Our policy statement
EXECUTIVE SUMMARY
We strive to meet our clients’ expectations of excellence by providing highly professional services, timely and efficiently at competitive market related fees.
We do not treat our clients as just another entity to be verified. Our objective is to foster long-term relationships with our clients based on trust and credibility.
We have implemented and strive to maintain management structures based on the requirements of SANAS R47 to ensure that our verification analysts and verification committee members remain objective, independent, fair and open-minded, producing credible and reliable B-BBEE verification results. We treat our clients’ information with the strictest confidence. Only the verification team assigned to a particular client’s verification, have access to that client’s information.
BEE Empowered and Labour Consultancy CC is a Level Four Contributor to Broad-based BEE with a 100% BEE Procurement Recognition Level. We support various community projects aimed at the upliftment and empowerment of women and children in rural areas.
BEE EMPOWERED AND LABOUR CONSULTANCY CC
FULL POLICY STATEMENT
BEE Empowered and Labour Consultancy CC is an independent Cape based verification agency that conducts verifications of small to medium enterprises across all sectors, countrywide.
We strive to meet our clients’ expectations of excellence by providing highly professional services, timely and efficiently, at competitive market related fees.
Our relationships with our clients are based on trust and mutual respect.
We have extensive up to date knowledge of BEE legislation and the verification processes involved.
Our implemented management system is based on the requirements of SANAS 47. We have implemented a Management Review procedure and an Internal Audit procedure to ensure that we continue to carry out our activities in accordance with our management system to enable us to continue to achieve our company’s key objectives, i.e. to produce objective, accurate and credible verification results.
We have structures, policies and procedures in place to ensure that all our internal and external verification personnel are familiar with our processes and procedures, are trained, competent and skilled and impartial towards the entity that they are assigned to. We treat our clients’ information with the strictest confidence and have implemented a Control of Records procedure to ensure that the confidentiality and integrity of our clients’ information is maintained.
BEE Empowered and Labour Consultancy CC is a Level Four Contributor to Broad-based BEE with a 100% BEE Procurement Recognition Level. We support various community projects aimed at the upliftment and empowerment of women and children in rural areas.
BEE Empowered and Labour Consultancy CC is a full member of the Association of Verification Agencies and Lizette Frank, our managing member, is a director on ABVA’S Board of Directors.
The Code of Conduct provides a framework for BEE Empowered and Labour Consultancy CC’s values and ethical standards. The following principles must be applied in our day-to-day business:
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All decisions and actions must conform with all applicable laws, regulations and Corporate policies.
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Business must only be secured for BEE Empowered on the basis of our belief in competitive market systems and the appropriateness of earning profit by providing our customers with efficient service.
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Economic substance alone is not justification for originating a transaction. It must be evaluated in the light of comprehensive knowledge of our client’s business and of the transaction’s purpose.
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Commercial, financial and other pressures shall not compromise our impartiality.
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Individuals must be honest and trustworthy in all actions and relationships for, on behalf of BEE Empowered.
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Situations where personal interest conflict, or appear to conflict, with the interest of BEE Empowered or its clients, must be avoided.
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The result of each action or decision must be fair and even-handed to all parties to the transaction or event, in the short- and long-term.
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Each decision or act must be proper, in terms of both our own sense of integrity and the scrutiny of others. Is should seem appropriate even if published in a major newspaper.
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Human dignity must be respected in all our dealings with others.
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Communications must be honest and accurate. Confidentiality must be maintained where appropriate.
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Ethical conduct should be recognised and valued by all employees and external personnel of BEE Empowered.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC, shall display internally a positive commitment to all seven elements of the relevant indicators of the broad-based BEE scorecard as contained in the B-BBEE Codes of Good Practice, issued under section 9(1) of the Broad-based Black Economic Empowerment Act, 2003. We shall endeavour to meet the current compliance targets pertaining to all seven elements of the B-BBEE scorecards and to meet the general requirements of a verification agency as set out in SANAS 47, clause 11.
