paid, are both conditional on what happens next. Who bears the risk: the funds sit with the Escrow Provider. Clause 5.7 sets out the limits of what we can say about that.

Stage 3 — The Order is created and the Vendor is notified to dispatch. We confirm the Order to you and to the Vendor. This is the moment the contract of sale between you and the Vendor comes into existence (clause 8.2 of the Terms & Conditions). The Vendor is instructed to dispatch within the dispatch window set out in the Shipping Policy. Whose money it is: unchanged — held by the Escrow Provider.

Stage 4 — The Vendor dispatches and loads the tracking details. The Vendor packs and hands the Item to the courier, or makes it available for collection, and loads the waybill or tracking number to the Platform. Who bears the risk in the Item: the Vendor. The Item remains at the Vendor's risk while it is in transit. The Shipping Policy explains this and explains how section 19(2)(c) of the Consumer Protection Act applies where the Vendor is a business seller. Whose money it is: unchanged — held by the Escrow Provider. Dispatch does not release any money.

Stage 5 — Delivery is confirmed. Delivery is recorded by the courier and reflected on the Platform, or you confirm collection. Who bears the risk in the Item: risk passes to you on delivery. Whose money it is: unchanged — still held by the Escrow Provider. Delivery does not release the money either.

Stage 6 — The Acceptance Window runs. You now have the Acceptance Window, being [INSERT: Acceptance Window — number of days after delivery], to inspect the Item and either confirm acceptance or lodge a Dispute in the Platform. Whose money it is: unchanged — held by the Escrow Provider. This is the whole point of escrow: the money is still recoverable while you check the Item.

Stage 7A — You confirm acceptance, or the Acceptance Window closes without a Dispute. If you confirm acceptance, or if you do nothing and the Acceptance Window closes, acceptance is confirmed or deemed (clause 6).

Stage 7B — You lodge a Dispute before the Acceptance Window closes. The five-step Dispute path in clause 12 runs. While a Dispute is open, the funds for that Order stay in escrow. No money is released to anyone until the Dispute is determined.

Stage 8 — Release. On acceptance or deemed acceptance, the Escrow Provider releases the Purchase Price and the Delivery Charges, less the Commission and the fees set out in clause 7, to the Vendor, and pays the Commission and our fees to us. Whose money it is: from the moment of release, the released amount is the Vendor's money and the Commission and fees are ours. Where a Dispute was determined, the Escrow Provider gives effect to the determination instead, which may mean a full refund to you, a partial refund, or a release to the Vendor.

Stage 9 — Payout to the Vendor's bank account. The Escrow Provider pays the released amount to the Vendor's verified bank account on the payout schedule in clause 8, subject to any hold under clause 9.

5.3 What escrow does and does not do

5.3.1 What escrow does. It keeps your money out of the Vendor's hands until the Item has been delivered and you have had the Acceptance Window to inspect it. If the Item never arrives, or arrives and is not what was described, the money is still there to be returned to you.

5.3.2 What escrow does not do. It is not insurance. It is not a guarantee that the Vendor will perform. It does not protect an Order for which you paid off the Platform. It does not survive the closing of the Acceptance Window — after that, the money has gone to the Vendor and any further claim is one you must pursue against the Vendor, although we will still assist where we can.

5.3.3 Escrow is a contractual protection we arrange for you. It is not a statutory right and it does not replace one. Your rights under the Consumer Protection Act and ECTA are set out in the Returns & Refunds Policy and in clause 13 of the Terms & Conditions, and they continue to apply.

5.4 Vendors: you must not release the Item before escrow confirms

5.4.1 A Vendor must not dispatch or hand over an Item until the Platform shows that the funds for the Order have been received into the Escrow Account.

5.4.2 A Vendor who hands over an Item on the strength of a payment notification received by email, SMS or WhatsApp, rather than the Platform's own confirmation, does so at its own risk. Fake proof-of-payment messages are one of the most common frauds on marketplaces in South Africa. Check the Platform.

5.5 Multi-Item Orders and part deliveries

5.5.1 Where one Order contains Items from more than one Vendor, each Vendor's portion is treated as a separate transaction for escrow, delivery, the Acceptance Window and Disputes.

5.5.2 Where an Order from a single Vendor is delivered in parts, the Acceptance Window for each part runs from the delivery of that part, unless the Items were sold as a set that is of no use incomplete, in which case the Acceptance Window runs from delivery of the last part.

5.6 Interest on funds held in escrow

5.6.1 [CONFIRM: whether interest accrues on funds held in the Escrow Account, and if so who is entitled to it — the Buyer, the Vendor, the Escrow Provider or List Secure. This must match the Escrow Provider's own terms and must be disclosed to Users. Do not publish this document until the answer is inserted.]

5.7 The Escrow Provider's and the Payment Provider's own terms

5.7.1 The Escrow Provider holds and releases the funds subject to its own terms and conditions. The Payment Provider processes the payment subject to its own terms and conditions.

5.7.2 By transacting on the Platform you agree that you are bound by the terms of the Escrow Provider and the Payment Provider, in addition to the Platform Terms. Links to those terms are on the checkout page. If you do not accept them, you must not transact.

