Inside the practice · Our own internal documents

The Governance Register.

MBM Valkyrie Advisory runs on a written internal governance framework — a charter, delegations, policies and registers adopted by resolution and reviewed annually. What follows is the public record of that framework: the Company’s statutory PAIA and POPIA Manual, and a selection of its own internal instruments, published so that clients, funders and organs of state can see how the practice governs itself.

Notice · Status of these documents

The documents on this page are internal documents and policies of MBM Valkyrie Advisory (Pty) Ltd (registration number 2026/493372/07). They form part of the Company’s internal governance framework, bind the Company and those who act in its name, and are published for transparency and client assurance. The PAIA and POPIA Manual is, in addition, a public document published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000.

These documents are not legal advice, and they are not precedents or templates for adoption or use by any other person or organisation. MBM Valkyrie Advisory (Pty) Ltd is an independent legal, governance and compliance advisory practice; it is not a firm of attorneys. © MBM Valkyrie Advisory (Pty) Ltd — the documents may not be reproduced or adapted without the written consent of the Board.

Statutory publication

Section 51 of PAIA

Published as required of every private body. Requests for access to records, and POPIA requests, are dealt with by the Information Officer in accordance with this Manual.

MBM‑PAIA‑01

PAIA and POPIA Manual

Public document · Version 2.0 · 13 September 2026

What records the Company holds, how to request access to them, the prescribed fees, and how the Company processes personal information. Information Officer: Mthokozisi Brian Mhlongo — Information Regulator registration number 2026‑064683.

Download the Manual (PDF)

Published internal policies

7 instruments

Internal policies of the Company, published for transparency. Each instrument is adopted by written resolution of the Board, carries its reference in the Company’s Policy Register, and is reviewed annually. The copies below are the clean issued versions; the signed originals are held in the Company’s minute book.

  • MBM‑GOV‑03

    Code of Conduct and Ethics

    Internal policy · Published for transparency · v1.0

    The standard of conduct required of everyone who acts in the Company’s name.

    Download PDF
  • MBM‑GOV‑06

    Compliance Policy and Regulatory Universe

    Internal policy · Published for transparency · v1.1

    The Company’s compliance obligations, calendar, monitoring and breach procedure.

    Download PDF
  • MBM‑GOV‑07

    Client Acceptance, Engagement and Independence Policy

    Internal policy · Published for transparency · v1.0

    Who the Company may act for, on what terms, and when it must decline or withdraw.

    Download PDF
  • MBM‑GOV‑08

    Information Governance and POPIA Policy

    Internal policy · Published for transparency · v1.1

    Personal information, confidentiality, data subject rights and access to information.

    Download PDF
  • MBM‑GOV‑09

    Financial Management, Procurement and Tax Compliance Policy

    Internal policy · Published for transparency · v1.0

    Banking, revenue, expenditure, procurement, accounting records, tax and financial controls.

    Download PDF
  • MBM‑GOV‑11

    Ethics, Whistleblowing and Anti-Bribery and Corruption Policy

    Internal policy · Published for transparency · v1.2

    Reporting channels, protected disclosures, the prohibition on corrupt conduct, and the Company’s adequate procedures under section 34A of PRECCA.

    Download PDF
  • MBM‑GOV‑15

    Client Complaints and Service Standards Policy

    Internal policy · Published for transparency · v1.0

    The service standards a client is entitled to expect, how to complain, and what happens when we fall short — including the external routes that do not run through us.

    Download PDF

Available on request

8 instruments

Every instrument of the framework has been drafted, adopted and entered in the Policy Register (MBM‑GOV‑13). The instruments below contain operational and commercial detail and are not published here. As their confidentiality legend provides, they are produced to a client, funder, auditor or organ of state as evidence of the Company’s internal governance arrangements — write to info@mbmvalkyrie.co.za.

  • MBM‑GOV‑01

    Governance Framework Charter

    On request
  • MBM‑GOV‑02

    Delegation of Authority Framework

    On request
  • MBM‑GOV‑04

    Conflicts of Interest and Declarations Policy

    On request
  • MBM‑GOV‑05

    Risk Management Policy

    On request
  • MBM‑GOV‑10

    Records Management and Company Secretarial Procedures

    On request
  • MBM‑GOV‑12

    Technology, Information and Artificial Intelligence Governance Policy

    On request
  • MBM‑GOV‑13

    Framework Adoption Resolution and Policy Register

    On request
  • MBM‑GOV‑14Business Continuity and Key-Person Succession PlanOn request

Requests and questions

A request for access to a record under PAIA is made on Form 2 of the PAIA Regulations, 2021, addressed to the Information Officer at paia@mbmvalkyrie.co.za, and is subject to the prescribed request fee — the procedure, the fees and the remedies are set out in the Manual above. A POPIA request (objection, correction or deletion of personal information) goes to the same address and carries no fee.

A report under the Ethics, Whistleblowing and Anti‑Bribery and Corruption Policy may be made in confidence to whistleblowing@mbmvalkyrie.co.za — a dedicated mailbox — or through any of the statutory channels listed in that policy.

Questions about any instrument on this page can be sent to info@mbmvalkyrie.co.za. See also the Company’s privacy notice.

The content of this page and of the documents on it is general information about MBM Valkyrie Advisory (Pty) Ltd and its internal governance arrangements. It is not legal advice, and no advisory relationship arises from reading or downloading any document on this page.

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