We shall be seen as being both factual and perceptually independent from our measured enterprises, and shall avoid any circumstances that give rise to, or may potentially give rise to, a conflict of interest between various entities. Should such a circumstance arise, we shall disclose the full nature of the conflict of interest to all parties concerned and no verification shall be done. We shall require the measured enterprise to obtain the services of another verification agency under such circumstances.
Our members shall not hold an equity share, or have any voting rights, in an entity to be verified. Members may however have a minority interest or listed share/s where the total shareholding does not constitute a substantial shareholding when compared with the total number of shares issued by the measured enterprise. The materiality of such a financial interest shall be evaluated to ensure that our independence is not impaired. We shall disclose to the dti in accordance with sound corporate governance principles any material financial interest that we may have in an enterprise to be verified.
BEE Empowered shall not enter into a debt-creating agreement with a prospective client if such an agreement factually encumbers, or is perceived to encumber us in the execution of our professional discretion and objectivities towards the B-BBEE assessment of the said client, unless it is the normal business for the said client to provide such services and it is entered into under conditions not more favourable than those provided to the general public at large.
Our clients shall be required to enter into a legally enforceable Verification Agreement with us, prior to us conducting the client’s verification. The rights and obligations of both parties shall be clearly defined in the aforementioned Verification Agreement. We shall retain authority and shall be responsible for our decisions relating to the BEE Verification.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall be committed to and shall demonstrate its commitment to impartiality in our BEE verification activities, especially through our top management structures. We understand the importance of impartiality when managing conflicts of interest as it ensures our objectivity when carrying out our BEE verification activities.
We shall identify, analyse and document the possibilities for conflict of interest arising from the provision of our services, including any conflicts arising from our relationships. If any relationship poses a risk to our impartiality, we shall document how we have (or intended to) eliminated or minimized such a risk to an acceptable level. Should we not be able to eliminate or minimize such risk, we shall terminate the relationship. We shall require our personnel to declare and disclose any prior association with any enterprise they may be assigned to evaluate.
We shall ensure that the activities of other related bodies do not affect the confidentiality, objectivity and impartiality of our activities. We shall avoid any situation where the activities of another body could create a conflict of interest.
We shall implement measures to prevent a consultancy body from stating or implying that a verification by BEE Empowered will be simpler, faster or less expensive if our services are engaged. Similarly, we shall not state or imply that the BEE verification will be simpler, faster or less expensive if a specified consultancy body is used.
We shall not provide any other services, which could compromise the confidentiality, objectivity and impartiality of our verification activities.
We shall implement and maintain procedures and structures whereby the composition, terms of reference, duties, authorities and responsibilities of any committee involved in the verification process shall be documented and authorised by our top management to ensure representation of a balance of interest such that no single interest predominates, and that such committees shall have access to all the information necessary to enable it to fulfill its functions.
All our verification personnel, internally and externally, as well as committees that could influence the verification activities, shall act impartially and shall not allow commercial, financial or other pressures to compromise their impartiality.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall implement Control of Records procedures to ensure the confidentiality and integrity of our clients’ information, obtained or created during the performance of verification activities, at all levels of our structure, including verification committees and external bodies or individuals acting on our behalf. We have furthermore entered into legally enforceable agreements with our internal and external verification personnel, including internal and external committees and bodies, to ensure that the confidentiality and integrity of our clients’ aforementioned information is maintained.
BEE Empowered and Labour Consultancy CC shall inform the verified enterprises, in advance, of the information it intends to place in the public domain. All other information, save for information that is made publicly available by the client, shall be considered proprietary information and shall be regarded as confidential. Information about a particular client, or individual, shall not be disclosed to any third party without the written consent of that particular client, or individual, concerned. Should we be required by law to release confidential information to a third party, we shall notify the measured enterprise or the individual concerned, unless prohibited by law, in advance of the information provided. Information about the measured enterprise from sources other than the measured enterprise itself (e.g. complaints, regulators) shall be treated as confidential.
