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Writer's pictureTalita Westraadt

UPDATE: LEGISLATION RELATING TO TRUSTS, EMPLOYEE SCHEMES, AND BROAD-BASED SCHEMES

Updated: Feb 25, 2023



The Department of Trade Industry and Competition, has released the eagerly anticipated Practice Note on the regulations governing discretionary collective enterprises, such as broad-based schemes, employee share ownership programs, trade unions, not-profit corporations, cooperatives, and trusts.


This Practice Note makes clear, among other things:


  • The ownership requirements under the Codes are satisfied by a designated class of black beneficiaries, not necessarily by a list of beneficiaries' names;

  • Evergreen ESOPs, which offer corporate employees a lifetime benefit, satisfy the ownership requirements outlined in the Codes;

  • Minors are eligible for inclusion in Collective Enterprises' ownership calculations and decision;

  • a distribution may be made in kind or in cash, and either or both may be claimed under "Economic Interest" on the Ownership scorecard;

  • permits the Fiduciaries' application of discretion in determining the amount or share of Economic Interest disbursements to beneficiaries or participants; and

  • enables the measurement of voting rights by the fiduciaries casting ballots on behalf of participants or beneficiaries.


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