IMVABA CO-OPERATIVE FUND REVISED POLICY AND PROCEDURES MANUAL September 2011 1|Page Imvaba Policy and Procedures Manual TABLE OF CONTENTS 1. 2. 3. 4. Introduction and Purpose………………………………………………………6 Macro Structure of Imvaba…………………………………………………….6 Role of the ECDC…………………………………………………………………..7 Business Rationale of Imvaba…………………………………………………7 4.1. Vision 4.2. Objectives 4.3. Development Impact 5. Target Market……………………………………………………………………….8 5.1. Geographic Area 5.2. Distribution Channels 5.3. Targeted Economic Sectors 5.4. Targeted Co-operative Enterprises 6. Imvaba Co-operative Fund Product Mix…………………………………….9 6.1 Technical Mentorship and Capacity Building Support 6.2 Equipment and Material Finance Support (Seed Capital) 6.3 Term Loan Funding 6.4 Co-operative Governance Training Support 6.5 Disbursement of funds 7. Qualifying/Non-Qualifying Terms………………………………………….…11 7.1 Eligibility Criteria 7.2 Requirements from Applicants 7.3 Non-Eligibility Criteria 8. Risk Management…………………………………………………………………14 9. Recovery and Collections……………………………………………………..16 10. Key Policy Indicators………………………………………………………….16 10.1 Co-operative Funding Terms 10.2 Interest Rate 10.3 Fees and Charges 10.4 Investment Size 10.5 Security 10.6 Moratorium 11. Application Process……………………………………………………………17 11.1 Enquiries Stage 11.2 Interview Stage 11.3 Basic Due Diligence and Site Visit 11.4 Compile a Funding Memorandum 11.5 Funding Committee 10.6 Signing of Legal Agreements 10.7 Aftercare and Administrative Support 12. Governance and Reporting…………………………………………………21 12.1 Signing of a Service Level Agreement 12.2 Establish an Oversight Committee 13. Check List of Required Documents………………………………………22 14. Templates of Supporting Documents……………………………………23 2|Page Imvaba Policy and Procedures Manual 3|Page Imvaba Policy and Procedures Manual 1. Introduction and Purpose This policy document sets out the purpose of the establishment of the Imvaba Cooperatives Fund in the Eastern Cape and it should be read in conjunction with the Imvaba Co-operatives Fund Strategy of the ECDC in order to understand the target and market choices. This policy document particularly outlines the business rationale behind Imvaba, the target market, product definition, pricing and the proposed distribution channels. Attached to this policy document are: Imvaba application processes, access criteria, proposed business plan format and draft legal agreement template. 2. Macro Structure of Imvaba Imvaba will be structured as part loan (repayable) and part seed capital (nonrepayable). The seed capital portion is essentially structured to cover the developmental aspects and provide the capacity building aspects of the cooperatives to enable sustainability thereof. The loan part is to provide production and working capital to enable business activities of the co-operative. Imvaba will be ring fenced within the ECDC to finance co-operatives and be treated as a revolving fund for assisting prospective co-operatives. The critical element is to develop requisite capacity for co-operative activities to be sustainable and thus, some money will be allocated for non financial support services (capacity building) and the term loans to be invested in the activities of the co-operative enterprise. Imvaba funds from DEDEA will be allocated as follows: a. Loan Funds b. Technical Mentorship and Institutional Building Fund c. Seed Capital Fund (Equipment and Material) d. To cover Imvaba Operational Costs 4|Page Imvaba Policy and Procedures Manual 3. Role of ECDC According to the Act of 1997, the ECDC objective is to plan, finance, coordinate, market and promote the development of the people of the province in the fields of agriculture, industry, commerce, transport and finance. In a nutshell, it is an economic development agency of the province operating through oversight by DEDEA. ECDC as the implementing organ of Provincial Government will administer the Imvaba Co-operative Fund in line with the principles outlined in this document and the sentiments of the Service Level Agreement signed between DEDEA and the ECDC All funds apportioned to the Imvaba Co-operative Fund will be ring-fenced and managed separately from the normal ECDC balance sheet. These funds will be separately reported on and accounted for. 4. Business Rationale of Imvaba 4.1. Vision To provide funding through loans and institutional building support to co-operatives of the Eastern Cape Province in order to: Mainstream co-operative enterprises within the economy of the Eastern Cape; Enhance self employment creation opportunities in the province; Contribute to poverty relief efforts through enterprise development support. 4.2. Objectives The establishment of Imvaba seeks to achieve the following objectives: Leveraging the Imvaba Funds through partnerships; Provide institutional support and capacity building support to co-operatives in order to enhance the sustainability of their businesses; Provide loan funding to co-operatives for commercialisation purposes; 5|Page Imvaba Policy and Procedures Manual Enhance knowledge management about co-operatives in the province through effective Monitoring and Evaluation. 