It's official - Bernie says it is

There is one rule about blogging that no one will ever tell you about - and that is shooting from the hip.  You can create an immense amount of trouble for yourself by shooting your mouth off unnecessarily.

Before I start - I see that the Property Charter has been gazetted under section 12.  It was gazetted on the 5th of October, 2007 and has now found its way onto the DTI's website.

I have had some time to think about this post - and I've spoken to Bernard van der Walt as well.  I told him I'd be nice.  Here goes

Today many of us received this email.

BEE Update:  Self Ratings not valid

Spending money on suppliers who did self-assessment to compile their BBBEE scorecard does not count as BEE procurement spend on your scorecard. (Don't know where that English did come from - Bloem?)

According to a trade and industry department guideline (issued October 2007), self-assessed scorecards will not be recognised seeing that self-assessed scoring does not provide sufficient proof of a supplier's BBBEE status (Mail & Guardian, 13 February 2008).

Make sure that your suppliers provide you with official BEE verification documentation that is valid. BEE Rating Solutions is a full member of ABVA (Association of BEE Verification Agencies) and can provide valid scorecards to you and your suppliers.  In addition, we undertake to issue your scorecard within 48 hours for an Exempt Micro Enterprise (EME) and within 5 working days for a Qualifying Small Enterprise (QSE) or Generic verification once all supporting evidence has been submitted.

For more information visit our website at http://www.beeratingsolutions.co.za/ or contact
Bernard van der Walt at
Mobile:  082 885 0991
Phone:  0861 111 233(BEE)
Fax:  086 500 2270
Email:  [email protected]

Before I say that this is a lot of deceptive bullshit crammed into one email - I'll say this.

1. BEE Rating Solutions does not put a link to the article they refer to.  And this is a serious omission because the article does not state that self rating is unacceptable.
2. They fail to mention that this is still speculative - it is based on a document that the DTI published in October.  It seems as though this document remains a draft - it is incomplete in places.

Now back to the original article.  It was written by Barrie Terblanche who is a tireless campaigner for small businesses and their rights.  It is quite strange for Barrie to have taken the stance he has - he's almost lost the fight.  But he is very clear to point out that even though the document states "when an entity have recognised B-BBEE suppliers without sufficient verified proof (i.e. valid verification certificate), all such B-BBEE spend must be deducted from the calculated B-BBEE spend. For the avoidance of doubt, a supplier letter or a self-assessed scoring system does not represent sufficient proof of a supplier’s B-BBEE status. (Only B-BBEE suppliers with verification certificate are included in the calculation of B-BBEE spend)",  the DTI still doesn't  know what they want.   
When pressed on the issue,  (DTI) BEE official Takalani Tambane told the Mail & Guardian that a self-assessed score will be recognised if it is supported by evidence. A verification agency studying the supply chain of a company will have to find supporting evidence to back up the self-assessed scorecards of the company’s suppliers. 

This last paragraph is very significant - I have written about this before.  The codes are very clear that points will only be awarded if sufficient evidence is produced (statement 000, paragraph 2.6).  This doesn't matter who conducts the assessment. 

Admittedly this does place a larger burden of proof on a self-rated certificate but the verification document in no way precludes a company that assesses itself from producing this evidence on demand. 

Back to Bernard

BEE Rating Solutions did not send this email out without consulting the powers that be at ABVA.  And Theo himself said it was OK.  I do find this strange because after my call for Theo's resignation I was told that he is a very well respected person within the verification community.  But this is plain weird.  The email is factually incorrect because the document it is based on has no official backing and is not available on the DTI's website.  Therefore the words contained in the codes take precedence.  And they do not prescribe any type of verification.

I invite any reader to comment on this post - if I am speaking kak then correct me.  I'll publish it on this blog. 

Comments

[Kevin Lester]

Nice expose Paul. A client recently ran into problems with an (unnamed) ABVA member over a self assesment presented by a major supplier. The agency, predictably, disallowed the procurement spend.
My client was on the cusp of 65 points, so they naturally decided not to take no as an answer. After some very incoherent agency foot shuffling, a fax was sent to my client purporting to be an extract from a DTI approved document (the same text you reproduce above)!
My now immensely cross client phones the DTI for an explanation, After a little confusion, it suddenly emerges that the document in question has no DTI approval at all, its a work in progress off the desk of a team of largely unkown experts who appointed one another to create a set of verification standards. By close of business that day, client was disillusioned to the point of hopeless resignation and I had obtained three independent confirmations of the status of the document as having no DTI approval! Short moral, dont believe in DTI Logos.
Funny as this tale of deceipt and manipulation may be, these verification stanadards are very troubling. Take some examples:
1) Possibly ignorance, probabaly self serving arrogance results in the exposition of the rule on export exclusions under procurement being restated with a completely different meaning.
2) With nothing but arrogance at play, a diagram under enterprise development contains frankly embarrassing text to the effect the codes suggest one thing around recognistion of loans while in fact, we are told, the truth is three unanswered question marks. Of course, it is probably the case that SANAS has not included within their ISO standard for rating, that raters undertstand that rules are rules and dont suggest anything. wishfull interpretations about rules and what they suggest is what most people call opertunism.
3) The clearly self serving exclusion of self assesment needs noting
4) have a look a look at the silly attempts to define acceptable valuation standards under ownership.
In the end then, a bunch of wannabe racketeers writing their own rules and doing a pretty aweful job at it. Its shameful and gives credence to the arguements that ABVA and SANAS need to rethink their bloddy mindedness and gain some entrepreneirial ethics and maturity!