Compensation for Occupational Injuries and Diseases Amendment Bill & Employment Equity Amendment Bill: public hearings
NCOP Trade & Industry, Economic Development, Small Business, Tourism, Employment & Labour
22 February 2022
Chairperson: Mr M Rayi (ANC, Eastern Cape)
Various organisations were invited to the meeting and presented concerns on the amendments of the Employment Equity (EE) Amendment Bill and the Compensation for Occupational Injuries and Diseases (COID) Amendment Bill. They shared their concerns, however deliberations did not take place, as they were scheduled to take place on 15 March 2022. Questions for clarity were asked and accordingly responded to.
Business Unity South Africa (BUSA) presented on EE Bill. During its submission, BUSA paid attention to the numerical targets that are set to constitute an absolute barrier or quota and how that would fall foul of s15(3) of the Employment Equity Act. BUSA, through its submission, highlighted how the consequences of not meeting sectoral targets would eliminate organisations from transacting with the state and destroy revenue lines, resulting in liquidation and job losses. It was further pointed out that the criterion that an employer should not have had any unfair discrimination findings from the Commission for Conciliation, Mediation and Arbitration (CCMA) in the last 12 months is irrational. BUSA expressed that to accept the current Bill as it is, would likely lead to constitutional challenges and disputes.
BASA focused its presentation on s15, s15A(3) and s15A(4) and it was of the view that sector targets should be set nationally and not differentiated by region. It felt that if regional targets were applied, businesses with a national footprint would have to comply with multiple sets of targets which would result in a considerable burden in terms of restructuring, managing and monitoring the compliance requirements for businesses that operate nationally. BASA also made the Committee aware of concerns that it has regarding the issue of bonds and how that may present a difficulty for a bank if it has failed to meet its target within the five-year period and has a regulatory finding against it. BASA recommended that the process to set targets should be consultative, transparent and that the Minister should consult with individual sectors before setting targets to ensure that targets were sector-specific.
The Financial Intermediaries Association of Southern Africa (FIA) said that it had not been consulted in terms of the setting of targets under the EEA Bill. And was of the view that the consultation thus far did not meet consultation requirements set in s15A(2) of the Employment Equity Act (EEA). As a result, it said that it did not agree to any targets set outside of the required consultative process. The FIA went on to express that the National Council of Provinces (NCOP) should endorse the approach of setting appropriate targets per sector (or sub-sector) taking regional demographics into account. The absence of input from the NCOP will result in national government and the Minister making laws and regulations without considering unique provincial and regional dynamics.
The Black Business Council in the Environment (BBCE) expressed that it supports the amendments and the Association for Savings and Investment South Africa (ASISA) and South African Insurance Association (SAIA) elaborated that the compliance has to be considered in respect of general compliance in terms of section 42 and a certificate of compliance in terms of section 53.
The Master Builders Association South Africa expressed concerns about the determination of numerical sectoral targets saying that the section is silent on the need for consensus between the Minister and economic sectors in determination of numerical targets, which demonstrates adequate consultation and is crucial to setting and achievement of any targets set. In terms of the amendments of S53, the MBSA proposed that a compliance period of no less than the minimum required for completion of an occupational qualification dominant for each sector should be included in the definition of acceptable reasonable grounds for failure to qualify
In the discussion, it was proposed that s15 should be taken out entirely as it would not pass on a national level. There was also a question about the constitutionality of s15(3). The Committee also raised a concern regarding the digitisation of banks and how this has led to unemployment. It was suggested that there be a special session with the banking association to deal with issues of banking beyond the traditional banks. It further asked the FIA to provide clarity around s 53(6) (b) in respect of any target that an employer had not complied with, and how the employer had to raise reasonable reason for non-compliance. The Committee also asked why none of the organisations were speaking to the amendments to the COIDA Bill.
The Chairperson welcomed all present to the meeting and made a request that the submissions should be followed by questions of clarity and that no discussions were to take place, as the Department of Labour would make presentations on 8 March 2022 and thereafter deliberations will take place on 15 March 2022. An apology was received from Ms B Mathevula (EFF, Limpopo).
Submission by Business Unity South Africa: Employment Equity
Mr Kaizer Moyane, Vice Chairperson, Business Unity South Africa (BUSA), thanked the Committee for meeting with BUSA and the opportunity to deliver its presentation. He took the Committee through the presentation (see attachment), and highlighted further points.