5.7.3 Where a determination we issue under clause 12 conflicts with what the Escrow Provider's terms permit it to do, the Escrow Provider's terms govern what actually happens to the money. We will tell you if that occurs and will assist you in taking the matter up with the Escrow Provider.

5.7.4 We give no warranty of any kind in respect of the Escrow Provider or the Payment Provider. In particular, and subject to clause 14.1, we do not warrant, guarantee or accept responsibility for:

(a) the solvency, financial standing or continued existence of the Escrow Provider or the Payment Provider;

(b) the security, integrity or availability of their systems;

(c) their performance of their own obligations to you, including the timing of a release or a payout; or

(d) any loss you suffer as a result of their act, omission, failure, outage, error, insolvency, business rescue or liquidation, except to the extent that we caused it.

5.7.5 Where such a failure occurs, we will do what we reasonably can to assist you in dealing with that provider, including giving you the transaction records and evidence we hold.

5.7.6 We may replace the Escrow Provider or the Payment Provider. We will give Users notice of a change before it takes effect and will not change the provider for an Order already placed.

6. The Acceptance Window and deemed acceptance

6.1 After the Item is delivered, you have the Acceptance Window, being [INSERT: Acceptance Window — number of days after delivery], to inspect the Item and either confirm acceptance or lodge a Dispute in the Platform.

6.2 If you do not confirm acceptance and do not lodge a Dispute before the Acceptance Window closes, you are deemed to have accepted the Item and the funds will be released from escrow to the Vendor. This is what happens if you do nothing at all.

6.3 In practical terms, deemed acceptance means:

6.3.1 the money leaves the Escrow Account and is paid to the Vendor, less Commission and fees;

6.3.2 there is no longer any money held back for that Order, so we can no longer refund you from escrow; and

6.3.3 the Dispute process in clause 12 is closed for that Order.

6.4 Deemed acceptance does not take away your statutory rights. In particular:

6.4.1 it does not remove the six-month implied warranty in section 56 of the Consumer Protection Act, where that section applies;

6.4.2 it does not remove your seven-day cooling-off right under section 44 of ECTA, if you are still within the seven days; and

6.4.3 it does not remove any other right you have under the Consumer Protection Act, ECTA or the common law.

6.5 What deemed acceptance does mean is that the escrow protection for that Order has ended, and that any further claim is one you must pursue against the Vendor directly. We will still assist where we can, and the Returns & Refunds Policy explains the routes that remain open to you.

6.6 Inspect the Item as soon as it arrives. Open it, test it, check the serial or IMEI number, check that all the parts and accessories described in the Listing are there, and take photographs before you use it. Keep the packaging until the Acceptance Window has closed.

6.7 We will send you a reminder before the Acceptance Window closes, to the email address on your account and by notification in the Platform. [CONFIRM: the number and timing of Acceptance Window reminders sent to Buyers, and that the reminder is in fact built and sent. Deemed acceptance is much harder to defend if the Buyer was never reminded.] It remains your responsibility to keep your email address current and to check your account.

7. Fees and charges

7.1 The principle

7.1.1 You will never be charged a fee that was not shown to you before you paid. Every amount payable by a Buyer is itemised on the checkout page before payment. Every amount payable by a Vendor is set out in the Vendor Agreement and is itemised on the Vendor's statement.

7.1.2 Buyers pay the Order Total. Vendor fees are not payable by Buyers and are not added to the Order Total shown to a Buyer.

7.2 The fee schedule

7.2.1 The following table sets out every fee that may be charged in connection with an Order. A fee not listed here is not charged.

7.3 A warning about fees charged for using the Dispute process

7.3.1 [CONFIRM with attorney: whether a Dispute Administration Fee may lawfully be charged to a Buyer at all. A fee that a consumer must pay in order to exercise a complaint or return right risks being an unfair, unreasonable or unjust contract term for the purposes of sections 48 and 51 of the Consumer Protection Act, and may deter a consumer from exercising a statutory right. The safer position, and the one we recommend, is that no fee is charged to a Buyer for lodging a Dispute, and that any administration fee is charged only to a party found to have acted dishonestly or abusively.]

7.4 Whether fees are refunded when an Order is cancelled or refunded

7.4.1 The general rule we apply: where an Order is cancelled or refunded for a reason that is not the Buyer's fault — non-delivery, late delivery, the Item not being as described, the Item being faulty or counterfeit, the Item being out of stock, a pricing error, or a cancellation by the Vendor — the Buyer is refunded the full Order Total, including all Delivery Charges and all Buyer-side fees. The Buyer is not left out of pocket.

7.4.2 Where an Order is cancelled or refunded at the Buyer's election and not because of any failure by the Vendor — for example, a cancellation under section 44 of ECTA or a change of mind that a Vendor agrees to accept — the position is as follows:

(a) the Purchase Price is refunded in full;

(b) the direct cost of returning the goods is borne by the Buyer, as section 44(2) of ECTA provides; and

(c) [CONFIRM: whether the outbound Delivery Charges and any Buyer Service Fee are refunded on a section 44 cancellation. Section 44(2) of ECTA provides that the only charge that may be levied on the consumer is the direct cost of returning the goods. An attorney must confirm whether retaining the outbound Delivery Charges or a Buyer Service Fee is consistent with that section. If it is not, both must be refunded in full.]

