Skills development hacks for BEE scorecards

It's probably about time for me to start offering one on ones discussing the various BEE hacks that I have mastered over the last 18 years. If there is an interest please email me and we can look at a presentation.

It's no secret that I think the skills development code is the most ridiculous code of the lot, and that's saying a fair amount. I have mentioned before that the bursary requirement has been largely rejected by corporate South Africa. If it was we wouldn't be having the student process that appear at the beginning of each year.

However compliance with skills development is still a requirement. The trick is to go for the easiest and cheapest points to get to the subminimum. I'll start with the DTIC's generic scorecard

Large Enterprises – Skills Development. Total points – 25 (including 5 bonus points) – (PRIORITY)

Description

Weighting points

Compliance Target

 

Skills development expenditure on any programme specified in the Learning Programme Matrix for black people as a percentage of the leviable amount

Skills development expenditure on learning programmes specified in the Learning Programmes Matrix for black people as a percentage of leviable amount

6

3.5%

Skills development expenditure on bursaries for black people as a percentage of leviable amount

4

2.5%

Skills development expenditure on learning programmes specified in the Learning Programmes Matrix for black employees with disabilities as a percentage of leviable amount

4

0.3%

 

Learnerships, Apprenticeships and Internships

Number of black people participating in Learnerships, Apprenticeships and Internships as a percentage of number of employees

6

5%

 

Bonus points

Number of black people absorbed by the Measured and Industry Entity at the end of the learnership programme

5

100%

The most expensive points are the bursaries and skills development points. Old Slaptjips appears to be acutely aware of the bursary bollocks because he hasn't extended it to the other codes. This is the recommended approach I would take to get to the subminimum.

The trick lies in learnerships. There are many learning programmes out there but none as good as ours. What you want is to put 5% of your staff, subject to the EAP on a learnership. Our SMME Accelerator is an entrepreneurial requirement that will put the necessary numbers onto the learnership and learn how to become self-sufficient as small businesses. We aren't talking large amounts of learners here. There are your first six points. Now if you make sure that all of these people are disabled, which is absolutely possible for people on an entrepreneurship programme, then the spend on the learners talks to the disabled skills target, which is 0.3% of payroll. Then you take that spend and it may just give you a few points.

Let's take a fictitious example.

This is what Jones and Vusi's targets look like

Leviable amount

16 000 000

Skills Spend

560 000

Bursary Spend

400 000

Disabled skills target

48 000

Total Staff

240

Learners

12

You can't take 12 learners because of the national EAP (which we will use for this exercise). They'll have to take 15

EAP Representation

  

Target number

Actual Number

 

AM

45.89%

5.51

6.00

2.75

CM

6.54%

0.78

1.00

0.39

IM

2.14%

0.26

1.00

0.13

AF

38.56%

4.63

5.00

2.31

CF

5.64%

0.68

1.00

0.34

IF

1.24%

0.15

1.00

0.07

TOTAL

  

12.00

15.00

6.00

At an average cost per learner of R2600, which includes the stipend for a NQF2 learnership, you'll get the following over a 12 month period.

EAP Representation

Value over 12 months

AM

187 200

CM

31 200

IM

31 200

AF

156 000

CF

31 200

IF

31 200

TOTAL

468 000

If two of these people were disabled then you would get R62,300 towards your disability target of R48,000, which is not subject to the EAP you'll get the full four points for disability.

The balance of the spend will then go up to the skills target.

  

Modified EAP for points

Target spend per race group

Actual spend per race group

Score

AM

45.89%

256 956.03

187 200.00

2.0057

CM

6.54%

36 617.81

31 200.00

0.3343

IM

2.14%

11 995.49

31 200.00

0.1285

AF

38.56%

215 918.83

156 000.00

1.6714

CF

5.64%

31 567.08

31 200.00

0.3343

IF

1.24%

6 944.76

31 200.00

0.0744

  

100.00%

560 000.00

468 000.00

4.55

For 15 learners over 12 months that will effectively cost you nothing due to the tax deductions, this is what you are looking at for points.

Description

Weighting points

Points

 

Skills development expenditure on any programme specified in the Learning Programme Matrix for black people as a percentage of the leviable amount

Skills development expenditure

6

4.55

Bursaries

4

 

Disabled

4

4

 

Learnerships, Apprenticeships and Internships

Learnerships

6

5.59

TOTAL

 

14.55

That's the DTI's hack. Should cost you close to nothing if you are in a tax paying position. This is for most other codes (other than Construction, Transport and FSC).