Mr Moyane pointed out that if the numerical targets, which are set, constitute an absolute barrier or quota, the opportunity to bid for government work would fall foul of s15(3) of the Employment Equity Act (EEA). The consequences of not meeting the sectoral targets would eliminate organisations from transacting with the state and destroy their revenue lines, resulting in liquidation and job losses. The same consequence would apply to any company exercising its rights to appeal the findings of the Inspector, should they choose to do so, as they will have no certificate during such appeal period either.
The criterion that an employer should not have had any unfair discrimination findings, from the Commission for Conciliation, Mediation and Arbitration (CCMA) or Labour Court in the last 12 months, is irrational and unduly onerous. It allows the Minister the power to usurp the powers of those forums to determine their own dispute resolution processes and to assess appropriate remedies. For example, an employer may be ordered to pay money or restore the position of a wronged employee. To prevent such an employer from bidding for state contracts amounts to double punishment and is unjustified.
In conclusion, Mr Moyane expressed that BUSA respectfully submitted that to accept the current Bill as it stood would likely lead to constitutional challenges and endless disputes; cause disharmony in the workplace and undermine policy coherence, even within the government department.
Mr T Brauteseth (DA, KZN) pointed out that in the submission, Mr Moyane had referred to a lot of irrationality and irrational decisions and things that have been marked as unconstitutional. If the Bills were passed as they were, would they be legally challenged and face constitutional muster?
The Chairperson referred to s15A(b) of the Employment Equity Bill and asked whether s15 should be taken out in its entirety as it would not pass N-national as yet. He asked if both the section including the proposal made by Busa should be taken out. Referring to s15(3) that was already in the Employment Equity Act, the Chairperson asked whether the concern was in the concession of sub-section 6, particularly 6(d) and (e) and whether these sub-sections would make the entire section unconstitutional. He said state contracts were already in the principal Act and there were no amendments regarding those. The Chairperson also asked whether Busa agreed or disagreed with sectorial targets and if Busa had considered that its proposal on s42(1) would be accommodated by s6 and asked whether there had been a difference to what was contained in s53. He said there were specific areas regarded for compliance in the Bill, which were not vague. Busa proposed reasonable steps should be taken to reach targets. The Chairperson went on to ask how these steps would be measured as this had not been indicated during the submission.
Mr K Mmoiemang (ANC, Northern Cape) asked whether he was correct in thinking that Busa wanted to benefit from state contracts but had challenges with the state in strengthening its hands in terms of fasttracking transformation particularly to empower the historically disadvantaged.
Mr Moyane (Vice-Chairperson) replied to Mr Brauteseth saying that Busa was an active participant of the National Economic Development and Labour Council (NEDLAC), which meant it was interested in seeing whatever policies or legislation that came out of NEDLAC should have general support among all social partners. This would further mean that the legislation had a reasonable chance of being implemented without a glitch. He said where there were obvious concerns about legislation, Busa had to point those out. He said there were good things about the Bill, however the way in which the Bill went about driving transformation in the workplace was at times not legally sound. Busa did not want to raise legal challenges where it was not warranted.
He responded to the Chairperson and said if s15A of the Bill was seen as imposing hard targets, as if they were quotas, it would be in conflict with s15(3) of the EEA. Busa understood the need for sector targets in consultation with role players in the sectors, as it would bring about an element that government would not necessarily be familiar with that would impact the levels of employment or transformation. If sector targets were considered to be quotas, it would be challenged and Busa was against that. Mr Moyane said Busa did not want companies to discriminate against employees. There were no contradictions and he was quite clear. He said when assessing compliance, the reasonable steps taken to reach a decision should be assessed. Busa’s argument is that s42 should have been retained as it contained steps and gave clarity to parties on what needed to be looked at when compliance was assessed.
Mr Jonathan Goldberg, Chief Executive Officer, Global Business Solutions, said that the application of s15A of the Bill was important and if targets were set which everyone agreed with, there would be wonderful progression over the next five years. Section 42 was critical in terms of application because it was law and did not fall under s53 which deals with the Minister’s delegated power. He said in effect, an inspector could decide not to grant a compliance order and that would mean no business and potentially more job losses. He said a double jeopardy situation could arise. He said if the proposal would amount to an absolute bar, then one should read the recent case law judgment in Minister of Finance v Afribusiness NCP CCT279 and it should be accordingly applied.
Mr Moyane replied to Mr Mmoiemang saying that he was incorrect to think that way as Busa was not opposed to the intentions of the Bill when it came to promoting transformation. He said Busa wanted transformation to happen in a way that was not legally questionable.
