National Credit Act Language Policy

1. Introduction

Section 63 of the National Credit Act, No. 34 of 2005, as amended (“NCA”) states that a consumer (customer) has a right to receive any document that is required in terms of the NCA (“Credit Documentation”) in an official language that the consumer reads or understands, to the extent that is reasonable having regard to usage, practicality, expense, regional circumstances, and the balance of the needs and preferences of the population. Accordingly, Koola Capital (“Koola”) is required to offer Credit Documentation in at least two official languages.

The purpose of this Language Policy (“Policy”) is to give effect to the right of the consumer set out in section 63 of the NCA as it pertains to credit agreements concluded with Koola.

2. Objectives

The objectives of this Policy are to:

• Ensure that Koola remains compliant with all the NCA requirements insofar as they relate to the official languages that Credit Documentation shall be provided in.
• Ensure Credit Documentation is provided in official languages that:
  • Align with the dominant language preferences of the Koola customer population.
  • Balance the needs of the Koola consumer population against the practicality of Koola being able to provide Credit Documentation in multiple official languages.
• Establish responsibility for the maintenance and enforcement of this Policy on an ongoing basis.

3. Communication Languages

While Koola will endeavour to do everything reasonably possible to ensure that customers are able to read and understand Credit Documentation, it is not practically possible to provide Credit Documentation in all eleven official languages.

Koola has made a determination on which official languages to use for Credit Documentation by having regard to usage, practicality, expense, regional circumstances, and the balance of needs and preferences of Koola’s customer population.

In light of the above, Koola has elected to provide Credit Documentation to customers in either English or isiZulu (“Communication Languages”). This determination was made by taking the following factors into account:

• English is considered to be the primary business language in South Africa.
• isiZulu is one of the most widely spoken languages in the regions where Koola operates.

4. Policy Implementation

4.1 Credit Documentation

For purposes of this Policy, Credit Documentation refers to any formal document required in terms of the NCA and is limited to:

• Key information documents, such as quotations, pre-agreement statements, credit agreements, and amendments thereto in terms of the NCA.
• Legal/Enforcement Notices in terms of the NCA, such as notices in terms of section 129(1)(a) or section 86(10).

Koola will provide Credit Documentation in one of the two Communication Languages and endeavours to do so in plain language that is understandable to the customer, i.e. not overly complicated jargon.

• Key information documents are available in both Communication Languages.
• Legal/enforcement notices are currently available in English only. Such notices will be translated into isiZulu prior to Koola seeking to enforce any credit agreements against a customer who has chosen isiZulu as their preferred language.

4.2 Marketing and Advertising Material

All marketing and advertising material are available in English only. Usually, marketing material does not contain or communicate customer rights and/or obligations; therefore, it would not be cost-effective or practical to translate it into other languages.

Should a customer require any clarification regarding marketing material, the customer may contact Koola’s Customer Service Centre and receive assistance in their preferred language.

4.3 Delivery Channels

All delivery channels are available in English only, as these channels are not used solely for the conclusion of credit agreements. These channels also host information pertaining to Koola as well as its product and service offerings and are digital. It would, therefore, not be cost-effective or practical to have these delivery channels available in both Communication Languages as this would require Koola to incur software development and hosting costs that are disproportionate to the need for the channels to be provided in both Communication Languages.

4.4 Customer Service Centre (“CSC”)

The Koola CSC has the capability to converse with and assist customers in both Communication Languages for any credit-related queries. Koola will always strive to enable customers to understand the information that is provided to them and will attempt to verbally communicate with the customer in their preferred language, where reasonably possible, where the Communication Languages are not clearly/easily understood.

5. Access to this Policy

• A copy of this Policy will be published on the official Koola Capital website (www.koolacapital.co.za).
• A copy of this Policy will also be made available electronically, free of charge, to customers upon request.