We shall have available and shall make use of equipment or facilities that ensure the secure handling of confidential information (e.g. documents, records, etc). When confidential information must be made available to other bodies, i.e. SANAS and the dti, we shall inform our verified clients of this action.
POLICY STATEMENT
Our organizational structure shall be such as to give confidence in our activities.
We shall identify our top management who shall be responsible for the development of policies relating to our operations, supervision of the implementation of the policies and procedures, supervision of the finances of the body, supervision of the performance of evaluations and verifications, BEE verification decisions, delegation of authority to committees or individuals, as required, to undertake defined activities on our behalf and to provide adequate, qualified resources for our activities.
Our overall organizational structure shall be documented, showing the duties, responsibilities and authorities of management, other verification personnel and any committees. We shall implement formal rules for the appointment, terms of reference and operations of any committees that are involved in the verification process.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall establish, implement and maintain a management system in accordance with SANAS 47, appropriate to the conducting of B-BBEE verifications.
We shall document our policies, procedures and instructions to the extent necessary to assure accurate, objective and reliable verifications. Management shall review our management system at regular intervals to ensure that corrective action is taken as soon as they identify non-conformities or departures from our managements system to enable us to continue to meet our key objectives within our organisation, i.e. to deliver accurate, objective and reliable verifications.
POLICY STATEMENT
We have implemented a procedure to ensure that all authorised editions of appropriate documents of internal or external origin, are available at all locations where operations are performed, that documents are periodically reviewed, and where necessary, that they are revised and that obsolete documents are promptly removed from all points of issue. This procedure will ensure that all documents that form part of our management system are current, valid and duly authorised.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall implement and maintain a procedure to maintain records on the audit and verification process of all its measured enterprises, including all entities that submitted requests for verification, and all entities verified.
All internal and external personnel shall adhere to our implemented Control of Records procedure to ensure that the confidentiality and integrity of our clients’ information is maintained.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall implement and maintain a procedure for receiving, evaluating and making decisions on appeals. We shall be responsible for all decisions at all levels of the appeal-handling process. All appeals shall be resolved in a timely manner. We shall furnish the appellant with a formal notice of the end of the appeal-handling process. Appeal decisions shall be made by an individual not involved in the matter that is the subject of the appeal.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall ensure that all types of complaints received from whatever source are recorded, properly investigated and resolved timely and effectively. A procedure has been established to outline the process of handling and resolving complaints.
The person investigating a compliant shall be completely independent from the complaint or the activities surrounding the complaint. Trends on the nature of complaints shall be analysed on a continuous basis and used to improve our management system, client services, verification activities and processes.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall implement and maintain procedures that would enable us to periodically, and in accordance with a predetermined schedule and procedure, conduct internal audits of our activities to verify that our operations continue to comply with the requirements of our management system. Our internal audit programme shall address all elements of the verification process/system, including verification activities. Trained and qualified personnel, who are, whenever resources permit, independent of the activities to be audited, shall carry out such audits.
When audit findings cast doubt on the effectiveness of our operations, we shall take timely corrective action and shall notify our verified clients in writing if investigations show that their verifications have been affected. We shall record the area of activity audited, the audit findings and the corrective actions that arise from them. Where we have implemented corrective action, a follow-up audit shall be carried out to verify and record the implementation of the said corrective action implemented.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall establish, implement and maintain a procedure and shall designate appropriate authorities for implementing corrective action when departures from policies and procedures in our management system or verification processes have been identified.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall implement and maintain a procedure in terms of which our top management shall be responsible to review our management system, including information on relevant complaints and appeals from users of our verification services, in accordance with a predetermined schedule.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall require an authorised representative of the enterprise requesting verification to complete a Request for Verification form, furnishing us with sufficient detail in order to inter alia determine whether or not we have the necessary competence and ability to perform the requested verification services.