Submission by Banking Association South Africa
Ms Bongiwe Kunene, Managing Director, Business Association South Africa (BASA), presented on the following:
• Section 15A
• Section 15A (3)
• Section 15A(4)
Speaking on s15A(4) which read “notice issued in terms of subsection (3) may set different numerical targets for different occupational levels, sub-sectors or regions within a sector or based on any other relevant factor”, Ms Kunene said that BASA was of the view that sector targets should be set nationally and not differentiated by region. If regional targets applied then businesses with a national footprint would have to comply with multiple sets of targets which would result in a considerable burden in terms of restructuring, managing and monitoring the compliance requirements for businesses that operate nationally.
Ms Kunene further highlighted the concerns that BASA has. The first concern was regarding the issuing of bonds, saying that the issuing of bonds to local or international investors might become difficult if a bank has failed to meet the targets within the five-year period, and has a regulatory finding against them. This could impact the raising of capital (and therefore growth) within the country. The same would apply to investments made by asset managers or individuals.
Further, she said that one of the effects of the targets being hardcoded was that it would make it very difficult to reach and comply with the intended goals in a five-year period. The unintended consequences are the biggest risk for the banks. The main concern is how the banks would be perceived by asset managers that had to invest capital in the banks. Retrenchments of employees in crucial sectors to fit into the targets, could unintentionally lead to economic harm and or systematic risk.
Ms Kunene said that BASA recommends that the process to set targets should be consultative, transparent, and use the best available and up-to-date evidence. The Minister should consult with individual sectors before setting targets to ensure that targets were sector-specific. Target timelines to be extended to a minimum of ten years instead of five years, to allow for adequate time to transition and avoid unintended consequences.
Mr M Dangor (ANC, Gauteng) said with digitisation, he witnessed that branch networks were closing and people were becoming unemployed. He asked whether people were being reemployed by the banking sector or were reskilled because of the digital age. He said people were working elsewhere and not from a bank branch any longer. He suggested that there be a special session with the banking association to deal with issues of banking beyond the traditional banks. He said community banks were important to service the area the banking association was not servicing. He said if ‘un-bankable’ people were going to be included in the banks and provided with services, traditional banks would refuse to do so as the risk analysis would not allow them to do so. In America, traditional banks invested in community banks such as South Shore Bank that was created by President Obama. He said banks could provide for people who were outside of it and a special meeting needs to deal with those kinds of matters.
Ms Kunene said the submission should be narrowed down to s15A; s15 (3) and s15 (4). She said the banking association did not put the proposals on the submission because it wanted to highlight the concerns of the banking association. She asked the Chairperson permission to present the eact wording on another day.
Submission by Financial Intermediaries Association of Southern Africa
Adv. Sandile Khumalo, who made the submission on behalf of the Financial Intermediaries Association of Southern Africa (FIA), said to date, the FIA has not been consulted in terms of the setting of targets under the EEA Bill. It is the view of the FIA that any consultation thus far does not meet the consultation requirement set in s15A(2) of the EEA Bill and as such consultation may only happen when the EEA Bill is promulgated. The FIA therefore does not agree to any targets set outside of the required consultative process.
• The financial services sector is different from other sectors where a “one size fits all” target can be applied.
• Diverse and distinct sub-sectors exist, which all have different challenges.
• Examples of sub-sectors are (i) intermediaries (ii) life insurers (iii) non-life insurers (iv) banks and (v) asset managers.
• Section 15A (3) allows for the setting of sub-sector targets and the FIA supports and endorses this.
• Regional demographics have to be considered when sub sector targets are set. The demographics of certain provinces (KwaZulu Natal and Western Cape) do not allow for the application of national targets across the board.
Adv Khumalo expressed that the National Council of Provinces (NCOP) should endorse the approach of setting appropriate targets per sector (or sub-sector) taking regional demographics into account. The absence of input from the NCOP will result in national government and the Minister making laws and regulations without considering unique provincial and regional dynamics.
Please see annexure A for comments on proposed amendments to sections 15A and 20(2A).
The Chairperson asked if s42 was left as proposed in the Bill. He said he was unclear about s53(6) (b) in respect of any target that any employer that had not complied, and how the employer had to raise reasonable reason for non-compliance. He asked whether the two sections did not say the same thing. He said he was concerned about the debate regarding what was considered a reasonable step and what was not a reasonable step. He asked whether it should not be left as is proposed in the Bill but if you have reasonable attempts taken then that would be taken care of by s53(6)(b).
