BEE fronting – what it is, the risks, and what to do about it:

There has been a lot of recent publicity around BEE fronting and the B-BBEE Commission devoted much of its recent annual conference on BEE ownership to this very important topic. Fronting and BEE ownership can easily overlap.

At the 2019 B-BBEE Ownership conference the Minister of Trade and Industry (under whose ministry the B-BBEE Commission falls) categorically stated that fronting is hampering economic transformation.

However, some issues are often overlooked and so in this article we seek to clarify some of the issues around fronting.

What is “fronting”?

Fronting was not mentioned in the original BEE Act (2003), but it did not mean that people did not abuse the Act and put all sorts of structures in place which met the letter of the law but actually did nothing to further the objectives of the Act.

In response, a decade after the Act was passed a definition was included for what constitutes a “fronting practice”.  In essence it was defined as “any act that undermines or frustrates the objectives of the Act or its implementation”.  This can obviously be broad and can be open to interpretation.

The definition does list some examples, but this is not an exhaustive list.  In other words, there are other forms of fronting, but the following are definitely fronting (in simpler English than in the Act.  Please read section 1 of the B-BBEE Act for the proper definitions):

  • Where a Black Person is given a title (such as director or shareholder) but does not get the powers associated with it;
  • Where the economic flows from a BEE transaction differ between what the legal documents say and what actually happens;
  • Where the contracts are not commercially reasonable. This could be because the contract has significant (and unfair) limitations, is not likely in reality or was not arm’s length on a fair and reasonable basis.

While the list is not exhaustive (and more examples exist), it is clear if one contracts or appoints fairly and then abides by the contract there is no clear-cut fronting, and some proof will be required that the objectives and implementation of the Act are knowingly being frustrated.

What are the consequences of fronting?

Just inserting a definition of fronting into the Act doesn’t really change how people behave.  So, it’s important that all the other 2013 amendments also be considered.

The most significant were in section 13, which not only established the B-BBEE Commission but also criminalized certain contraventions of the Act, including fronting (section 13 O(1)(d)).

Anyone found guilty of fronting can be sent to prison and/or be fined.  These penalties can be summarized as follows:

  • For people involved in fronting: prison can be for up to ten years and there is no limit to the fine.  People can be sentenced to both prison and a fine.
  • For companies involved in fronting: the fine can be up to 10% of annual turnover (there cannot be any imprisonment).
  • For verification agents, procurement officers and public servants who are aware of any fronting or attempted fronting who fail to report the fronting: prison can be for up to one year and there is no limit to the fine.  These parties can also be sentenced to both prison and a fine.

Clearly these are very serious offences.  To be clear, there are other offences in the BEE Act, which carry the same penalties.  But this article will be confined to the offence of fronting.

Section 13P adds another consequence to a fronting conviction: once convicted the guilty party also cannot for the next ten years deal with government and organs of state.  Given that such contracts were presumably the motivation for the fronting, this could be the worst punishment for many businesses (and could be 100% of turnover for the next decade).  This is  theoretical, as such a company clearly would not be around after conviction.

The section goes on to provide for all shareholders and directors of a company convicted of fronting (even if they themselves were not) to be restricted in a similar way.  This is so that they do not simply try and front again through another entity.  Importantly, there is no time limit for such a restriction and individual shareholders and directors could find that they are banned from ever doing public sector work.

But, as the B-BBEE Commission points out, this is not all…a conviction also comes with significant reputational damage.  For example, if payments have been made to a business on the back of BEE Scores that were wrongfully obtained because of fronting, litigation may be instituted to recover these amounts.

In other words, fronting carries some really serious penalties including reputational risk, fines, imprisonment and removal of access to markets (government spend).

Who can be guilty of fronting?

As can be seen from the above it is clear there are two types of fronting offenders:  those who front and those who know of fronting and who should report it.

To be guilty of fronting one has to knowingly engage in fronting.

While this sounds like the normal requirement in criminal law that someone should have the intention to commit the crime, the BEE Act goes further to also cover those crimes that are as a result of negligence too.

This is because there was also a definition added in 2013 for “knowing” which covers more than actual knowledge of fronting.  Those who actually know that they are engaged in fronting are liable to being charged, but so are those who ought to have known.  In this latter category are people who ought to have investigated a matter to such an extent that they have actual knowledge and those who should have taken reasonable steps to have actual knowledge.

