Updated: Sep 10, 2020
The South African National Accreditation System (SANAS) has published an updated version of the R47 -03 Accreditation of B-BBEE Rating Agencies. The R47-03 is said to be implemented on 7 October 2020.
The R47-02 was introduced in 2007 when the B-BBEE codes were originally gazetted. The R47, as it is commonly known, clarifies the roles of the B-BBEE Rating Agency and specifies the criteria by which they agency shall be accredited by SANAS on behalf of the Department of Trade, Industry and Competition (the dtic). The guideline is also used by SANAS to accredit B-BBEE Rating Agencies.
There are approximately 83 SANAS accredited agencies in South Africa at present, who are accredited to issue B-BBEE certificates. The R47 is not easily complied with. SANAS regularly inspects the methodology followed by a B-BBEE Rating Agency in the performance of B-BBEE verifications. SANAS also tests if the agency has a clear understanding and knowledge of all gazetted B-BBEE Codes of Good Practice inclusive of the B-BBEE Sector Codes of Good Practice and the Practice Notes.
The R47 -03 seeks to clearly establish that the B-BBEE Agency is 100% impartial and objective in their assessment, and ultimately in the issuance of the B-BBEE certificate.
This will create a verification that provides confidence. A B-BBEE Rating Agency must be able to demonstrate that its decisions are based on objective evidence and that its decisions have not been improperly influenced by other interests, or by other parties.
Scenario planning or Gap Analysis services will not be provided by an agency. The following threats to impartiality include, but are not limited to:
Self – interest threat – arising from a person or enterprise acting in their own interest i.e. financial self-interest.
Self-review threats – arising from a person or enterprise reviewing the work done by themselves, for example evaluating the B-BBEE compliance of a measured entity to whom the B-BBEE Rating agency provided consultancy.
Familiarity (or trust) threats – arising from a person or body being too familiar with, or trusting toward another person, instead of seeking impartial evaluation evidence on which to base the verification conclusion.
Intimidation threats – arising from a person or enterprise having a perception of being coerced openly or secretively, such as a treat to be replaced or reported to a supervisor.
As such documentation collation and the preparation of a portfolio of evidence will be key.
Your claim and proof should be prepared carefully and precisely, to ensure that the evidence is correctly interpreted, which will result in points being allocated fairly by the B-BBEE verification agency.
Being proactive and allocating sufficient time to complete this task is of the utmost importance!
Edrich Linde – Executive Consultant