Adv. Khumalo said the difficulty was that s42 and s53 were standalone sections and as such, s53 would not cure for the two because the consequence for s42 could be a fine is imposed because of non-compliance hence it provides ‘whether the employer complies’ or it was found that employer did not comply then it would be an act of non-compliance that could attract consequences independent and separate from s53. He said s53 was only relevant to state contracts. The issues of a Minister being taken to court could arise under s53. The pass mark should not be 100 but should be from 50 to anything above depending on the type of sector dealt with. He said if a business that only complied with 5% got fined the same amount as a business that complied with 95% did not make sense.
Mr Mmoeimang asked if the team could share what reasonable steps could entail as a result of non-compliance.
Mr Sisa Makabeni, State Law Advisor, said the provision s53 cross-referenced s42 (4) in the principal Act which read ‘in any assessments of its compliance with this act or any court proceedings a designated employer may raise any reasonable ground to justify its failure to comply’.
Adv Khumalo responded that the section was justifying non-compliance but that their submission did not deal with defence to non-compliance because if what FIA was proposing carried favour with the Committee and to National Assembly substantial compliance would be compliance with s42 and s15A and others. He said if the Minister found that reasonable steps had been taken there would be no need to go to s 42(4) of the principal Act. He said s42(4) dealt with a situation where there was no compliance. The Minister would then deal with the reasonable steps taken and issue a report and the matter would not need to consult s42(4) which deals only with non-compliance. In the event of non-compliance, a reasonable explanation needed to be given for non-compliance.
Submission by Black Business Council in the Built Environment
Mr Gregory Mofokeng, Chief Executive Officer, Black Business Council in the Built Environment (BBCBE), and Mr Douglas Affleck, Group SHEQ Manager, ENZA Construction, presented on the following:
- The BBCBE supports the amendments.
- Overall, the amendments are written in good context with respect to improvements on occupational diseases, rehabilitation, inspector’s powers and involvements, and the expansion/extension of time frames to finalise administrative work.
- The definition of “dependent” has been updated to suit the South African context. However, broadening the context and with SA's migratory workforce in mind, it will create challenges for the insurance underwriters and legal aids on who is most dependent, or most relevant, or most bound to the person who was injured/ passed away and how to fairly distribute the policy outcomes. BBCBE would like to see the definition to consider the broader legal context.
- In terms of Section 18: Amendment for the Commissioner to have the power to transfer funds to the PIC without the Director-General's involvement, BBCBE believes the DG should still play a role in the decision and take accountability for investment of the funds.
- The license provided to FEM to conduct business on behalf of the Commission in the construction sector must be advertised for alternative and empowered players in the market to have an opportunity to tender for it. We must allow for other insurance providers, particularly black-owned businesses to be allowed to compete for this opportunity.
- It has become an administrative nightmare and costly for companies (small businesses in particular) to secure letters of good standing. Companies are charged exorbitantly to secure it and in some instances, upon renewal, they are subjected to unending audit processes. This simply means companies that depend on public sector projects are unable to tender for such opportunities.
No questions were asked.
Submission by Association for Savings and Investment South Africa (ASISA) / South African Insurance Association (SAIA)
Adv. Riaz Itzkin presented the submissions on the Employment Equity Bill (see attachment). He elaborated that compliance has to be considered in respect of general compliance in terms of s42 and a certificate of compliance in terms of s53. He further stated the following:
• The financial sector is highly regulated with multiple licenses and significant capital requirements.
• As more funds and attention will be moved to address compliance on this hard‐coded requirement, other sections of broad‐based transformation will suffer.
• If the majority of companies fail to comply with the targets set out in the EEA, it would be perceived by the public as a governance failure.
• Recognition must be given for the achievement of transformation through a combination of other factors to determine an entity's compliance level. Compliance has always been measured in aggregate rather than compulsory performance on every element.
• There need to be clear assessment guidelines in terms of compliance and a robust appeal process to avoid systemic risk to the industry.
• Any determination of what would constitute compliance will need to take certain industry-specific events into consideration (such as a walkout of a senior black manager to start their own business shortly before the measurement date).
No questions of clarity
Submission by Master Builders Association South Africa on the Employment Equity Amendment Bill
Mr Roy Mnisi, Executive Director, Master Builders South Africa, and Mr T Moase, Senior Manager, Master Builders South Africa, delivered the submission on the Employment Equity Amendment Bill (see attachment). Mr Moase elaborated on the following points:
Determination of sectoral numerical targets
• The section empowers the Minister of Employment and Labour to set sectoral numerical targets after consultation by a notice in the government gazette.
