The JSE determined that Munro's actions and failure to comply with important provisions of the Listing Requirements were one of the causes of Tongaat's consolidated financial statements being published and disseminated with material misstatements from 2011 to 2018. Munro was Tongaat's CFO during the relevant periods, and he was the guardian and overseer of Tongaat's financial health and infrastructure, with a key role and direct function being the analysis and preparation of Tongaat's financial statements. Munro was also the senior executive in charge of managing Tongaat's financial actions and held the highest financial position in the company. Munro was in charge of the material prior to the errors. Munro's actions directly caused and/or contributed to Tongaat's violation of the listing requirements.