7.4.3 Vendor-side fees. Where an Order is cancelled before dispatch or refunded in full, no Commission is payable and any Commission already deducted is credited back to the Vendor, as clause 14.4.3 of the Vendor Agreement provides. Where an Order is partially refunded, Commission is recalculated on the reduced Purchase Price and the difference is credited back, as clause 14.4.4 of that agreement provides. [CONFIRM: whether the Escrow Fee, the Payment Gateway Fee and any other third-party cost are also reversed on a full refund, or whether those costs are borne by the Vendor. The answer must be the same here and in clause 14.4.3 of the Vendor Agreement.]

7.4.4 Third-party fees we do not control. The Escrow Fee and the Payment Gateway Fee are charged by the Escrow Provider and the Payment Provider under their own terms. Where those providers do not refund their fee on a reversed transaction, we cannot make them do so. [CONFIRM: who bears an unrefunded Escrow Fee or Payment Gateway Fee on a cancelled Order — the Buyer, the Vendor or List Secure. Our recommendation is that it is never borne by a Buyer whose Order failed through no fault of their own.]

7.4.5 The Returns & Refunds Policy contains a decision table setting out, scenario by scenario, exactly what is refunded and who pays return shipping. That table and this clause must be read together and must always say the same thing.

7.5 Changes to fees

7.5.1 We may change our fees. We will give you at least [INSERT: number of days' notice of a fee change] notice before a change takes effect.

7.5.2 A change to a fee does not apply to an Order already placed.

7.5.3 If you do not accept a fee change, your remedy is to stop using the Platform and, if you are a Vendor, to close your Vendor account in accordance with the Vendor Agreement.

7.6 Bank charges

7.6.1 Bank charges, currency conversion costs and charges imposed by your own bank or card issuer are yours to pay. We do not receive them and cannot refund them.

8. Vendor payouts

8.1 Bank account verification

8.1.1 Before we can release a payout to you, you must give us a South African bank account in the name of the registered account holder — that is, in the Vendor's own name, or in the name of the registered entity where the Vendor is a company, close corporation, trust or partnership.

8.1.2 We do not pay out to a third party's bank account. We will not pay to an account in the name of a spouse, a friend, an employee or another business, whatever the reason given. This is a fraud control and it is not negotiable.

8.1.3 You must complete bank account verification, which may include an account-holder verification check, proof of bank account not older than three months, and identity verification through Verify ID. Clause 7.2 of the Terms & Conditions and the Privacy Policy explain the verification process and how the data is handled.

8.1.4 If you change your bank account details, the change is subject to re-verification and we may hold payouts until the new account is verified. Bank-detail change requests are a common fraud vector and we treat them accordingly. We may contact you on a previously verified telephone number to confirm the change.

8.2 Payout schedule

8.2.1 Once an Order is accepted or deemed accepted, the Escrow Provider releases the funds and the payout is made to your verified bank account [INSERT: payout schedule — for example, within a stated number of Business Days of release, or on a stated weekly or twice-monthly cycle, with the cut-off time].

8.2.2 Minimum payout threshold: [INSERT: minimum payout threshold, or state "none"]. Where a threshold applies, amounts below it are carried forward and paid with the next payout that reaches the threshold. [CONFIRM: how a below-threshold balance is dealt with when a Vendor closes its account — our recommendation is that it is paid out in full on closure regardless of the threshold.]

8.2.3 Payout timing also depends on the Escrow Provider, the receiving bank and the interbank clearing system. Bank clearing times are outside our control and we do not guarantee that funds will reflect in your account on a particular day.

8.2.4 Payouts are made on Business Days only. Public holidays, weekends and bank system outages will delay a payout.

8.3 Your payout statement

8.3.1 For each payout you will be able to see, in your Vendor account: the Orders included; the Purchase Price and Delivery Charges for each; each fee deducted, by name, using the fee names in clause 7.2; VAT on our fees; any set-off or recovery applied under clause 9.5; and the net amount paid.

8.3.2 If you think a payout is wrong, tell us within [INSERT: number] Business Days of the payout date and we will investigate.

9. Payout holds, reserves and set-off

9.1 When we may hold a payout

9.1.1 We may hold, delay or withhold all or part of a payout, and may instruct the Escrow Provider not to release funds, where:

(a) you are a new Vendor within your probation period — [INSERT: new Vendor probation period, and the payout arrangement that applies during it];

(b) a Dispute is open on the Order, or on another Order with the same Vendor where the same issue arises;

(c) a chargeback, payment reversal or fraud alert has been received in respect of the Order or your account;

(d) we reasonably suspect fraud, misrepresentation, item switching, stolen goods, counterfeit goods or money laundering;

(e) a return is unresolved, including where an Item has been returned to you and you have not confirmed receipt or refunded the Buyer;

(f) your verification or KYC information has lapsed, expired or failed re-verification, or you have not responded to a request for information;

(g) you owe us or a Buyer an amount that is due and unpaid, including a refund we have funded, a chargeback, a fee or a penalty;

(h) we are required to do so by law, by a court, by a regulator or by the South African Police Service; or

(i) your account is suspended or terminated under clause 18 of the Terms & Conditions.