4.3. Development Impact The following development impact is anticipated with the establishment of Imvaba: Entrepreneurial enhancement and development; Creation of self employment opportunities (job creation); Contribution to poverty relief and alleviation efforts; Track the contribution of co-operatives to the provincial economy. 5. Target Market 5.1. Geographic Area Imvaba fund will be available to co-operatives in the Eastern Cape Province, specifically with the District Municipal boundaries of: Chris Hani District Municipality; Joe Gqabi District Municipality; Amathole District Municipality; Alfred Nzo District Municipality; OR Tambo District Municipality; Cacadu District Municipality; and Nelson Mandela Metropolitan. ECDC shall advance funding to co-operatives whose head offices fall within the provincial boundaries of the Eastern Cape; and/or the majority of the jobs created directly as a result of the funding and not indirectly as a spin off thereof falls within the provincial boundaries of the Eastern Cape. The co-operative must create direct new decent jobs, and/or must save existing jobs. 5.2. Distribution Channels Information about the criteria, application and feedback will be distributed through the ECDC Regional Offices situated in all the District Municipalities listed above. 6|Page Imvaba Policy and Procedures Manual 5.3 Targeted Economic Sectors The economic sectors to be targeted will be guided by the Provincial Industrial Development Strategy of 2009, viz: Agriculture (linked to an agro-processing activity, beneficiation and value addition activities from primary production); Retail (linked to the priority growing economic sector); Manufacturing (timber industry, textiles, chemicals, automotive activities, metal processing); Tourism activities (Setting up a B&B, shuttle service, entertainment centres, accommodation establishment and tourism adventure) ; Transport; Creative Industry; ICT and Film Production; Green Economy (bio-fuels, renewable energy, etc) Business Process Outsourcing (telecoms, etc) Textiles and Craft (job creation and protection) 5.4 Targeted Co-operative Enterprises In line with the socio-economic challenges of the province (poverty and unemployment), the types of co-operative to be targeted by the Imvaba Cooperatives Fund are (see definitions of all types of co-operatives to understand the logic behind the choice): Worker co-operatives (in line with the above sectors) Agricultural co-operatives Primary Co-operatives (dominant level) 6. Imvaba Co-operative Fund Product Mix A Co-operative approved for funding qualify for the following services under Imvaba Fund: 6.1 Technical Mentorship and Capacity Building Support 7|Page Imvaba Policy and Procedures Manual Purpose: Provide co-operatives with technical support in line with the business activities co-operatives are involved in Terms: Non-repayable, provided by contracted service providers Objective: enhance product quality for better market access and retention. 6.2 Seed Capital Funding Purpose: To discount the approved amount by 30% incentive in order to reduce the cost of capital for the co-operative Terms: Non-repayable funds Amount: 30% incentive of the required capital to finance ECDC management fees, lawyers’ fees and the balance to finance product quality and capacity building activities Objective: To be used as security for the term loan, where applicable 6.3 Term Loan Funding Purpose: Financing commercialisation activities Loan Terms: Repayable over 3 to 5 years, for a maximum of 12 months; Security: Fixed Assets of the co-operative; Amount: Minimum R10 000 to Maximum R1 400 000; Cost of Capital: Linked to prime Disbursements: Drawdowns directly to co-operatives informed by a thorough due diligence process; Moratorium: 6 months moratorium after the firstdrawdown. Final drawdown should not be more than 3 months from the first drawdown. 6.4 Co-operative Governance Training Support Purpose: Provide needed Governance Training and Auditing Support in order to improve compliance with the co-operative constitutions and the Cooperatives Act of 2005; 8|Page Imvaba Policy and Procedures Manual Terms: Non- repayable, provided by independent service providers funded by the ECDC under Imvaba; Disbursements: Paid directly to contracted service providers after the service has been conducted on approval of invoices by fund Manager. 6.5 Disbursement of funds The following principles will be applied by the ECDC when disbursing Imvaba funds: Funds will only be disbursed by ECDC to co-operatives whose applications have been subjected to the Funding Committee scrutiny and approval; Institutional and Capacity Building Funds will be disbursed only to accredited service providers of the ECDC that have been vetted and approved to provide such services to the co-operatives approved by the Funding Committee; Loan disbursements shall be disbursed to co-operatives in tranches and on proof that the co-operative has systems in place and that funds cannot be easily misused; Equipment finance can only be disbursed directly to suppliers on receipt of original invoices from the manufacturer/supplier of the equipment. 