Moyo was unexpectedly suspended from his position on May 23, due to what the company described as a breakdown in trust and confidence.
In his notice, Moyo wants his suspension to be declared "unlawful, unconstitutional and null and void" -- as well as contractual damages against Old Mutual.
At the centre of Moyo's dispute with the insurer is his relationship with NMT Capital, a black-owned investment company that he co-founded, and an alleged payment of dividends. Old Mutual Life Assurance Company, a subsidiary of Old Mutual, is an investor in NMT Capital.
In his affidavit, Moyo states that his suspension and the eventual termination of his contract on June 17, was "devastating and humiliating".
He says his rights were ignored and disregarded "in the unilateral preference of the economic interests of Old Mutual".
Manuel 'triple conflict'
He further states that friction between himself and the company started in March 2018, when he raised concern about what he perceived as "triple conflict" on the part of board Chairman Trevor Manuel during the process of the company's Managed Separation.
The process saw the company delist Old Mutual plc from the London Stock Exchange and list Old Mutual Limited on the JSE in June 2018.
He said one of the companies which stood to benefit from the exercise which involved a transfer of R5bn from Old Mutual plc to the new entity was Rotchschild, the company which Manuel was chairman. Manuel was also at the time a director at Old Mutual plc and chairman of Old Mutual Limited.
"I openly voice my objections to Mr Manuel about the impropriety of his participation in any discussion regarding the proposed takeover of the Old Mutual Plc liability, which was in the nature of a guarantee in favour of an American company," said Moyo.
He says his relationship with Manuel deteriorated from that point, followed by "relatively smaller incidents of pettiness".
Moyo held the position of CEO for two years.
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