Let’s unpack what this means, using a common front arrangement:  a black person signs up to be a shareholder in a business and gives it BEE points. However, that person is not really a shareholder because he signs contracts that leave the economic rights and votes in that company in effect unchanged.  This is a typical sham transaction and the company would have engaged in fronting practice because it would have actual knowledge that nothing has changed (and in all likelihood not demonstrable audit/paper trail of records of participation in meetings, dividends, resolutions, etc).

But, just like with bribery and corruption, fronting practices have to always involve two or more parties.  Simply put this boils down to a white party (which wants to get BEE credentials) and a black party (who gives those credentials) at least.  So, the black party in this example has also engaged in a fronting practice.

However, he might escape criminal liability if he did not “know” he was fronting.  If he conspires with the white party and knows full well that there is a front, he is equally guilty as the white party.  But what if he genuinely did not know?  Well, this is where the definition is important, and one would need to consider whether he should have investigated or taken steps to understand.  The test is whether “reasonable” steps were taken to get the knowledge.

What is reasonable?

Consider whether it is reasonable for a black person to say he did not know he was fronting when he is well educated and experienced in commercial matters and has signed contracts with fronting in?  Getting an attorney or accountant as a BEE partner therefore, for example, gives certain protection to a white party because the BEE partner has to think carefully before reporting fronting that he himself knows about and is involved in.  Such partners should investigate or are reasonably expected to find out and whether they do or not is not relevant to whether they know or not that they are fronting.

But, if even the most uneducated BEE partner becomes aware of his involvement in a fronting practice and allows it to continue, he is fronting too!

It is important that all verification agents, officers and state officials understand that the B-BBEE Commission has effectively got them as its eyes and ears and if they become aware of any fronting or attempted fronting, they have to report it, in much the same way one has to report a car crash that one is involved in.  Not reporting something like this is an offence for such people.

How does someone get convicted of fronting?

As with any crime only a court can convict someone of fronting.

For this to happen, someone would need to lay a complaint and the B-BBEE Commission would need to investigate the matter and decide to refer the matter to the NPA for prosecution.

The NPA would then need assess itself whether it agrees with the B-BBEE Commission and decide whether it believes that it can successfully prosecute.  Then of course a judge would need to agree with the NPA and B-BBEE Commission that fronting has taken place (and if there is an appeal, maybe more judges would need to agree too).  But, what is clear is that the B-BBEE Commission does not have the powers to convict anyone of fronting – that is handled through ‘normal’ legal challenges.

What’s very important however, is that the B-BBEE Commission does have significant powers to investigate fronting, and this can open up a can of worms for guilty parties.

Section 13K gives powers to summon witnesses and evidence, for example.  People have to cooperate with the Commission, but they do not if it will incriminate themselves, and if they do and it is self-incriminatory the evidence is not admissible in the criminal court case.  But, to be clear, the B-BBEE Commission can make a finding of whether fronting has occurred (section 13J(3) makes this crystal clear) but this is not a criminal conviction.

More likely, what happens here is that the BEE commission could refer you to court to enforce the terms of the ‘fronting’ agreement. For example – a black person (the gardener or the tea lady) is told they become the owner of 51% of the share in a company but never see a share certificate, dividend or board meeting (fronting 101) – the courts could enforce the agreement leaving the black person the legitimate owner of the shares, and the company no longer fronting…as we’ve said before – the risks are high.

The B-BBEE Commission can also refer the matter to the NPA or SAPS (s13J(4) and (5)) or (and here’s another real risk) SARS (s13J(6).  So, to put it in another way, the B-BBEE Commission has access to significant information which they can share with parties with serious teeth.

How to report fronting:

Verification agencies and procurement officers have an obligation in terms of the Act to report fronting, but anyone can lay a complaint or report something suspect here: https://www.bbbeecommission.co.za/lodge-a-complaint-process/

What is the state of fronting?

A lot of fronting is alleged but before turning to the statistics around fronting it is important to contextualize fronting as follows:

Firstly, fronting only became illegal in October 2014.  So, while BEE was introduced in 2003, for the first decade there was no fronting in a legal sense.

Secondly, even though in the first five years of fronting there have not been fronting convictions, it does not mean that fronting does not occur.  This may be more a reflection of our law enforcement agencies or our court backlogs, which are not BEE issues.

