Letshego addresses shortcomings flagged by equity commission

The Employment Equity Commission’s (EEC) chief review officer, Gino Brinkmann, has laid bare a series of compliance failures by Letshego Namibia, accusing the financial services company of failing to correct glaring shortcomings within the legally prescribed period.

Letshego was one of 15 companies that appeared before the Employment Equity Commission’s (EEC) review panel last week due to non-compliance with the provisions of the Affirmative Action (Employment) Act.

Presenting the case before the commission on Thursday, Brinkmann said the company’s employment equity report, submitted on 16 July 2025 and received by his office on 8 August 2025, contained multiple deficiencies that were in violation of the law.

“The matter before us concerns the failure to submit, or to correct, shortcomings within the given time period provided," Brinkmann told the commission.

He said his review had identified deficiencies in several annexures, namely annexures A, B, F and G.

Issues identified

The review officer said the first and most serious breach was identified in Annexure A, where a non-Namibian employee had been employed for more than 12 months without an understudy or any proof of an application for exemption.

“Table 2 of the same annexure needed revision, as it did not correspond with Table 1,” he said.

“In Table 3, where the Namibian understudy was required to sign, there was no signature due to the absence of an understudy. The employer also omitted Table 4, which is the understudy training programme or progress report," he added.

Brinkmann highlighted further discrepancies in Annexure B, noting that the company’s workforce profile figures did not match its previous submission. He said he had instructed the employer to revise the figures using a specific reconciliation formula.

“For clarity, the formula is as follows: use the workforce from the previous report, add the current report’s recruitments, and subtract the terminations. The result should give you the current workforce profile," he said.

Brinkmann added that Letshego had also failed to ensure table totals were correctly calculated and that Tables 4 and 5, which record terminations and their reasons, contained inconsistencies. He said he had requested additional information to address these issues.

“Once Table 1 was corrected, it also had to reconcile with Table 10a–d, which reflects salary scales and actual salaries. Table 10d, however, did not include the average annual salaries for non-Namibians, which is required at all times."

“As you can hear, Chair, it was quite extensive,” Brinkmann remarked on the issues uncovered. “These shortcomings were emailed to the employer on 20 August 2025.”

Despite receiving a reminder on 2 September, Brinkmann said the company failed to comply within the extended deadline.

“Mr Guiseb later contacted me and assured me that they would provide the corrections by 5 September. Unfortunately, by that time, the review period had already lapsed in accordance with our standard operating procedures,” he told the panel.

Brinkmann said he ultimately recommended conditional approval pending the rectification of the identified shortcomings. The report was tabled before the commission on 16 October 2025 but was subsequently referred back for further compliance.

Problems addressed

Responding before the review panel, Letshego’s head of people and culture, Kingsley Guiseb, acknowledged the issues raised by the commission and said all identified shortcomings had since been addressed.

“On behalf of Letshego, we fully acknowledge the report that we submitted,” Guiseb said. “To begin with, we submitted the initial report within the required period in 2025. Subsequently, we received a notice outlining the shortcomings, as Mr Brinkmann mentioned. He had emailed them to us; however, I initially indicated that I had not received them."

He added that after contacting Brinkmann, “I must acknowledge that he was very helpful throughout the process. He clearly explained the nature of the shortcomings and guided us on how to address them.”

Guiseb told the commission: “I wish to state before this commission that all identified shortcomings have been rectified. Accordingly, we seek the indulgence of this review panel to allow these corrections to be submitted for final review, either by the review committee or through Mr Brinkmann, so that our report may be considered favourably.”

He added: “I must emphasise that we went back to the drawing board and worked diligently to align our report fully with the guidelines provided. We have made every effort to ensure that all shortcomings have been addressed.”

Changes made

Guiseb said Letshego had conducted a detailed review of its understudy programme to ensure compliance with the commission’s requirements.

“It took some time to fully resolve the issues, particularly because we needed to review our understudy programme,” he said.

“We have two expatriate employees in our business, both with highly technical skill sets, so we had to carefully assess the type of skills they possess and identify suitable understudies. Through that process, we identified the individuals and developed a detailed understudy programme for each of them."

Guiseb said the process had been time-intensive, as the company wanted to ensure that the development of these employees was thorough, equipping them with the necessary knowledge and technical skills.

“Reviewing and finalising our understudy programme for the identified employees was therefore essential, and that process has now been successfully completed.”

The EEC notified Letshego that a response will be issued to the companies after seven working days.

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