SolveSA Home All SolutionsTransformationAboutInsightsContact
Mandated Investments & B-BBEE Ownership

There is black ownership hidden inside your share register. Most companies never find it.

Pension funds, unit trusts and insurance policies quietly hold a third of the JSE — and the black ownership flowing through them is almost always measured as zero. Alternative Prosperity's Mandated Investment analysis finds it, measures it defensibly, and reports it in a form your verification agency will accept.

2011Research programme launched with the JSE & ASISA
3Disciplines on every engagement: actuarial, legal, financial services
Codes-alignedMethodology maps directly to FS100 / the Financial Sector Code
Mandated Investment Universe
Pension Funds · Unit Trusts · Insurers
Categories defined under Code Series 100, Statement 100
Default treatment
Treated as non-black
Unless a Competent Person's Report says otherwise
With flow-through analysis
Measured, evidenced, reportable
Delivered as an Independent Competent Person's Report
The Challenge
Our Track Record
How It Works
The Service
Who It's For
Get Started
The Challenge

Financial intermediation was never built for measuring transformation

Modern capital markets move fast and largely anonymously. That's efficient for trading — but it means a huge share of black economic participation in listed companies simply disappears from view.

01

Mandated investments are enormous

Pension funds, collective investment schemes and long-term insurers collectively hold a substantial share of every JSE-listed company's register — often larger than any single identifiable shareholder.

02

The conservative default costs you points

The Codes allow entities to either treat all mandated investment ownership as non-black, or commission a Competent Person's Report. Most default to the first option — and leave real, measurable black ownership unclaimed.

03

Doing it properly takes specialist skill

Flow-through measurement needs actuarial technique, financial-services domain knowledge, legal interpretation of the Codes, and the data-matching capability to trace beneficiaries through funds, schemes and policies.

Our Track Record

We didn't build this methodology for a brochure. We built it for a national policy question.

Alternative Prosperity's mandated investment work began as public-interest research, not a product pitch — which is exactly why regulators, verification agencies and listed companies rely on it today.

Our multidisciplinary team spans B-BBEE ownership specialists, financial-services and actuarial expertise, legal interpretation of the Codes, and the data engineering needed to trace ownership through complex fund structures — assembled specifically so every conclusion can withstand verification-agency scrutiny.

Circa 2011

A public-interest question, answered with rigour

Appointed and funded by the JSE, with the support of ASISA, to answer a simple but consequential question: to what extent do black people actually own shares on the JSE?

2011 – 2017

Peer-reviewed, audited, and published

The resulting methodology was peer-reviewed by National Treasury and audited by independent verification agencies, with findings published widely and presented to Parliament as part of the national "Ownership Monitor" research.

2012 & 2017

Written into the Financial Sector Code itself

Our team played a direct role in the Financial Sector Code being gazetted under the B-BBEE Act — the same Code that governs how mandated investments must be measured today.

Ongoing

A standing capability, not a one-off study

What started as research is now a repeatable service: Independent Competent Person's Reports, prepared to the standard verification agencies expect, for companies who want their real ownership picture reflected.

How It Works

One integrated process, from raw fund data to a defensible report

Our mandated investment process is a single pipeline — not a black box. Each stage feeds the next, and every conclusion can be traced back to its source data.

1

Data Collection

Public, semi-public and client / project-level data on the underlying investment and its investors.

2

Data Analysis

Identification of mandated investments and application of the relevant measurement methodology.

3

Register Analysis

Voting rights and economic interest measured for black people, black women and black youth, on a flow-through basis.

4

Related Services

Corporate finance, B-BBEE committee support, compliance-committee support and scorecard solutions where needed.

5

Communicate

Report production, data aggregation and presentation to your verification agency for inclusion in your certificate.

Three principles that keep every finding defensible

Conservative by default

Where the B-BBEE status of a beneficiary cannot be determined, it is treated as non-black. Nothing is ever inflated to reach a better number.

Proportionate value basis

Economic interest is measured on proportionate value, not headcount — because the Codes measure economic participation, not the number of people involved.