7. Qualifying/Non-Qualifying Terms 7.1 Eligibility Criteria A co-operative wishing to apply for the Imvaba Co-operative Fund will need to comply with the following criteria: The Co-operative must be registered at Companies Intellectual Property Registration Office (CIPRO) or its successor, under the Co-operatives Act No.14 of 2005; The Registration Certificate of the Co-operative must be signed by the Registrar of Co-operatives or any other Official of the Office of the Registrar officially delegated to doing so; The co-operative must have a signed resolution by all the members that they should apply for the Imvaba Co-operative Fund and state reasons for the application, such a resolution must also explicitly provide names of 9|Page Imvaba Policy and Procedures Manual designated members to conclude all the relevant documentation in respect of Imvaba Fund; The co-operative must have in place a Constitution, in line with the provisions of the Co-operatives Act No14 of 2005; A business plan a fully completed and/or application form signed by the designated members of the co-operative should be submitted; The co-operative should have secured a market for their product or service; The Co-operative should have secured at least quotations from different suppliers in relation to the equipment and material it requires; The establishment of the co-operative must comply with the requirements of the Co-operative Act of 2005 all in all respects; Members of the co-operative must be willing to make themselves available to workshops and training to be provided through the Institutional and Capacity Building Fund; The ECDC commits to funding co-operatives that show the following significant development impact indicators: Job creation/retention potential; Empowerment of women and youth; Largely based in rural areas; Community development Potential for sustainability 7.2 Requirements from Applicants Over and above the eligibility criteria listed in number 7 above, the following will also be relevant: own contribution is required from the co-operative and its members, it could be in the form of sweat capital or own capital to show commitment to the cooperative; Members of the co-operative must demonstrate 100% commitment to the activities of the co-operative; 10 | P a g e Imvaba Policy and Procedures Manual It is a requirement of the ECDC that the members of the co-operative must be actively involved in the activities of the co-operative. Active involvement requires full time participation by members in the activities of the co-operative; Members of the co-operative must display some technical expertise in the activities of the proposed business, should this not be the case, the members should make themselves available to support through the Institutional and Capacity Building Fund; The members of the Co-operative must have clean credit records, and/or provide ECDC with written proof of arrangements made to clear any existing debts. Failing which, the ECDC shall not provide funding. Co-operatives or its individual members with outstanding loans or debts with the ECDC shall not obtain funding until they settle their debts with the ECDC. 7.3 Non-Eligibility Criteria The Imvaba Co-operative Fund will not finance co-operatives that have been proven to have the following: All activities related to gambling, alcohol, tobacco, drugs; Costs associated with preparing and submitting tender documents; Any development investment which might be offensive to the community directly affected by such Co-operatives Investment; Any Co-operative whose activities might be offensive to the community at large; Any Co-operative which might seek finance in the form of a loan to finance an acquisition of shares from another company; Co-operative which might seek finance with the purpose to acquire property (land and buildings), of which the property will be receiving its income from lease rentals only and the loan proceeds will be used for the acquisition of the property only; A co-operative whose members are not going to be directly involved in the daily activities of the co-operative and also not be able to create jobs for either members or non-members; 11 | P a g e Imvaba Policy and Procedures Manual A co-operative, whose members are owners of individual businesses (cc, pty ltd) which have loans or debts with the ECDC; Any co-operative requiring funds to purchase another development investment from ECDC (ECDC does not lend money to a buyer to fund the purchase of a sale of its existing development investments). The member(s) of the co-operative who holds existing accounts with ECDC (including rental accounts) must not be in arrears; Where an existing co-operative is in default, it could only be considered for further investment based on an appropriate recovery and collection strategy and only after an appropriate due diligence has been conducted by the ECDC to justify the proposed recovery and collection strategy referred to paragraph 9 below. Any co-operative whose members are employees or immediate family / board members or immediate family / stakeholders of ECDC and DEDEA; 8. Risk Management 8.1 Despite the not so ideal profile of co-operatives targeted by the Imvaba Fund, DEDEA expects the ECDC to ensure broader access