THE
BEECHAMBER
Enhanced Recognition WHAT DOES IT MEAN?
2021
Amended General B-BBEE Codes of Good Practice
Enterprise & Supplier Development
Enhanced Recognition WHAT DOES IT MEAN?
According to the Generic Codes of Good Practice (Codes), a
Qualifying Small Enterprise (QSE) is an organisation with an annual
turnover of between R10m and R50m. However, there are two
categories for QSEs based on the ownership structure.
A QSE that has:
> Less than 51% ‘Black’ Ownership must be measured
against the QSE Scorecard by a SANAS accredited
B-BBEE Rating Agency.
> More than 51% ‘Black’ Ownership can claim Enhanced
Recognition, thus only has to confirm its Ownership and the
annual financial total revenue in an Affidavit.
There are only two Status Level categories a QSE with Enhanced
Recognition can fall under:
> At least 51% ‘Black’ Ownership equates to a Status Level 2
with a corresponding Preferential Procurement Recognition
level of 125%.
> 100% ‘Black’ Ownership equates to a Status Level 1, with
a corresponding Preferential Procurement Recognition
level of 135%.
It is, therefore, understood that a QSE with Enhanced Recognition
does have leverage over its counterparts that have less than 51%
‘Black’ Ownership. Consequently, a QSE with Enhanced Recognition
must qualify to claim this status. B-BBEE Credentials in the form of
an Affidavit confirm that a QSE with Enhanced Recognition is indeed
entitled to claim this status. The information captured in an Affidavit
confirms its annual turnover and Ownership status by applying the
‘Flow-Through’ Principle (FTP).
> Confirming annual total revenue
The latest financials produced by QSEs confirm whether or not
they qualify to be measured under this threshold.
> Confirming Ownership
Confirming Ownership against the scorecard is not always cut
and dry when applying the FTP. It was introduced to trace and
measure the chain of Ownership until it ultimately ends in the
hands of a ’Black’ natural person. It traces ‘Black’ Participants
that own a business through the shareholding in another
business. It essentially identifies the overall percentage of ‘Black’
Ownership through a chain of Ownership. To mitigate any
risk, a B-BBEE Rating Agency may require further evidence to
substantiate that the FTP has been correctly applied.
The FTP concept was introduced to encourage organisations to
change their procurement patterns and focus on procuring from
‘Black’-owned businesses with more than 51% ‘Black’ Ownership.
Apart from the favourable Preferential Procurement Recognition, an
organisation can apply a 1.2 multiplier for every Rand spent. It means
that for every R100,00 paid on an invoice, R120.00 can be claimed in
Procurement Recognition.
Other benefits for QSEs with Enhanced Recognition
A QSE with Enhanced Recognition qualifies as an Enterprise
Development and Supplier Development Beneficiary. By design,
QSE’s with less than 51% ‘Black’ Ownership and Large Enterprises
are encouraged to engage with QSEs with Enhanced Recognition to
earn points on their scorecard.
All sub-elements of Enterprise & Supplier Development, namely
Preferential Procurement, Enterprise Development and Supplier
Development, play a part in Large Enterprises and QSEs with less
than 51% ‘Black’ Ownership meeting their scorecard requirements.
The core aim is to encourage larger businesses to grow the footprint
of smaller ones over a given financial period.
A QSE with Enhanced Recognition is in a position to receive the
following assistance from a Large Enterprise or QSE with less than
51% ‘Black’ Ownership:
> Direct cost related to a specific cost object, such as stock
purchases.
> Overhead costs – those associated with the day-to-day
operations of a Beneficiary.
> Discounts.
> Loans and related costs:
o Interest-free loan;
o Standard loan;
o Guarantees on behalf of the QSE with Enhanced
Recognition; and
o Loans at lower interest rates.
> Equity Investments: o Minority investments; and o Investments with a lower dividend to the financier. > Human Resource Contributions: o Professional Services rendered at no cost to QSEs with Enhanced Recognition; o Professional Services rendered at a discounted rate to QSEs with Enhanced Recognition; and o Time spent by employees of a QSE with less than 51% ‘Black’ Ownership productively assisting a QSE with Enhanced Recognition. > Shorter payment terms for Supplier Development Beneficiaries.
Enhanced Recognition Sector Codes
Construction Sector Code
The financial threshold for a QSE with Enhanced Recognition per
annum is between R6m and R25m
Full points, excluding the Bonus Points for Skills Development as
per paragraphs 1.1, 1.2 and 1.3 of Statement CSC603. A QSE with
Enhanced Recognition must achieve:
> 40% of the Skills Development Scorecard target to avoid the
application of the Discounting Principle;
> Or meet the requirement of Supplier Development, which
features in paragraphs 1.1, 1.2, 1.3 and 2.1 of CSC604.
Tourism Sector Code
The financial threshold for a QSE with Enhanced Recognition per
annum is between R5m and R45m per annum.
Transport Sector Code
The amendments to this sector code do not align with the 2019
amendments to the Codes; therefore, it does not recognise
Enhanced Recognition. In conclusion, over the past few years, I have seen many fake
Affidavits and ones not signed by a Commissioner of Oaths on
the same day, which renders them invalid. Affidavits as B-BBEE
Credentials are here to stay and must be taken at face value unless
there are apparent discrepancies. As a SANAS accredited B-BBEE
Rating Agency, we have to mitigate risk continuously. The
Affidavits can pose a huge risk to the verification process.
Enhanced Recognition is a huge advantage for smaller businesses
and may contribute to their growth. However, with no regulator for
Affidavits, the onus is on the owner, member or director signing
the Affidavit to be truthful.