Thirdly, one needs to consider whether like so many other crimes, there are reasons for underreporting.  We have already alluded to the risks of reporting a fronting offence where one is also a guilty party, but some parties will not report a crime which does not affect them, because they do not want to become involved in investigations and trials.  And, of course, many people are simply unaware that fronting occurs.  All this does not mean that fronting is not a real problem.

At the B-BBEE Commission’s 4th Annual Conference earlier this month it was reported that 484 complaints were received up to the end of 2018 and of these three had been referred to criminal prosecution and two to court.  Details were not provided as to what they were referred for, but even if it assumed that all referrals relate to fronting, one will see that the numbers are not as alarming as the popular press would lead one to believe.

Problems with fronting:

The Minister of Trade and Industry did say at the 4th Annual BEE Conference that while fronting needs to “ruthlessly eradicated”, it is equally important “to identify, support and value those who are doing the right thing”.  So, it is important not to throw the baby out with the bath water. The B-BBEE Commission also repeatedly stressed that they urge companies to approach them to review structures or other arrangements they are considering so that they can give guidance/opinions as to how to make them compliant before they are implemented. (Tusker has taken this approach with our structures and continue to engage with the B-BBEE Commission and DTI as we innovate further).

Given our history, there is too much distrust in our society and fronting is immediately suspected to be behind many BEE transactions.  This is often unfair, even though it may sometimes be the case.  The vast majority of South Africans are not criminals and we should not lose sight that we must target the wrongdoers and not go for the innocent.  The B-BBEE Commission is obligated to operate impartially and without fear or prejudice, which means that the B-BBEE Commission respects the principles of our legal system, including of criminal law.

So, if one acts wrongfully one should worry.  If not, do not.

We recommend everyone to keep solid records of decisions made, resolutions, meeting attendance, participation in management, dividends, AGMs etc (standard governance stuff, but essential proof if ever you face a fronting allegation).

Please contact us if you’re looking for a B-BBEE investor/shareholder that’s 100% legitimate and can grow the value of your investment in your business.

 

 

Is B-BBEE going away?

We’re frequently asked if B-BBEE is going away. The reality is that it’s here to stay – but likely to be changed/modified along the way. This article is an NB read for those who’d like to believe they can put off BEE until some magical future date – we think (for all the reasons listed below) that this is an unsafe bet. Please read and share. We’d be very interested, as always in constructive comments and suggestions. 

The foreign investment imperative:

Zimbabwe recently abolished indigenisation ownership requirements in its mining sector, allowing for 100% foreign ownership.  This follows a similar move in Namibia at the end of 2018 – where BEE was scrapped because it wasn’t benefitting the majority. Both countries found that foreign investment had dropped off and attributed this to their laws comparable to our BBBEE laws.  Envoys of President Ramaphosa on his drive to drum up investments in South Africa, have been told that investment is less appealing because of, amongst other factors, the BEE Act.

Foreigners are not alone in questioning this Act, which is central to South Africa’s transformation agenda.  South Africans also question the future of this Act.  The questioners range from those waiting for economic transformation and losing faith in the Act’s ability to deliver this, to those who consider the Act racist legislation to blame for corruption and economic decline.  They believe, for completely different reasons, that the Act should be scrapped, following the Namibian and Zimbabwean examples.

Policy uncertainty breeds risk:

Many investments have structured around BEE and were the Act to be scrapped, some of these investments would be relooked at.  Resentment may be created where the investment is then considered a waste.  But, even if it’s not, it’s certain that the investors would see more policy uncertainty.  Investors only need to know what the rules of the game are to be able to plan their affairs.  The rules themselves are less important than knowing that they are what they are.  The negative investor sentiment around BEE stems from the fact that rules appear to be changed often.  Consider the uncertainty around the Mining Charter and the impact on investment, for example.  The B-BBEE Commission does not help by making rulings/directives that are non-binding – compared to those by SARS which set clear guidelines for everyone on tax matters. This means that the Commission never introduces certainty, even when issuing practice notes or interpretation guidelines.  Nobody can therefore every be fully certain that the BEE rules are whatever one thinks them to be.

Change in inevitable:

We have to expect that the Act (and Codes) will change.  This is partially an admission of some of the failings in the Act, but it also reflects what a radical idea BEE is.  This is a social experiment, never attempted anywhere else in the world.  An idea to redress the past without reparations.  Normally, the idea is for the “victor” (the side on the right side of history) to make the other side pay.  This happened throughout history and after each war the loser was made to pay.  This was meant to hurt.  Germany, for example, made its final instalment ($94 million) on its WWI debt in 2010, almost a century after the Armistice.