Vested rights only

Only vested rights are taken into account when calculating a member's proportionate share, so every figure reflects an actual, current entitlement.

Category of Mandated InvestmentHow it's treated
Collective investment schemesFull value in scope
Pension fundsFull value in scope
Long-term insurers (policyholder funds)Portion from policyholder funds
Medical schemes (member funds)Portion from members' funds
Friendly societiesFull value in scope
Banks (depositor funds)Apportioned to depositor ratio
Mutual banks (depositor funds)Apportioned to depositor ratio
The Service

An Independent Competent Person's Report your verification agency already recognises

The Codes are specific: mandated investments as defined in Paragraph 3.7.3 of Code Series 100, Statement 100, can only be counted as black-owned if a qualified Competent Person estimates the extent of that ownership. We are that Competent Person.

Every engagement is built around your actual share register and your actual mandated investors — not generic assumptions — and delivered as a formal, citable report ready to hand to your verification agency.

Request a Proposal
Getting Started

From register to report in four stages

1

Scoping conversation

We review your current B-BBEE ownership position and identify where mandated investment exposure sits in your register.

2

Data & register access

You provide share register and underlying investor data; we handle it under strict confidentiality throughout.

3

Flow-through analysis

Our team applies the measurement methodology to determine black economic interest and voting rights on a flow-through basis.

4

Report & sign-off

You receive a signed Independent Competent Person's Report, ready for your verification agency's review.

Who It's For

Built for the people who own the B-BBEE scorecard

JSE-listed companies

Issuers whose share registers include significant pension fund, unit trust and insurance ownership that has never been formally measured.

Transformation & compliance teams

B-BBEE and DE&I officers who need a defensible, Codes-aligned basis for the ownership element of their scorecard.

CFOs & company secretariats

Finance and governance leaders preparing for verification-agency review who want the analysis right the first time.

Illustrative Insights

What a flow-through analysis actually surfaces

Every register is different — these views illustrate the kind of picture our methodology produces once mandated investments are properly analysed.

Illustrative mandated investment category split

Indicative structure only — every engagement is measured against your own register
Illustrative
Pension funds
Collective investment schemes
Long-term insurers
Other mandated categories

Illustrative flow-through measurement

Representative shape of findings, not the output of any specific engagement
Illustrative
Total mandated exposure identified
Voting rights — black people
Voting rights — black women
Economic interest — black people
Economic interest — black women
Independent Competent Person's Report
B-BBEE Mandated Investment Analysis — Sample Structure
Prepared for
Client name
Confidential to each client
Total mandated investment identified
XX.X%
of issued shares
Voting rights — black people
XX.X%
flow-through basis
Voting rights — black women
XX.X%
flow-through basis
Economic interest — black people
XX.X%
flow-through basis
Sign-off
Alternative Prosperity
Reviewed & signed by our lead Competent Person
Confidentiality & Governance

Every register we touch is treated as strictly confidential

Our reports carry real regulatory weight precisely because we handle underlying data — yours and your investors' — with the same discretion we'd expect of our own.

Private & confidential by default

Every report is prepared exclusively for the requesting entity and is not published or shared without explicit permission.

Independence, checked

Every engagement is reviewed to confirm no member of the team holds a material interest that could impede independence.

Verification-agency ready

Findings are formatted and referenced against the Codes so they can be presented directly to your verification agency.

Traceable methodology

Every figure can be traced back to its underlying data source and the specific measurement principle applied to it.

The Difference It Makes

From an assumed zero to a measured, evidenced number

Without a Mandated Investment analysis

  • All mandated investment ownership defaults to "non-black"
  • Real, existing black ownership goes unclaimed on the scorecard
  • No documented basis to challenge a conservative rating
  • Ownership level may sit below what the register actually supports

With an Alternative Prosperity ICPR

  • Black voting rights and economic interest measured on a flow-through basis
  • Findings backed by a Codes-aligned, peer-reviewed methodology
  • A signed report your verification agency can rely on directly
  • An accurate, defensible reflection of your true ownership position

Find out what your register is really telling you.

Book a confidential scoping conversation with our Mandated Investment team — no pricing, no obligation, just a clear view of where you stand.