• The section is silent on the criteria for identifying and setting sectoral numerical targets.
• The section is silent on the need for consensus between the Minister and economic sectors in determination of numerical targets, which demonstrates adequate consultation and is crucial to setting and achievement of any targets set.
• Master Builders Association South Africa (MBASA) was deeply concerned that neither the criteria for setting targets nor the need for consensus had been included in s15A.
• MBASA proposed that s15A (2) should include a requirement for the Minister to determine criteria for identifying and setting sectoral numerical targets jointly with economic sectors.
Amendment of s53: state contracts
• The section allows for an employer to raise a reasonable ground to justify its failure to comply.
• The section is silent on the definition of acceptable reasonable grounds to justify a failure to comply- this may be subject to abuse
• MBASA proposes that clear definitions of acceptable reasonable grounds to justify a failure to comply should be included in the Act.
• MBSA proposes that a compliance period of no less than the minimum required for completion of an occupational qualification dominant for each sector should be included in the definition of acceptable reasonable grounds for failure to qualify.
Ms S Boshoff (DA, Mpumalanga) asked why was it that hardly anyone was speaking to amendments of the Compensation for Occupational Injuries and Diseases (COIDA) Bill. She asked whether people were happy with it.
Mr Mmoiemang asked what MBASA would do if recommendations made were included in the Bill.
Mr Mnisi responded to Ms Boshoff saying that the concerns for COIDA were not as significant as the ones on the Bill presented by MBASA.
Mr Mnisi responded to Mr Mmoiemang that he would not find anything wrong with that because if you are dealing with the Bill and not dealing with the regulations at the same time, you are not quite sure what the regulations will be covering taking into account the importance of those areas. He said MBASA reflected on those areas that were already in the Bill itself so there was just a need for those sections to be looked at in a different way than the way they are at this point in time.
Mr Matthew Parks, Deputy Parliamentary Coordinator, COSATU, made the following submissions on the Employment Equity Amendment Bill:
- COSATU supports the Employment Equity Amendment Bill;
- Bill is progressive and will assist in seeking to address the legacies of discrimination;
- It is fair, rational and empowers the state to deal with obstinate employers;
- Equally it allows for regional diversity which is a matter requiring sensitivity; &
- Links state tenders requirement to compliance with labour laws & good labour practices.
- COSATU urges Parliament to prioritise and pass this Bill as soon as possible;
- Parliament should defend its progressive provisions & not be convinced by calls to gut, dilute or weaken these necessary interventions;
- It has taken many years to reach Parliament;
- It should not be delayed any further.
No questions asked
Submission Injured Workers Action Group
Mr Tim Hughes, Spokesperson, Injured Workers Action Group, presented on the COIDA Bill (see attachment).
He said that s43(4) of the COID Bill sought to prohibit Medical Service Providers (MSPs) from ceding their claims for payment by the Compensation Fund.
This would have resulted in third-party administrators who assist the medical fraternity with administration and funding no longer being able to provide this service in the absence of financial and legal security.
No questions were asked
Submission by Construction Alliance South Africa
Mr Chris Campbell and Mr R Haul presented the submission. They further elaborated on the following points:
- Legislation Conflict: If EEAB is implemented, it will be afforded greater impact than the Procurement Bill. (s63 of EEAB states it enjoys preference to any other legislation other than the Constitution). Other areas of conflict with BBBEE legislation;
- S217 of the Constitution allows for procurement to be utilised by the Ssate for redress of past imbalances.
- Target setting on an irrational and unreasonable basis that seeks to absolutely limit public procurement opportunities may be considered unfair and may be a matter of unconstitutionality;
No questions were asked
Mr Fritz Luttich, Managing Director, Compensation Solutions (CompSol), and Mr MP van der Merwe, presented on the COID Amendment Bill clause 43(4) and 43(5) (see attachment)
Mr Dangor said legislation should be strengthened with regard to debt collectors.
Ms Boshoff said if there is going to be a continuation of working with a dysfunctional Compensation Fund, the Committee will witness medical practitioners eradicate work of extra admin just to close their doors to injured workers and this would place a huge burden on our public health service.
Mr Luttich agreed with both Mr Dangor and Ms Boshoff especially since many service providers refuse to treat workplace injury patients and burden will be on government hospital facilities.