9.1.2 A hold is a temporary measure to protect Buyers and to allow an investigation. It is not a forfeiture and it is not a penalty.

9.1.3 We will not hold funds indefinitely. At the end of an investigation we will release the funds to the person entitled to them, or pay them over as required by law. Where an account is terminated for fraud, funds and payouts may be held for [INSERT: number of days funds may be held pending investigation of suspected fraud] while we investigate, as clause 18.4.2 of the Terms & Conditions provides.

9.1.4 We will tell you that a hold has been placed, and why, unless the law prevents us from doing so (see clause 13.6 on tipping-off).

9.2 Reserves

9.2.1 A Reserve is an amount retained from a Vendor's payouts, or held back in the Escrow Account, as security for refunds, chargebacks, Disputes, penalties and other amounts the Vendor may owe. Clause 15.6 of the Vendor Agreement governs Reserves in full, including review and release.

9.2.2 [INSERT: the Reserve mechanism and the maximum Reserve percentage or amount, and the rolling period — this must be identical in this clause and in clause 15.6.2 of the Vendor Agreement] A Reserve that is not disclosed to a Vendor before it is approved to sell is not enforceable.

9.2.3 [CONFIRM: where a Reserve is held — in the Escrow Account with the Escrow Provider, or in a List Secure bank account. If List Secure holds Vendor money itself, that is a materially different arrangement from the "we do not hold client funds" position taken in clause 5.1.1 of this document and clause 9.3 of the Terms & Conditions, and all three documents must be reconciled before publication.]

9.2.4 Money held in a Reserve remains the Vendor's money, subject to our rights of set-off under clause 9.5.

9.2.5 Where a Reserve applies, it will be shown on your payout statement as a separate line, and the amount and release date of each tranche will be visible in your Vendor account.

9.3 Your right to query a hold, and to appeal

9.3.1 You may query any hold, reserve or deduction. Send your query to support@listsecure.co.za, quoting the Order number or payout reference.

9.3.2 We will acknowledge your query within [INSERT: number] Business Days and give you a substantive response within [INSERT: number] Business Days.

9.3.3 If you are not satisfied with the response, you may appeal. Send your appeal to support@listsecure.co.za within [INSERT: appeal window — number of days from the decision], saying what decision you are appealing and why, and attaching any further evidence.

9.3.4 Your appeal will be reviewed by a person, not by an automated system, and by someone who was not responsible for the original decision where that is practical. We will respond within [INSERT: number] Business Days.

9.3.5 Where a decision to hold a payout was made wholly or substantially by automated means, you have a right under section 71 of POPIA to ask for human intervention. The appeal route in this clause gives effect to that right.

9.3.6 Nothing in this clause takes away your right to approach a court, a regulator or an ombud.

9.4 Escalating fraud losses

9.4.1 Where we have released a payout and later establish that the Order was fraudulent, that the Item was stolen or counterfeit, or that the Vendor misrepresented the Item, the amount paid out is repayable to us on demand, and clause 9.5 applies.

9.5 Set-off and recovery

9.5.1 We may set off any amount you owe us against any amount we hold for you or owe to you, including funds held in escrow for other Orders, amounts due on a future payout, and any reserve.

9.5.2 Amounts that may be recovered in this way include: a refund we have funded to a Buyer; a chargeback amount and the associated fees; a Dispute determination in a Buyer's favour that you have not honoured; a fee, penalty or cost due under the Platform Terms; and our reasonable costs of investigation and recovery.

9.5.3 Where there are not enough funds to set off against, the amount owing is a debt due to us and payable on demand. We may hand the debt over for collection and institute legal proceedings, and we may recover our reasonable legal costs.

9.5.4 We will give you an itemised account of any set-off or recovery.

9.5.5 Interest on an overdue amount is charged at [INSERT: interest rate on overdue amounts — for example, the rate prescribed under the Prescribed Rate of Interest Act 55 of 1975].

10. Taxes

10.1 The general position

10.1.1 We do not provide tax advice. Nothing in this document or on the Platform is tax advice. If you are unsure of your tax position, consult a registered tax practitioner or the South African Revenue Service ("SARS").

10.1.2 [INSERT: VAT treatment — whether prices displayed include VAT, whether List Secure is a registered VAT vendor and charges VAT on Commission and on the other fees in the fee table in clause 7.2, and how VAT is handled where the Vendor is not a registered VAT vendor].

10.2 VAT on our Commission and fees

10.2.1 Where List Secure is a registered VAT vendor, VAT at the standard rate is charged on our Commission and on the other fees we charge under the fee table in clause 7.2, in terms of the Value-Added Tax Act 89 of 1991, and we will issue you with a valid tax invoice for those amounts.

10.2.2 Each fee in the table in clause 7.2 states whether the amount shown is VAT-inclusive or VAT-exclusive. Where the table says a fee is VAT-exclusive, VAT is added.