The problem with reparations is that the “loser” often feels they are unfair and often this causes significant resentment.  The WWI reparations led the economic hardship of the Weimar Republic and the rise of the Nazis.  We all know how that worked out. Beware the shallow victory.

South Africa is a massive compromise (AKA negotiated settlement) with a powerful Bill of Rights:

Our Rainbow Nation chose not to exact revenge and reparations in this way.  But did demand the restoration of some equity and justice.  This included many compromises, which were intended to be just, without being unjust.  This was to balance the competing interest groups’ needs, without destroying value for everyone.  As with any compromise, this meant that nobody is entirely satisfied with what they got.

The compromises included the establishment of a Government of National Unity, the Truth and Reconciliation Committee, our anthem and most significantly the Constitution of the Republic.

Chapter 2 of the Constitution introduces a Bill of Rights, which is the complete antithesis of what existed under apartheid.  The Bill of Rights includes the right to equality, as the very first right, prohibiting unfair discrimination on the basis of, amongst other things, race.  Clearly, this marked a complete break with South Africa’s past, and echoed what Mandela referred to in his inauguration when he said this beautiful land would never again experience the oppression of one group by another.  It’s the same section many refer to when criticizing the BEE Act.

The right to equality is a basic human right.  Basic human rights are often called first generation rights, which are political and civil rights such as the right to be freedom of religion, speech and movement and rights to fair trials and votes and so on.  First generation rights protect citizens from the state, and, although basic were missing for most of South Africa’s history.  After the second world war, second generation human rights developed.  These are economic, social and cultural such as the rights to education, housing, health and food.  These are more progressive and also sorely needed in South Africa.  But there is a third generation of human rights such as the rights to a healthy environment, group rights and intergenerational rights.  These are much more aspirational and largely unofficial.  But, South Africa, sought to compensate for previous lack of human rights and included these too its constitution.  This is what makes our constitution so different.  One third generation right is the right to economic and social development.

B-BBEE and the constitution:

So how BEE fits into South Africa’s constitutional framework is an important consideration:  Clearly if it does not, it would not be allowed and the Constitutional Court would strike the statute down.  This has not happened and should give those who say the BEE Act should be scrapped pause, because in one way it would be easier to scrap through the Courts than through parliament.

So, we need to consider how an Act such as the BEE Act which clearly is discriminatory and does not treat everyone equally can be upheld when it immediately looks like a contravention of the first human right.

Well, let’s first consider that nothing in the Constitution prohibits discrimination.  There is plenty discrimination around that we accept.  Pensions, maternity leave, disability parking bays are examples of discrimination, where not everyone is treated equally but which nobody has challenged constitutionally.  The simple reason is that the Constitution prohibits unfair discrimination (and not any fair discrimination).  So, the first consideration is whether BEE is fair in the context of South Africa.  If it is, the Act will not be scrapped in this way.

Most people who think this is unfair have not read the Right to Equality clause in the Bill of Rights which goes to state “to promote the achievement of equality, legislative and other measures designed to protect or advance persons, or categories of persons, disadvantaged by unfair discrimination may be taken.”  Therefore, if the BEE Act is intended to promote equality it’s specifically allowed.

The BEE Act has specific objectives in section 2 which include economic transformation for more meaningful participation of black people in the economy.  There is no debate that this is designed to advance a category of persons disadvantaged by unfair discrimination.  And therefore it’s hard to argue that the BEE Act is unconstitutional by being racist.  (This is not intended to be a legal treatise on the Act vis a vis the whole of the Constitution.  Rather simply to explain why even though based on racial identity it’s not unconstitutional).

Can B-BBEE be scrapped by a political process?

The only other way for the Act to be scrapped is through the democratic process by the National Assembly repealing it.  This could be because the Act has achieved its objectives (and is therefore no longer necessary).  The Act’s objectives are not clear – in that it’s unclear what meaningful participation by black people in the economy means or what substantial change in racial composition of ownership and management is, for example.  There is quantitative measure of “meaningful” or “substantial”, but it would be hard to argue that the economy is fairly distributed while we have the Gini coefficient of inequality that we do.  We do not believe the objectives have been met, and importantly, no political party would dare to suggest this.

