As you are all aware the Revised BBBEE Codes of Good Practice has caused quite a stir in the business community, and justifiably so. We as Global are in the process of rolling out information sessions to all of you in an effort to inform so that your comments are based on all aspects of the revision that may hurt your company’s scorecard. The roll out thus far has been a success yet has highlighted the realities of the draft changes. Once these realities hit home it becomes patently clear to all that we must submit comment in this regard to all avenues available. We trust that this will make the DTI sit up and take notice that what is currently a big bright juicy carrot (The Codes of Good Practice, 2007) is turning into a large stick. As the old adage goes – You catch more more flies with honey…
Onto more promising news, the DTI recently held a briefing in which they said the following…(I paraphrase) Insert quotation marks
• The revision is a draft document put out for comment and should be treated as such. This revision is apparently a broad view with allsorts thrown in. It will be refined and repackaged based on the comments received.
• All comments received will be collated, reviewed and considered for amendment to the draft, and then put out for another comment period after December 5, 2012.
• The DTI seems hopeful that this process will be resolved by February 2013 and will be gazetted on the anniversary of the codes. This timeline fits with one further commentary period.
• The glaring omission of Statement 600 and the Technical Assistance Guidelines (TAG) are coming.
• The final gazetted codes will come into effect a year after they are gazetted – Essentially, a transition period is allowed.
Given the above and the experiences of the past, we foresee that this revision will be effective, practically speaking, in about 18 to 24 months from now. This does not allow us to become complacent however. To assist you in this regard we can offer you the following:
• Standard generic commentary which you may use on your letterhead to submit to the DTI
• Personalised commentary based on your company’s specific profile and supported by the last measurement period data, where available.
• Scenario testing and planning based on the changes proposed
Ultimately though, it is important to note that you must not lose sight of the current codes and the need to adequately prepare for your next audit. If your company has a Financial Year that ends in December or February the focus should be on a BBBEE Fitness Test or GAP Analysis to ensure that your target score is achieved before it is too late to implement initiatives to bolster the score.
For further advice and information please do not hesitate to contact any member of our BBBEE team…
Johnny and Vinal