10.3 The Vendor's own tax obligations

10.3.1 You, the Vendor, are responsible for your own tax. That includes:

(a) VAT on your sales. If your taxable supplies exceed the compulsory VAT registration threshold, you must register as a VAT vendor and account for VAT on the Items you sell, in terms of the Value-Added Tax Act 89 of 1991. Registering, charging, declaring and paying that VAT is your obligation, not ours;

(b) income tax on the profit you make, in terms of the Income Tax Act 58 of 1962, whether you trade as an individual, a company, a close corporation or a trust; and

(c) any other tax, duty or levy that applies to what you sell, including customs duty and import VAT on Items you import.

10.3.2 You must give us accurate tax information, including your VAT registration number if you are registered, and you must tell us if it changes.

10.3.3 We do not withhold tax from your payouts and we do not account to SARS for tax on your sales.

10.3.4 We may be required to report transaction information to SARS. [CONFIRM: whether third-party reporting obligations to SARS apply to the Platform, under which provision, and what data must be reported.]

10.4 Who issues the tax invoice to the Buyer

10.4.1 [CONFIRM with attorney and the company's tax advisor: whether List Secure issues tax invoices to Buyers as agent for its VAT-registered Vendors in terms of section 54 of the Value-Added Tax Act 89 of 1991, or whether each Vendor issues its own tax invoice directly to the Buyer.]

10.4.2 The answer determines all of the following, and none of them can be built until it is given:

(a) whose VAT number appears on the invoice the Buyer receives;

(b) whether the Platform must generate a compliant tax invoice containing every particular required by section 20 of the Value-Added Tax Act, including the supplier's name, address and VAT registration number, the recipient's details where the consideration exceeds the prescribed amount, a serial number, the date, a description of the goods, the quantity, and the VAT amount or a statement that VAT is included;

(c) whether an agency agreement in terms of section 54 must be concluded with each VAT-registered Vendor, and whether the Vendor Agreement must contain it;

(d) how invoices are handled for Vendors who are not VAT registered — a non-registered Vendor may not issue a tax invoice or charge VAT, and the Platform must not generate a document that looks like one; and

(e) how credit notes are issued when an Order is refunded in whole or in part.

10.4.3 Until clause 10.4.1 is answered, the Platform must not present any document to a Buyer as a "tax invoice". A document that shows VAT but does not meet section 20 is not a valid tax invoice, and issuing one exposes both the Vendor and us.

10.4.4 Where the Vendor is a private seller and not a VAT vendor, no VAT is charged on the sale of the Item and no tax invoice is issued for it. VAT is still charged on our own Commission and fees where we are a registered VAT vendor.

11. Chargebacks and payment reversals

11.1 What a chargeback is

11.1.1 A chargeback is a reversal of a card payment that you ask your bank or card issuer to make. The issuer takes the money back from the Payment Provider, which takes it back from the Escrow Account or from us, and the matter is then decided under the card scheme's rules — not under ours.

11.1.2 A chargeback is a legitimate protection where a payment was not authorised by you, for example where your card was used fraudulently, or where a seller has genuinely failed to deliver and will not put it right.

11.2 Raise a Dispute with us first

11.2.1 If there is a problem with an Order, you must raise a Dispute in the Platform before you approach your bank.

11.2.2 There is a practical reason for this and it is in your interest. While the money is still in escrow, we can return it to you quickly and without cost. A chargeback is slower, is decided by the card scheme on documents alone, may fail, and may leave you with neither the Item nor the money while it runs.

11.2.3 The escrow protection exists precisely so that a chargeback should not be necessary.

11.2.4 Nothing in this clause takes away your right to raise a genuine chargeback for an unauthorised or fraudulent transaction on your card, or your rights under your agreement with your bank or card issuer. We cannot and do not restrict that right. Clause 11.2.1 is a contractual request about the order in which you use the routes available to you, not a waiver.

11.3 Cooperation

11.3.1 If a chargeback is raised on an Order, both the Buyer and the Vendor must cooperate with us and must give us, promptly and on request: the Order and message history; proof of dispatch and proof of delivery; the waybill and courier tracking record; photographs; the serial or IMEI number; and any correspondence with the bank or card issuer.

11.3.2 A Vendor must respond to a chargeback representment request within [INSERT: number] Business Days. If a Vendor does not respond in time, the chargeback will usually be lost by default and clause 11.4 applies.

11.4 Who bears the loss

11.4.1 Where the chargeback is upheld because the Vendor failed — the Item was not delivered, was not as described, was counterfeit or was faulty — the Vendor bears the loss. We will recover the amount charged back, plus the chargeback fee charged to us by the Payment Provider or the Escrow Provider, plus the Chargeback Administration Fee in clause 7.2, from the Vendor under clause 9.5.

11.4.2 Where the chargeback arises from a fraudulent or unauthorised use of a Buyer's card by a third party, and neither the Buyer nor the Vendor is at fault, the loss falls where the card scheme rules and the Payment Provider's terms place it. [CONFIRM: whether the Payment Provider's merchant agreement places liability for a fraudulent card transaction on List Secure, on the Escrow Provider or on the Vendor, and whether 3D Secure or an equivalent liability shift is enabled on every transaction. If it is not enabled, it should be — this is the single most effective control against card fraud losses.]