Submission by South African Civil Engineering Contractor
Ms I Campbell and Adv Stelzner presented on the Employment Equity Amendment Bill. During the submission, Ms Campbell made the following points
▪ Section 15 of the EEA described “affirmative action measures” as including “measures to ensure the equitable representation of suitably qualified people from designated groups in all occupational levels in the workforce”
▪ Section 15(3) provided that such measures “include preferential treatment and numerical goals, but exclude quotas”
▪ Goals [or targets] represented a preconceived target or objective of what was rationally capable of achievement in the light of the expected impact of external factors.
▪ Quotas, on the other hand, function as an end in them by providing a ‘target’ that was non-negotiable, fixed and removed from the reality of factors that determined the achievability of a true goal.
▪ In the context of transformation, while ‘goals’ represented objectives, a quota functioned as a measure in itself.
▪In the Barnard case, Moseneke J expressly condemned quotas, observing that “the primary distinction between numerical targets and quotas lies in the flexibility of the standard. Quotas amount to job reservation and are properly prohibited by section 15(3) of the [EEA]” ‘.
Adv Stelzner raised the following concerns:
▪ Strong growth in industry was required to enter employment cycle – needed to meaningfully impact EE
▪ Job creation through infrastructure investment must take priority.
▪ Poorly conceived and implemented EE legislation could severely damage our fragile industry denying the country a national asset and skill set which had been defined as critical.
▪ On-going legal processes absorb resources and were counterproductive which creates a fertile breeding ground for potential bribery within a powerful inspectorate holding sway over company survival.
▪ Ease of doing business decreases which were in conflict with 2022 SONA.
▪ Employment costs would escalate.
▪ Employers avoid employment and employ a minimum number of employees.
▪ Further skills flight of people we need as the mentors and drivers of change.
No questions were asked.
Submission by COIDLINK
Mr Gideon Nkadimeng, Chairperson, COIDLINK, presented the following recommendations:
• The Minister of Employment and Labour needed to explain how the Gazette Notices 526 and 615 relate to the Bill, in particular, s43(4).
• Unless the Gazette Notice 615 was to be withdrawn, Clause 43 of the Bill would be rendered invalid effectively rendering the parliamentary process null and void.
• They urged the Select Committee to be vigilant to ensure that administrative powers were not abused by the Commissioner to frustrate the legislative process. They said the disregard of the parliamentary process by the Commissioner and CF management was evident from the above Gazette Notice that has been issued to frustrate operations of pre-funders as third parties.
• They suggested the Select Committee should send a stern warning to the CF Commissioner and his management not to undermine the legislative powers vested in the National Assembly and the National Council of Provinces. Any administrative notices must be strictly in line with the Act and should not be used to implement policy changes.
They said “We do not make this request lightly as we are aware of clear separation of powers between the Executive, Judiciary and the Legislative arms of the state. However, COIDLink wrote to the Portfolio Committee on Employment and Labour on 3 November 2021 to bring to the attention of the Portfolio Committee the attempts by the CF to undermine the legislative process underway in Parliament with a Bill passed by the National Assembly."
They agreed with the Portfolio Committee that the Commissioner has a right to regulate third parties through administrative checks and balances but he does not and should not have the power to exclude legal transactions or to undermine a democratic process through administrative and operational actions.”
Ms Boshoff asked whether there was any response from the Chairperson of the Portfolio Committee regarding the letter for compensation and if so what was it.
Mr Dangor asked what the margin for costs was.
Mr Nkadimeng said they had not received a response from the Minister or the Compensation Fund.
Ms Nzau Leah, Chief Executive Officer, COIDLINK, said they could not say what the margin is in the presence of competitors.
The Chairperson thanked everyone for their presence, reiterated the steps going forward and the meeting was adjourned.
- Compsol COID Amendment Bill Presentation
- COSATU: Compensation of Injury on Duty A/B
- COIDLINK Oral Submission Presentation
- CASA Employment Equity A/B presentation
- BUSA Employment Equity Parliament Presentation
- BBCBE Presentation
- BASA Presentation
- ASISA Presentation
- SAFCEC Presentation
- MBSA: Employment Equity A/B Presentation
- IWAG: COID Amendment Bill
- IWAG letter to Honorable Chair
- FIA Presentation
- COSATU Submission
- Employment Equity Amendment Bill: B14B-2020
- Employment Equity Amendment Bill: B14A-2020
- Compensation for Occupational Injuries and Diseases A/B:B21B-2020
- Compensation for Occupational Injuries and Diseases A/B: B21A-2020
Rayi, Mr M
Boshoff, Ms SH
Brauteseth, Mr TJ
Dangor, Mr M
Mmoiemang, Mr MK
Moshodi, Ms ML
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