(Please note that bloody TypePad makes it almost impossible to post tables. I've had to post them up here as a seperate file).
This post started out as an open letter to the DTI and the drafters of the new bill and the impending codes. It is too early to respond in any emotive way because anything I say would be far too speculative. However the three points below are easily gleaned from that infamous presentation.
EMEs
Is it fair and equitable to elevate black owned EMEs to a level 2 and level 1 as the case may be? This would provide a 100% black-owned EME (or 50% black women-owned EME) with an eight point advantage of a non-black owned EME in an 80/20 tender or five points in a 90/10 tender. What would section 217 of the constitution say? Would this not destroy numerous legitimate businesses that employ black people because they may never get a chance to win a government contract?
Management and employment equity
Degrees of blackness is rapidly becoming government policy. Interestingly, it's still not too bad to be a whitey in this economy, but Coloureds and Indians ought to be very concerned. The ridiculousness of the EAP targets (national targets to boot) is shown below. It is not necessary to work on the whole element, the board requirement amplifies the folly. I applied this formula into the FirstRand board. TheFirstRand annual report tells us that the company has 19 directors, 3 of whom are executive. I love the fact that for 0.14 points, the board would need 0.0324% of an Indian male on their board – would his foot be acceptable? Proper table is here.
|
Criteria |
Points |
Targets |
African Male |
Coloured Male |
Indian Male |
African Female |
Coloured Female |
Indian Female |
|
Required percentage per category |
|
|
0.6918 |
0.1026 |
0.0324 |
0.5655 |
0.0855 |
0.0222 |
|
2.1.1 Black Executive Directors |
2 |
50% |
23.06% |
3.42% |
1.08% |
18.85% |
2.85% |
0.74% |
|
Points value for this requirement |
|
|
0.92 |
0.14 |
0.04 |
0.75 |
0.11 |
0.03 |
What we do see here is that the greatest number of points can be gained by only employing African males and females – to be specific 1.68 points out of the available 2 points (84%) would be awarded if they only employed the directorial services of those people. Why bother with the others, as it is anyway boards are getting smaller. This is an obvious attempt to squeeze out the services of people like Marcel Golding, Cheryl Carrolus, Mustag Brey, Frene Ginwala etc (forgive me Cheryl but I've always thought of you as coloured).
Skills development
Once again the proposed codes require spend to be based on national EAP statistics. Back to FirstRand, their annual report tells us the following
|
Total payroll |
6 733 333 333 |
|
3% of payroll |
202 000 000 |
|
ACI employees (they don't specify a gender or breakdown into race) |
21517 |
|
Target spend (6% of payroll) |
404 000 000 |
|
Ave spend per ACI |
18 775.85 |
Back to FirstRand. The last line in the table below show the required spend per person per race grouping (actually it doesn't the full table is here)
|
Criteria |
Points |
Target |
African Male |
Coloured Male |
Indian Male |
African Female |
Coloured Female |
Indian Female |
|
1.1.1 Skills Development Expenditure on Learning Programmes specified in the Learning Programme Matrix for black people as a percentage of Leviable Amount |
6 |
6% |
2.77% |
0.41% |
0.13% |
2.26% |
0.34% |
0.09% |
|
Required spend |
1 865 133.33 |
276 066.67 |
87 533.33 |
1 521 733.33 |
228 933.33 |
60 600.00 |
Hmmm….. so FirstRand could get five of the six points by just focusing on Africans – why bother with the others! Food for thought – I can only imagine how devoid of logic the new codes are going to be.
Food for thought indeed.