11.4.3 Where the chargeback is abusive — the Item was delivered as described, the Buyer had already accepted it, or the Buyer had already been refunded — clause 12.4 of the Marketplace Rules applies. We may recover the amount charged back, the chargeback fee and our reasonable costs of investigation as a debt due to the Buyer, set that amount off against any funds we hold for the Buyer, suspend or permanently remove the account, hand the debt over for collection, and report the conduct as clause 12.4.4 of the Marketplace Rules sets out.

11.4.4 List Secure does not underwrite chargeback losses. Subject to clause 14.1, we are not liable to a Vendor for a chargeback that is upheld against it, or to a Buyer for a chargeback that fails.

11.5 Effect on escrow and payouts

11.5.1 Where a chargeback is raised on an Order for which funds are still in escrow, those funds are frozen until the chargeback is resolved.

11.5.2 Where a chargeback is raised on an Order that has already been paid out, we may hold your other payouts under clause 9.1 up to the amount at risk.

11.6 Repeat chargebacks

11.6.1 A high chargeback rate is a ground for restriction, suspension or termination under clause 18.2 of the Terms & Conditions, for both Buyers and Vendors, and may result in the Payment Provider withdrawing services.

12. Failed, duplicate and erroneous payments, and refunds

12.1 Failed payments

12.1.1 If a payment fails or is declined, no Order is created and the Item is not reserved. You may try again with another payment method.

12.1.2 Where a payment is declined but an amount is reserved or "pended" on your card, that reservation is released by your bank in the ordinary course. The timing is set by your bank and is outside our control.

12.2 Duplicate and erroneous payments

12.2.1 If you are charged twice for the same Order, or are charged an amount that is not the Order Total, tell us immediately at support@listsecure.co.za with the date, the amount and the payment reference.

12.2.2 We will investigate and, where a duplicate or erroneous payment is confirmed, arrange a full refund of the incorrect amount. No fee is charged for this and you do not lose the Order.

12.2.3 If we or the Escrow Provider pay an amount to you in error — for example, a duplicated payout, a refund paid twice, or a payout of funds that should have been held — you must tell us and you must repay it. You are not entitled to keep money paid to you in error. We may recover it under clause 9.5 or as a debt.

12.3 Refunds

12.3.1 Refunds are made to the original payment method only. If you paid by card, the refund goes back to that card. If you paid by Instant EFT, the refund goes back to the bank account the payment came from.

12.3.2 We do not refund to a different card, a different bank account or a third party's account. This is a fraud control. The only exception is where the original payment method is closed, expired or no longer exists, in which case we will arrange an alternative after verifying your identity and your entitlement, and we may require you to give us proof.

12.3.3 We do not pay refunds in cash, in cryptocurrency or by voucher.

12.3.4 Refund timing:

(a) we or the Escrow Provider will initiate a refund within [INSERT: number of Business Days within which a refund is initiated after it is approved] of the refund being approved;

(b) where the funds are still in escrow, the refund is made from escrow;

(c) where the funds have already been released, the refund must come from the Vendor, and we will require the Vendor to make it within [INSERT: number] Business Days;

(d) a card refund typically reflects on your statement within [INSERT: typical card refund clearing period] after it is initiated, and a bank transfer within [INSERT: typical EFT refund clearing period]; and

(e) where section 44(3) of ECTA applies, any payment you made must be refunded within 30 days of the date of cancellation.

12.3.5 Bank and card scheme clearing times are outside our control. The dates in clause 12.3.4(d) are estimates based on ordinary experience, not guarantees. Once a refund has been initiated, the money is in the hands of the Payment Provider, the card scheme and your own bank. If a refund has not reflected within the stated period, contact us and we will give you the refund reference so that you can take it up with your bank.

12.3.6 The Returns & Refunds Policy sets out the grounds on which a refund is granted, what is refunded in each scenario, and who pays return shipping. This clause deals only with the mechanics of paying the money back.

13. Fraud prevention, financial crime and sanctions

13.1 Our approach

13.1.1 We apply risk-based monitoring to transactions and accounts on the Platform, using a combination of automated screening and human review. The purpose is to detect and prevent fraud, money laundering, terrorist financing, the sale of stolen goods and the abuse of the Platform.

13.1.2 We apply controls aligned to the Financial Intelligence Centre Act 38 of 2001 ("the FIC Act"), including risk-based customer due diligence, identity verification through Verify ID, record-keeping, and the reporting of suspicious and unusual activity to the relevant authority.

13.1.3 [CONFIRM with attorney: whether List Secure falls within Schedule 1 of the FIC Act as an accountable institution. We do not assert that it does. If it does, a Risk Management and Compliance Programme, registration with the Financial Intelligence Centre and a full customer due diligence and reporting framework are legally required, and this clause must be rewritten.]

13.1.4 Where you are an accountable institution, you remain responsible for your own obligations under the FIC Act. Nothing we do relieves you of them.

