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01Our position
Fronting is a criminal offence under section 13O of the B-BBEE Act 53 of 2003. We do not design ownership or management structures to inflate a score. We do not supply paper directors, shareholders, learners or suppliers. We will end an engagement where we see misrepresentation.
Real transformation shows up in real evidence. That is the only kind we work with.
02What the law says
Under section 13O it is an offence to knowingly misrepresent B-BBEE status, to give false information to a verification agency, or to engage in a fronting practice. A person convicted may face a fine or up to 10 years' imprisonment. A company may be fined up to 10% of its annual turnover.
03What fronting looks like
- Window-dressing: black people appointed or listed without real authority, benefit or role.
- Benefit diversion: economic benefits that should flow to black participants are routed elsewhere.
- Opportunistic intermediaries: arrangements that exist only to win contracts or points.
- Paper participants: directors, shareholders, learners or suppliers who exist on documents and not in practice.
04What we will do
- Assess ownership, management control, skills and procurement on the evidence as it is.
- Plan improvements that are real, funded and sustainable.
- Keep where every figure came from, so a verification agency can test it.
- Tell you plainly when an arrangement carries fronting risk.
05What we will not do
- Promise a level or a number of points.
- Structure a deal to look compliant without the substance.
- Supply people or entities to fill a scorecard.
- Continue an engagement where we find misrepresentation.
06Reporting fronting
Anyone can report suspected fronting to the B-BBEE Commission. Its complaint process and current contact details are on bbbeecommission.co.za.