I'll go with the ICT code because that's more refined than others (I shouldn't give it that much credit)

Description

Weighting points

Compliance Target

 

Skills development expenditure on any programme specified in the Learning Programme Matrix for black people as a percentage of the leviable amount

Skills development expenditure on learning programmes specified in the Learning Programmes Matrix for black people as a percentage of leviable amount (EAP)

8

6%

Skills development expenditure on learning programmes specified in the Learning Programmes Matrix for black people with disabilities as a percentage of leviable amount (EAP)

4

0.3%

 

Learnerships, Apprenticeships and Internships

Number of black people participating in Learnerships, Apprenticeships and Internships as a percentage of number of employees (EAP)

4

2.5%

Number of black unemployed people participating in training specified in the learning programme matrix as a percentage of number of employees (EAP)

4

2.5%

 

Bonus points

Number of black people absorbed by the Measured and Industry Entity at the end of the learnership programme (EAP)

5

100%

The ICT code is a bugger because of this clause

A Measured Entity must achieve a minimum of 40% of the total targets set out in each of paragraphs 2.1.1 and 2.1.2 of the Skills Development Element. This is the skills expenditure AND the spend. Therefore at a minimum you'll need 6 for skills spend and 4 for learnerships etc.

I want to start with the learnerships etc. The unemployed people requirement is something that's been missed out across the board. They talk about the ENTIRE training matrix. This means that it could go from Category A to G – we know that F and G are informal training.

Let's go back to Jones and Vusi Software (must be an ICT company)

Leviable amount

16 000 000

Skills Spend

960 000

Disabled skills target

48 000

Total Staff

240

Learners

6

Unemployed

6

We'll reduce the number of learners to 10 – because it'll give you full points for learnerships.

This is what your points will look like for the learnerships

EAP Representation

Target number

Actual Number

Score

AM

2.75

3.00

1.84

CM

0.39

1.00

0.26

IM

0.13

1.00

0.09

AF

2.31

3.00

1.54

CF

0.34

1.00

0.23

IF

0.07

1.00

0.05

TOTAL

6.00

10.00

4.00

You've already got half the points for this sub-portion. But why stop there. What you do is take the same number of people and put them on a category G programme for a day in your offices, or somewhere else. You teach something interesting about operating your business. You'll need to get registers, unemployment letters, ID copies and other POPI unfriendly documents. And bang you've got your next four points.

YOU CAN'T DO THAT – I hear you say.

Oh but you can. Paragraph 5.6 of STATEMENT AICT 300 says

"Skills Development Expenditure arising from Informal and workplace Learning Programmes or from Category F and G Learning Programmes under the Learning Programmes Matrix cannot represent more than 15% of the total value of SKILLS DEVELOPMENT EXPENDITURE.."

This has got nothing to do with expenditure, sure you can add the costs of that session to your expenditure at the top of the code, but I wouldn't bother it's too much of a schlepp. Also – there no requirement for the duration of the training. You could do an hour with 10 people as per the numbers below. Go on take four points.

EAP Representation

Target number

Actual Number

Score

AM

2.75

3.00

1.84

CM

0.39

1.00

0.26

IM

0.13

1.00

0.09

AF

2.31

3.00

1.54

CF

0.34

1.00

0.23

IF

0.07

1.00

0.05

TOTAL

6.00

10.00

4.00

Let's get on with the actual expenditure of the learnerships. The learnerships will all need to be disabled people, the ICT code is not as friendly as the DTIC's code when it comes to disabled people. Still you'll shoot the disabled target by a long shot.

Disabled

     

  

Modified EAP for points

Target spend per race group

Actual spend per race group

Score

AM

45.89%

22 024.80

93 600.00

1.8354

CM

6.54%

3 138.67

31 200.00

0.2616

IM

2.14%

1 028.18

31 200.00

0.0857

AF

38.56%

18 507.33

93 600.00

1.5423

CF

5.64%

2 705.75

31 200.00

0.2255

IF

1.24%

595.26

31 200.00

0.0496

  

100.00%

48 000.00

312 000.00

4.00

You're still two points away from the subminimum.

  

Modified EAP for points

Target spend per race group

Actual spend per race group

Score

AM

45.89%

440 496.05

93 600.00

0.7800

CM

6.54%

62 773.39

31 200.00

0.2600

IM

2.14%

20 563.70

31 200.00

0.1714

AF

38.56%

370 146.56

93 600.00

0.7800

CF

5.64%

54 114.99

31 200.00

0.2600

IF

1.24%

11 905.30

31 200.00

0.0992

 

100.00%

960 000.00

312 000.00

2.35

And here's your score

Large Enterprises – Skills Development. Total points – 20 (plus 5 bonus points) – (PRIORITY)

Description

Weighting points

Score

 

Skills development expenditure on any programme specified in the Learning Programme Matrix for black people as a percentage of the leviable amount

Skills development expenditure

8

2.35

Disabled skills development expenditure

4

4

 

Learnerships, Apprenticeships and Internships

Learnerships, Apprenticeships and Internships

4

4

Black unemployed people participating in training specified in the learning programme matrix

4

4

TOTAL

 

14.35

The two subminima have been met and once again this is all tax deductible. In fact because you have put disabled people on the learnership you get more money back.

As to whether Slappie gets to change the codes that remains to be seen. He's actually useless. Not up there with bolshie bob, bolshie was a different waste of privileged private school space. Bolshie did stuff. Slaptjips doesn't do much except ban hot food.

Oh Cyril, what the hell have you given us, we've fucking had enough now.

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