13.2 What we may do

13.2.1 We may, at any time and on a risk-based basis:

(a) delay, hold, suspend, reverse or refuse a transaction, a payout or a refund;

(b) require you to complete or repeat identity verification;

(c) ask you for information about the source of funds used for a transaction, or about the source, ownership and provenance of an Item;

(d) ask you for supporting documents, including proof of purchase, an invoice, a warranty card, an import document or a second-hand goods register entry;

(e) limit the value or number of transactions on an account;

(f) freeze an account and the funds held for it pending an investigation; and

(g) report suspicious or unusual activity to the Financial Intelligence Centre, the South African Police Service or another competent authority.

13.2.2 We may act under clause 13.2.1 without prior notice where notice would defeat the purpose of the action, where there is a risk of harm to another User, or where the law requires it.

13.2.3 If you do not give us information we reasonably request under this clause within the time we specify, we may hold the funds, refuse the transaction, or suspend the account.

13.3 Sanctions screening

13.3.1 We screen Users against applicable sanctions and watch lists, including the United Nations Security Council sanctions lists given effect in South Africa under the Protection of Constitutional Democracy against Terrorist and Related Activities Act 33 of 2004, and [INSERT: the other sanctions and watch lists screened against, and the screening provider used].

13.3.2 We will not process a transaction for a person who is the subject of applicable sanctions, and we may be required to freeze funds and report the match.

13.3.3 A screening match is not an accusation. If you believe you have been matched in error, tell us and we will review it, and clause 9.3 gives you a route to appeal.

13.4 Your obligations

13.4.1 You must not use the Platform or its payment facilities to launder money, to finance terrorism, to move the proceeds of crime, or to move funds for any purpose other than a genuine sale of an Item, as clause 16.2.8 of the Terms & Conditions provides.

13.4.2 You must not structure transactions to avoid a threshold, a control or a reporting obligation.

13.5 Fraud losses

13.5.1 Subject to clause 14.1, we are not liable for a loss you suffer as a result of fraud committed by another User or by a third party, including a loss caused by your paying outside the Platform, by your giving your credentials or one-time PIN to anyone, or by your acting on a message that was not sent by us.

13.6 No tipping-off

13.6.1 Where we make a report to the Financial Intelligence Centre or to another authority, the law may prohibit us from telling you that we have done so. Section 29(3) of the FIC Act makes it an offence to disclose the fact of certain reports, and section 38 of that Act protects a person who makes a report in good faith.

13.6.2 Accordingly, we may not always be able to tell you why a transaction has been delayed, held or refused, or why an account has been frozen. This is not an evasion. It is a legal restriction on what we may say, and it applies to us as it applies to banks and other regulated businesses.

13.6.3 We will give you as much information as the law allows, and clause 9.3 gives you a route to query and appeal.

14. Dormant balances, unclaimed funds and limits on our liability

14.1 What we do not exclude

14.1.1 Nothing in these Payment Terms excludes or limits our liability for gross negligence, fraud, dishonesty or wilful misconduct on our part, for death or personal injury caused by our act or omission, or for anything that section 51 of the Consumer Protection Act or any other law does not permit us to exclude or limit. Clause 19.1 of the Terms & Conditions applies in full to this document.

14.1.2 Our liability is otherwise limited as clause 19 of the Terms & Conditions provides, including the caps in clause 19.4.

14.2 Dormant balances and unclaimed funds

14.2.1 A balance may become dormant where, for example, a refund cannot be paid back to a closed payment method and the Buyer does not respond to our requests for alternative details, or where a Vendor closes its account leaving a balance and does not respond.

14.2.2 [CONFIRM with attorney: the treatment of dormant balances and unclaimed funds — how many attempts are made to contact the User and over what period; how long an unclaimed balance is held; whether any administration fee may lawfully be deducted from an unclaimed balance; whether the funds are held by the Escrow Provider or by List Secure; what happens at the end of the period, including whether the funds may be forfeited, must be held indefinitely, must be paid to the Guardian's Fund, or must be dealt with in some other way; and the effect of prescription under the Prescription Act 68 of 1969. Forfeiting a consumer's money to ourselves is very likely to be an unfair, unreasonable or unjust term for the purposes of sections 48 and 51 of the Consumer Protection Act, and must not be published without express attorney sign-off.]

14.2.3 Whatever the outcome of clause 14.2.2, we will make reasonable efforts to trace you and return your money, and we will keep a record of those efforts. Money that belongs to you does not stop belonging to you because you did not answer an email.

15. Currency, pricing and how prices are displayed

15.1 Prices are set by the Vendor and are shown in South African Rand.

15.2 Prices are displayed [INSERT: whether displayed prices include VAT or exclude VAT]. Where a Vendor is a registered VAT vendor, the price displayed must be the VAT-inclusive price, as section 65 of the Value-Added Tax Act 89 of 1991 requires for prices advertised or quoted to the public. [CONFIRM: that the Platform enforces VAT-inclusive price display for VAT-registered Vendors, and that it does not display a VAT amount for Vendors who are not VAT registered.]

15.3 The Order Total shown at checkout includes the Purchase Price, the Delivery Charges and any applicable fees and taxes. Nothing further is payable to us or to the Vendor for that Order unless the Listing says so.

