THE saying, “If you can’t measure it, you can’t manage it”, is particularly apt when it comes to black economic empowerment. Almost every aspect requires some form of measurability, which has to be backed up with the correct documentation. Your scorecard must contain a true reflection of your status at the time of rating. The only objective method of proving this status is to furnish the requisite proof. This list should be your starting point.
Direct empowerment — equity
Company and close corporation registration documents indicating shareholding;
Minutes of the last board meeting; and
Racial breakdown of shareholders, including nationality and certified copies of identity documents or passports.
Direct empowerment — executive management (senior or board members)
Registration documents listing board members;
Minutes of the last board meeting; and
Racial breakdown of board members of and executive management, including nationality and certified copies of IDs or passports.
Direct empowerment — employment equity
Copy of the receipt of the latest submission of your employment equity report;
Updated employment equity plan; and
Comprehensive organogram showing management structures — senior, middle and junior — including race and gender.
Direct empowerment — skills development
Financials showing skills development spend as a percentage of payroll;
Workplace skills plan;
Financial quantification of all training;
Proof of training;
List of staff that have attended these courses, showing racial and gender status;
Copies of learnership agreements; and
List of learners showing race and gender.
Indirect empowerment — preferential procurement
Complete list of all your suppliers, detailing procurement spend — this excludes salaries, VAT and charitable donations;
Your procurement policy;
Your assessment of what constitutes eligible procurement;
Each supplier’s latest empowerment rating;
Each supplier’s size (as measured by the National Small Business Act 102 of 1996); and
The percentage of total procurement spent on each supplier.
Indirect empowerment — enterprise development
Financials showing investment in other companies as a percentage of profit before tax (incubators and so on), and empowerment rating certificate of (these including shareholding certificate);
Quantifiable nonmonetary support to other companies (such as time, materials); and rating certificate of these (including shareholding certificate);
Indirect empowerment — corporate social investment
Financials showing charitable contributions as a percentage of profit before tax (not limited to tax but must be quantifiable);
Documents showing the beneficiaries of the charity; and
Proof of the contribution.
The codes released this month made it clear SMEs would not require an official rating certificate. This does not mean small businesses should not furnish documents to back up their self-rating.
If a company produces a score that, for instance, seems too high, it may be required to obtain a certificate from an official rating agency, which will ask to see proof.
The codes are clear on the necessity of proof and the consequences if it cannot be furnished. Points are not awarded without it.
Janisch is CEO of BEE consultancy Caird Consulting. His book, The Basics of BEE, will be on the shelves next month.