The determining factor for accepting or rejecting a requesting enterprise’s Request for Verification shall be whether or not we have the competence and ability to perform the verification of the requesting enterprise. To determine whether we have the competence to verify the requesting enterprise, factors such as the location and number of the requesting enterprise’s operations, the time required to complete verifications, the number of verification analysts we have available to attend to the verification, and any other factors, for example language, safety conditions, threats to impartiality etc, which may influence the activities or the verification process shall be considered. Records of our reasons for accepting or rejecting a requesting enterprise’s Request for Verification shall be maintained.
POLICY STATEMENT
Upon receiving an enquiry about our verification services, we shall furnish our prospective client with sufficient information regarding the requirements of BEE Verification, their rights and obligations in respect thereof, the rights and obligations regarding their use of their verified BEE status in communications of any kind, information about our fees, the process involved in obtaining a BEE Verification, as well as information on the procedure for handling complaints and appeals.
By providing our prospective clients with the aforementioned information, we shall ensure that there exists no misunderstanding between us and the said prospective client and that both parties are fully aware of their rights and obligations in the BEE Verification to be carried out.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall ensure that it has a process for selecting and appointing verification analysts, including the verification team leader, that are competent after having taken into account the objectives of the verification that needs to be met. Verification analysts, including the team leader, shall be impartial and objective at all times.
The client enterprise shall be verified in accordance with a Verification Plan. The Verification Plan shall be communicated and the dates of the verification shall be agreed upon with the client enterprise prior to the on-site verification. On-site verifications procedures shall be documented.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall verify, evaluate and validate information obtained from the measured enterprises based on the principles encapsulated in the B-BBEE Codes of Good Practice, issued under Section 9(1) of the Broad-based Black Economic Empowerment Act, 2003 (Act No. 53 of 2003) and shall include all relevant elements of the broad-based BEE Scorecard.
All verifications shall be based on information that has been verified by an on-site verification to the measured enterprise in order to reach its opinion on the BEE status of a measured enterprise.
POLICY STATEMENT
The Verification Team appointed by BEE Empowered and Labour Consultancy CC shall carry out verifications in accordance with a Verification Plan at the site(s) of the measured enterprise. The purpose of such verification shall be to gather evidence to measure the enterprise’s B-BBEE progress or status. The Verification Team shall rate a sufficient number of examples of the activities of the enterprise in relation to the B-BBEE criteria to arrive at a sound appraisal of the enterprise’s BB-BEE status. As part of the verification process, the Verification Team shall interview a sufficient number of staff, including top management and operational personnel of the enterprise, to provide assurance that the information gathered is sound.
The measured enterprise shall receive a copy of our On-Site Verification Report after the Verification Team has analysed all the information and verified the gathered information. We shall retain ownership of the On-Site Verification Report.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall develop, implement and maintain procedures and structures to ensure that the person(s) and or verification committee members responsible for verification decisions shall have a level of knowledge and experience sufficient to evaluate the verification process, results and recommendations of the verification team.
BEE Empowered and Labour Consultancy CC shall ensure that the person(s) or committee members that are responsible for the verification decision are different from those who carried out the verification.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall provide to its measured clients, by any means it chooses, a B-BBEE Verification Certificate that shall identify the name and identifiable physical location(s) of the measured enterprise, the company registration number, the company’s VAT registration number, the dates of granting of the B-BBEE score and the period of validity, the expiry date of the Verification Certificate, the unique identification number, the standard and or normative document, including the issue and or revision used to evaluate the client, our name and or mark and or logo, the Broad-based BEE Status level, the SANAS logo (after we have been accredited) and the overall B-BBEE Procurement Recognition level of the measured enterprise, as well as the B-BBEE Status level of each of the seven elements. We shall ensure that the effective date of the Verification Certificate shall not be a date before the B-BBEE Score was decided.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall ensure that all internal staff members, as well as external verification analysts utilized from time to time, have access to up-to-date knowledge relevant to B-BBEE criteria.
