|Open Letter – Submission – B-BBEE Certificates should only be issued to compliant entities|
B-BBEE Certificates should only be issued to compliant entities.
We recommend that the dti minister, SANAS and IRBA jointly ensures that BEE certificates only be issued by verification agencies or approved auditors if the measured entities have reached a compliant BEE level. Where the entity is not-compliant, agencies/auditors should not be allowed to issue certificates.
Far too many companies ask to be verified and end up with a non-compliant score – less than 30 points. Some even get 0 (zero) points, which is more an indication of lack of interest than a genuinely poor score. Quite frankly, it is impossible to earn 0 points. At least one or two of their suppliers must be compliant – banks, cell phone companies. We have even seen a tender going out for the issuing of a “non-compliant certificate”. We have hundreds of non-compliant certificates on our database.
Very often the company is only interested in obtaining a BEE certificate, to give to their customer, in the hope that the certificate will be accepted, without the customer complaining about the low level. The customer’s contact person who receives the certificate is often untrained on BEE principles and does not always understand how levels work, or what non-compliant means. They often simply accept a certificate if it was produced by an accredited agency or auditor. They really should go back to their supplier and explain that a non-compliant certificate does not help them at all.
Our suggestion is that a verification agency must not be allowed to issue a certificate to an entity unless it has reached a compliant level – level 8 at minimum.
A BEE certificate should be seen as a certificate of achievement, and not a certificate of attendance. If you pass your matric, you get a matric certificate. If you fail, the school does not issue you with a certificate of failure. Anything less than Level 8 should not be rewarded with a valid B-BBEE certificate.
We recommend to the minister and to the regulators, SANAS and IRBA, that they instruct the verification agencies and approved auditors NOT to issue a BEE Certificate of Compliance, if the company is not in compliance. The agency can issue a letter and report, not bearing the SANAS or IRBA logos stating the points achieved with a clear disclaimer that this cannot be used as a certificate.
To be fair, there are some agencies that already refuse to issue a certificate to a non-compliant company. However, often all that the non-compliant company does is appoint a different agency or approved auditor. If all agencies were to follow the same policy, we would expect to see an improvement in levels of compliance. If a company that needs a valid BEE certificate were to not get one because they were not compliant, we believe that the company would take instant remedial steps to become compliant.
We believe that this will go a long way to ensuring improved compliance, and better implementation.
This is not a change to the codes, but only the method of verification, so does not require a gazette or commentary period in terms of 9(5) of the act. If SANAS and IRBA were to issue guidelines and in the future, notices of non-conformance, we believe that this would be sufficient.
|Skills Development – Portfolio of Evidence|
An easy way to take care of paperwork is the compilation of a Portfolio of Evidence (P.O.E.) for each learner. The good news is that once a suitable system is set up the onus of compiling the P.O.E. falls on the learner and should form part of the assessment process – in other words no P.O.E. – no competency. The learner’s need the competency to improve their performance, their chances of promotion and development and so with correct management of the implementation of the system you could be home and dry.
So what should/could the P.O.E. be comprised of:
One of the daunting aspects about all of this is the gathering of evidence and proof that training is indeed taking place. You may or may not have dedicated HR staff whose responsibilities fall in this area of expertise. Whichever way it works in your business it is almost certain that unless you run a significant payroll there is no one person whose sole responsibility is simply to look after the administration issues around training and development. As suggested in previous mail shots you can outsource work such as this to reliable and efficient service providers.
As a responsible and effective employer you have decided to embark on a supported skills development initiative for the people in your business. You know you should be doing this as per the BBBEE requirements and you also know that if you are going to be in business down the line then you need your employees to be adding value to the work that the company is involved in.
- CV – a short overview of who the learner is.
- Contractual obligations – the contract (if any) entered into in terms of the training and development initiative.
- Proof of induction of the learner into the initiative.
- Proof of attendance on courses – a signed copy of the attendance register etc.
- Assessment reports.
- Assessment results.
- Tracking documentation such as proof of work place documentation pertaining to the transfer of skills into the workplace. This would involve hands on exposure incorporating the learning and development into the actual job the learner is involved in.
- Proof of costs and the spend on the specific training initiative/s.
- Any other pertinent documentation pertaining to the learner. An example could be a requirement that the learner participates in CSI initiatives in terms of giving/putting back into the community. Any work done in this regard is then recorded in the P.O.E
- Proof of attendance on any team building initiatives.
None of the above is rocket science. What it represents is a simple, sound and painless administration practice that will assist you in meeting your BBBEE training requirements, accruing the valuable points required to continually build your business whilst at the same time nurturing a professional and trained workforce. Win/Win!
For more information or for assistance please contact JENNY O’CONNOR, firstname.lastname@example.org.
|Preparing for verification?|
Good Preparation for verification is the major contributing factor to earning a successful score. EconoBEE’s Prepare for Verification and Future-proof your BEE Activities
conference aims to make the BEE verification process less stressful by showing you all of the tips and tricks to earn maximum points.
|Date:||29 August 2013 – JHB – Gallagher Estate|
19 September 2013 – CPT – Belmont Conference Centre
12 September 2013 – DBN – Makaranga Garden Lodge
|Time:||8:30 for 9:00 – 17:00|
|Price:||R3500 excl VAT (R3990 incl VAT)|
|Booking Details:||Email email@example.com|
Contact 011 483 1190
Book online or download our brochure.
Preferential Procurement – Save Time by using the BEE Procured database containing over 30 000 BEE Certificates. Procurement Managed Service: Our consultants can phone your suppliers for a BEE certificate – Managed Service.
While there is demand for a B-BBEE Scorecard someone will be taking advantage, shouldn’t that someone be you…
20 August 2013
In this issue
- Open Letter – Submission – B-BBEE Certificate should only be issued to compliant entities
- Skills Development – Portfolio of Evidence
- Preparing for verification?
EconoBEE is an expert BEE consultancy. EconoBEE helps businesses Become BEE Compliant, prepare for verification, earn maximum BEE Points and ensure that they achieve the BEE Level they need to get more business.
Our services include BEE Management Systems, Training, EME Pack, Complete Managed Services; consulting and advisory and Procurement Solutions.
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