To overturn the Act parliament would have to change policy entirely, coming up with new objectives to better achieve equality.  This is quite a specific question and is not to be confused with some of the other perceived problems of the Act, such as corruption which are actually to be dealt with in terms of completely different laws (beyond this scope of this article).

This is a policy decision of the members of parliament to debate and it does not matter whether South Africa has a head of state who is a beneficiary of the Act or not.  What do the parties in parliament say?  Our parliament is coming to an end and will not look at changing any laws including the BEE Act and will leave this to the next parliament.

What are the positions of the major political parties?

None of the election polls suggest any party winning the super majority needed to change the Constitution and so the right to equality will remain as is.  But the winning party will be able to change the BEE Act.  When one looks at the main contenders’ election manifestos one gets an inclination of what the new parliament’s view on BEE will be.

A third of the 66 page ANC Election Manifesto deals with economic transformation and is the first policy addressed.  Nothing suggests that the party is considering scrapping the policy.

The 81 page manifesto of the current opposition also dedicates a third to the economy, and after public debate the DA agreed that “the approach to Black Economic Empowerment (BEE) as carried out by the ANC, which has only served to enrich a politically connected elite and to dampen economic growth, at the cost of job creation”.  So, should they be in a position to scrap the Act, what would they replace it with?  Their manifesto states “Empowerment approaches to provide meaningful redress which eventually realises socioeconomic justice. This approach must codify specific metrics which will signify successful redress (these could include measurables in terms of broader ownership, improved education and skills outcomes, improved entrepreneurial support etc.).  As these goals are achieved the need for this approach will fall away.”  This does not sound too dissimilar to the BEE Act other than it that states that the need should fall away.  We agree that should be the whole purpose of the Act.  But the DA goes on to state “Social protection measures which provide for all currently disadvantaged South Africans regardless of their, or their families’, exposure to past injustice.”  This will need to be assessed by the electorate, but in that disadvantages that translate to inequalities are still in the Constitution, how much would really change?

At 166 pages the EFF has the most to say in its manifesto.  The EFF seem in this respect to agree with the DA when they state “The few black people who participate in the economy, do so, subject to white approval through a black economic empowerment model that is ostensibly designed to benefit a small number of individuals without ever changing the structural exclusion of the majority.”  Theirs is a more aspirational document than the others and seeks the ideal of economic transformation which is more BEE if anything.

Why B-BBEE is here to stay:

Not one of these parties is calling for the BEE Act to be scrapped.  But there is an acceptance that BEE has problems.  This article is not to explore those.  We merely state that the Act is central to our objective of transforming South Africa.  Nobody has ever thought this could be achieved without some compromise and cost.  BEE is sometimes seen as the cost of transformation (we don’t believe it has to be a cost, contact us to learn how we do things) and even if this is true South Africa should focus on what it’s getting.  This goal was spelt in our world leading Constitution and its third generation rights.  This alone separates us from Namibia and Zimbabwe and for as long as it’s the Supreme Law of our land, it will be difficult to completely scrap BEE, but changes should be expected and they might well push harder for BEE rather than make it go away…As for foreign companies looking to invest here – we have a great solution for you too – please contact us.

How to calculate the return on investment from BEE

Is BEE about transformation? compliance? or could it be an investment that sets up a sustainable competitive for your business?

The lens you use to frame the problem is paramount to choosing the appropriate outcome and deciding if it’s worth the effort.

When it comes to transformation, most business owners we speak to understand the need to look after their black staff, suppliers and customers in some form. They understand the need to help transform our country. Many are happy with the transfer of a minority stake in the business (over time) to achieve this. There is a strong sense of looking after the stakeholders in the business as the ‘circle of influence’ and it’s a contribution that many are prepared to make, but it’s a minority stake and closely aligned to normal (i.e. non-BEE) employee shareholder scheme levels of ownership.

Those with a ‘compliance’ lens tend to spend just enough money on the scorecard to remain compliant. If they do any ownership, it’s a reluctant 25.1% deal, often using modified flow through. They’re compliant, but not aspirational nor strategic about BEE. They want the cheapest deal that gets them compliant and never give up control.