We shall determine the competence required (including experience and level of training), and where applicable, we shall determine any other qualification requirements for demonstrating competence prior to authorization to carry out specific functions. In determining the competence requirements of our verification personnel, we shall address the functions undertaken by management and the administrative personnel in addition to the functions of those who perform evaluations and verification functions directly.
We shall have access to the necessary expertise for advice on matters relating to B-BBEE verifications. Such advice may be provided by internal and external experts.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall, irrespective of the use made of external or temporary resources, have, as part of its own enterprise, personnel having competence to manage the BEE verification process. We shall employ or have access to a sufficient number of competent verification analysts and verification managers. All internal and external verification personnel shall receive clear instructions concerning his or her duties, responsibilities and authority.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall require external verification analysts and experts to enter into a written agreement by which they commit themselves to comply with the all our applicable policies and procedures. The agreement referred to herein, shall address aspects of confidentiality and independence from commercial and other interests, and shall require from them to notify us of any existing or prior association with any entity that they may be assigned to evaluate.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall develop, implement and maintain a procedure to maintain records of the relevant qualifications, training experience and competence of each person involved in the verification process. We shall furthermore maintain up-to-date records of the affiliations and professional status of all external verification analysts and external experts.
POLICY STATEMENT
After having analysed our relationships with other verification agencies for the possibility of conflict of interest, we made it our policy that we will not outsource any of our verification activities as we believe a conflict of interest that may arise should an employee of another verification agency carry out any of our verification activities whilst employed by another verification agency. We further believe that outsourcing could pose a high risk to our obligation to maintain the confidentiality and integrity of our clients’ information.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall conduct evaluations of entities at short notice in order to investigate complaints or in response to changes. In such instances, we shall describe and make known in advance the conditions under which these short-notice visits are to be conducted. As the enterprise to be evaluated shall not have an opportunity to object to the verification team, special care shall be taken in the selection and appointment of the verification team.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall maintain and provide, upon request, information about its activities to SANAS. The information we provide to any verified enterprise or to the marketplace, including advertising, shall be accurate and not misleading.
We shall make information about the B-BBEE Status level granted to any of the measured enterprises that we have verified, available on our website.
On request from SANAS, and/or the measured enterprise, we shall provide means to confirm the validity of a given B-BBEE Score granted.
We shall provide to the dti, upon completion of every verification, the BEE status level of the measured enterprises. We shall maintain and make available to the dti a current directory of valid Verification Certificates which shall show the name and identifiable physical location(s) of the measured enterprise, the company registration number and VAT registration number of the measured entity, the dates of granting of the BEE score and the period of validity, the expiry date of the Verification Certificate, the unique identification number, the standard and or normative document, including the issue and or revision used to evaluate the client, our name and or mark and or logo, the Broad-based BEE Status level, the SANAS logo (after we have obtained accreditation) and the overall B-BBEE Procurement Recognition level of the measured enterprise as well as the B-BBEE Status level of each of the seven elements.
POLICY STATEMENT
BEE Empowered and Labour Consultancy CC shall allow its measured entities to use its authorised mark “roundel”, provided such measured entities conform to our requirements when making reference to its verification status in communication media such as the internet, documents, brochures or advertising.
In circumstances where measured enterprises make use of any misleading statements regarding their B-BBEE Score, or where they use their B-BBEE Verification Certificate, or any part thereof, in a misleading manner, we shall retain the right to withdraw their B-BBEE Verification Certificate with immediate effect.
We shall furthermore retain the right to withdraw a measured enterprise’s B-BBEE Verification Certificate if the said measured enterprise used its verification status in such a manner that would result in BEE Empowered and Labour Consultancy cc losing public trust or that would bring our company into disrepute.
The Verification Certificate shall remain our property and measured entities shall reproduce its Verification Certificate only in full. We shall reserve to take action against measured entities should they make inaccurate or incorrect references to their B-BBEE Status Level.
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