15.4 Obviously erroneous prices. Section 23(9) of the Consumer Protection Act allows a supplier not to be bound by a price that contains an obvious unintentional error, provided the error is corrected and the consumer is told about it in good time.

15.4.1 Where an Item was displayed at a price that a reasonable person would recognise as an obvious error, we or the Vendor may cancel the Order. If we do, we will tell you as soon as we can and the full Order Total will be refunded to you from escrow. You will not be charged.

15.4.2 We will not cancel on this basis where the price was a genuine promotional or clearance price, or where the price was simply lower than you expected.

15.4.3 If an Order has already been delivered before the error is discovered, we will not require you to return the Item; we will deal with the matter with the Vendor.

15.5 A price shown in an advertisement, a search result, a cached page or a third-party price comparison site is not binding if it differs from the price shown on the Listing at the time you place the Order.

16. Disputes and complaints about payments

16.1 Order Disputes

16.1.1 A disagreement about an Order — non-delivery, an Item not as described, a faulty Item, a return or a refund — is a Dispute and follows the five-step path below. It is the same path in every document in the Platform Terms.

16.1.2 The Dispute escalation path:

Step 1 — the Buyer raises the Dispute in the Platform before the Acceptance Window closes, with a description of the problem and supporting evidence (photographs, the delivery record and the message history).

Step 2 — the Vendor has [INSERT: number] Business Days to respond, with its own evidence.

Step 3 — List Secure reviews the evidence and issues a determination within [INSERT: number] Business Days.

Step 4 — the Escrow Provider gives effect to the determination in accordance with its own terms.

Step 5 — unresolved matters go to the National Consumer Commission, a recognised consumer ombud, the Small Claims Court, or arbitration under [CONFIRM: AFSA or private arbitration].

16.1.3 While a Dispute is open, the funds for that Order stay in escrow.

16.1.4 A determination we issue in Step 3 is our assessment of the evidence available to us, as the operator of the Platform and under the Platform Terms. It is not an arbitration award, a court judgment or legal advice, and it does not decide the legal rights of the Buyer and the Vendor against each other. Both of you keep every right you have in law, and Step 5 remains open to you.

16.2 Complaints about us

16.2.1 A complaint about a fee, a payout, a hold, a refund or anything else in this document goes first to support@listsecure.co.za. We will acknowledge it within [INSERT: number] Business Days and respond within [INSERT: number] Business Days.

16.2.2 If you are not satisfied, you may approach the National Consumer Commission, the Consumer Goods and Services Ombud or another recognised ombud with jurisdiction, the National Consumer Tribunal, the Small Claims Court, arbitration under [CONFIRM: AFSA or private arbitration], or any court with jurisdiction. Clause 26 of the Terms & Conditions sets out the full route and the contact details.

16.3 Complaints to the Payment Provider and the Escrow Provider

16.3.1 The Payment Provider and the Escrow Provider have their own complaint channels, and you may use them directly. You do not need our permission to do so.

16.3.2 Payment Provider (PayFast, a Network International company) — complaints about the processing of a card or EFT payment, a declined transaction, a duplicate charge at gateway level, or the gateway's own fees: [INSERT: PayFast's current complaint contact details and complaints process, and any financial services ombud or regulator to which a PayFast complaint may be escalated].

16.3.3 Escrow Provider (TradeSafe) — complaints about the holding, release or delay of funds in the Escrow Account, or the Escrow Provider's own fees: [INSERT: TradeSafe's current complaint contact details and complaints process, and any ombud or regulator to which a TradeSafe complaint may be escalated].

16.3.4 Your bank or card issuer — complaints about a card transaction, a chargeback outcome or your account: your bank's own complaints process, and thereafter the National Financial Ombud Scheme South Africa [CONFIRM: the correct current name and contact details of the ombud scheme with jurisdiction over banking complaints].

16.3.5 Approaching a regulator or an ombud is free to you and does not take away your right to go to court.

17. Changes to these Payment Terms

17.1 We may change these Payment Terms. The current version is always available on the Platform.

17.2 Where a change materially affects your rights or the fees you pay, we will give you at least [INSERT: number of days' notice of a material change to the Payment Terms] notice by email and by notification in the Platform.

17.3 A change does not apply to an Order already placed. The version in force when the Order was created governs that Order.

17.4 If you do not accept a change, your remedy is to stop using the Platform and, if you are a Vendor, to close your Vendor account.

18. Governing law and jurisdiction

18.1 These Payment Terms and every transaction on the Platform are governed by the laws of the Republic of South Africa.

18.2 You consent, in terms of section 45 of the Magistrates' Courts Act 32 of 1944, to the jurisdiction of the Magistrates' Court having jurisdiction over you, in respect of any proceedings arising out of these Payment Terms, even where the amount in dispute exceeds that court's normal jurisdiction. This does not limit our right to institute proceedings in the High Court of South Africa where we choose to do so, and it does not limit your right to approach any court, tribunal, ombud or regulator that has jurisdiction.

18.3 Clause 18.2 does not limit our right to institute proceedings in the High Court of South Africa where we choose to do so, and it does not limit your right to approach any court, tribunal, ombud or regulator that has jurisdiction.