Those looking at BEE strategically – as an investment decision that can bring competitive advantage – quickly realise:

  • BEE is driven by your customers, not the government. Chances are your customers want their suppliers to be 51% owned to get the most points on their scorecard.
  • BEE is zero sum: either you do it or your competitors do. It’s a choice that creates winners and losers from within the same pot of money. It’s redistributive by design.
  • Ownership is the cheapest form of BEE – it enables EME/QSEs to get level 1 or 2 without spending on the rest of the scorecard, and for Generic companies (who must spend on all elements) ownership is the only way to get to the higher BEE levels.
  • It’s an investment decision: it’s much easier to transfer 51% or more of the business if you know you’ll make more money as a result.
  • It’s a control decision: astute business owners understand that control of investment decisions and the board is different to managerial control. Effective day to control can be maintained while transferring majority ownership, and negative control can be maintained on major board-level decisions.
  • There are variety of options/structures that can achieve this in different ways – they carry different costs and different risks. They must be assessed in terms of BEE compliance (letter and spirit of the Act), tax consequences (now and down the line), control, ROI etc. It’s a marriage, after all.

The most fundamental analysis, indeed the starting point, should always be working out what value BEE brings: 

So how do you do it?

Business valuation is about future earnings, discounted to today by the expected risk.

Doing a BEE deal should ideally increase earnings potential and reduce risk. Not doing a BEE deal may reduce earnings potential and increase risk (as is the situation many of our potential customers find themselves in). Remember than in business valuation terms,  even a small change in sales growth rates or a small reduction in risk (cost of capital) can make a major change to your valuation.

So how do we analyse the future earnings side?

Here is guide as to how to do it so that you can make more confident decisions:

  • Draw up a list of all your existing clients and prospective clients.
  • For each of them, make a column for existing and potential future products/services that you could sell to them.
  • For each of these, estimate how much you will sell to them if you do nothing, and how more you could sell to them at 25,1%, 51% or even 100% BEE ownership.
  • Do this for year 1, year 2, and all the way out to year 5. It gets fuzzy out there but force your mind to interrogate what is realistic.
  • Put a confidence level against each number – how certain are you to achieve these numbers
  • Sum the (totals*confidence) for each year. You now have a rough idea across 4 different ownership scenarios.
  • That’s the internal analysis. It’s a guess at best but forces you to think.

You now need to do the hard part: speaking to your customers.

Repeat the same exercise as above, but actually meet with your customers.

  • Have a confidential discussion with them.
  • Explain how you want to solve their problem (BEE procurement from quality customers they trust).
  • Ask them, if you got 25,1%, 51%, 100% BEE ownership levels then how much more business you would get?
  • Ask them to put a confidence level against their statement above i.e. force them to really think
  • Ask them what else (i.e. factors aside from BEE) you need to do to get more business. This is really important – it may be that you actually suck on service/price/quality but you think you’re not getting the work because of BEE. Or it may be you’re really good and it’s only BEE holding you back. Either way you learn and can improve.
  • Ask what happens if you do nothing about BEE – would your business really suffer?
  • by when?
  • Ask who else supplies them and what BEE level they have (they may not tell you exactly, but you’ll get a sense of how competitive it would make your business).
  • Maybe you can’t get much more business but they’ll offer you much more attractive payment terms? You need to push them and understand the difference here too. An extra 30 days cash can make a major difference to a business, and it’s often a concession they’re willing to make to BEE suppliers.
  • See how much you can get at different levels of BEE.
  • You also need to understand if their contracts with have any clauses relating to a change of ownership in your business. Many large, “strategic” contracts do have provisions for change of ownership – normally to do with takeover provisions – and you’ll want to understand if BEE ownership triggers any of this. It’s a potential business risk that your customers may not even be aware they’re forcing on you.
  • Repeat this with each customer. Maybe even different people from each customer, it depends how complex their business is, and how important they are to you. These conversations are great for building relationships, demonstrating intent, and growing your business so it’s never time wasted.
  • Add it all up as before.

Now you’ve got their guesses and somewhere between theirs and yours is the answer as to how much more your business could grow sales at different levels of BEE; from doing nothing to going 100% in. You’ll also know what other levers you can pull to grow your business.

You are now in a position to strategically choose the right level of BEE.

Lastly, remember that a small increase in sales or reduction in risk can make a massive difference to your valuation. You may find that a 51% deal is way more affordable than you think.

We have a very elegant solution to this complex problem where we can demonstrate how much your value can be expected to grow while you legitimately contribute to the future of SA. For help on how best to achieve that level, speak to us.