of the fund. Section 5.6 of the MOU clearly states: “The ECDC shall not carry any risk for the loan portfolio created for the Eastern Cape Provincial Co-operatives Development Fund (ECPCDF) and any losses due to failure of the co-operatives to repay their loans shall be for the account of the ECPCDF” The ECDC has identified the following as risk areas: ECDC staff’s lack of understanding of how co-operatives operate; Lack of business experience of members of co-operatives; Low levels of literacy amongst members of co-operatives; Lack of understanding of the application process by co-operatives; Lack of access to markets for co-operatives; Listing of members in credit bureau; Some members of co-operatives misusing Imvaba Funds for personal purposes. Market access risk; 12 | P a g e Imvaba Policy and Procedures Manual Over-inflation of cash-flow figures in business plans submitted 8.2 In order to mitigate the potential risk areas and also implement the objective of the MOU signed by DEDEA and ECDC, the ECDC is putting in place the following to mitigate the risk: A separate Funding Committee, with officials that are developmental in their approach will be established within the ECDC to evaluate Imvaba applications specifically; Exposure visit to the dti Enterprise Organisation for members of the new Funding Committee will be arranged in order to expose the members on how the CIS Funding Committee deliberate on applications from co-operatives; Thorough workshops and training of the ECDC Regional Officials on the revised Imvaba Policies, Processes and Application Forms will be undertaken; Each and every approved application will be attached a service provider that will provide Technical Mentorship Support, paid for by Imvaba for a maximum period of 6 months; Imvaba will insist on a market for products of the co-operatives because that will create a cash flow for co-operatives and also ensure income for members and employees; Members of co-operatives will sign personnel suretiship to mitigate risk of deliberate misuse of Imvaba Funds. 8.3 Therefore, investing in co-operatives will require a bigger risk appetite than currently is the practice within the ECDC. The following is highlighted: Funding does not require 100% security cover; ECDC to secure all possible and available security from the co-operative on the Loan Portion of all Co-operatives through the fixed capital that the cooperative has. Where a co-operative holds more than one business interest, ECDC should insist on registering cross guarantees in its favour from all these business interests; Mortgage bonds to be registered over all immovable property purchased; Suspense sale agreements to be registered on all relevant fixed assets; 13 | P a g e Imvaba Policy and Procedures Manual General Notarial Bonds (GNB) to be registered on all investments for the full value of the loan amount. Such GNB to include all moveable assets, including receivables and stock 8.4 Over and above the technical mentorship support, aftercare service to mitigate risk required. The following shall therefore apply: Account Managers are responsible for each investment made in each cooperative from inception right through to receipt of last payment; Monthly management accounts shall be collected and quarterly progress reports submitted by the Account Managers in the prescribed format as approved by the ECDC from time to time; Recovery and/or turn-around strategy should be followed where a loan is considered to be viable before any provision and collection action taken, except where it is suspected that ECDC is deliberately defrauded and it elects not to do any further business with the Co-operative invested in. The latter decision should be taken by the relevant development investment committee. 9. Recovery and Collections All Co-operatives in default of their loan portion of the funds will be notified in writing of such default and given an opportunity to remedy the defaultIn the event that the co-operative is not able to remedy the default, the ECDC shall notify DEDEA accordingly in line with section 5.6 of the signed SLA in order to get a policy directive. The collections unit must inform the relevant account managers immediately when the co-operative falls into arrears. The account manager must then immediately visit the Co-operative and compile a quality review report. 10. Key Policy Indicators 10.1 Co-operative Funding Terms 14 | P a g e Imvaba Policy and Procedures Manual The Co-operative investments are required to pay back the term loan within a period of between 3 years to 5 years 10.2 Interest Rate Co-operative term loans shall be priced at 0% (zero) interest 10.3 Fees and Charges The ECDC shall charge an upfront management fee of 10.5% of the value of each transaction, levied upfront from the total capital required by each co-operative and paid directly from the seed capital portion. These fees will cover administrative and operations fees of the ECDC. Additional fees that will be charged from seed capital portion include: Administrative and operations fees of the ECDC; Cost of registration of bonds; Cost of valuation of the transactions (where applicable); Legal fees of drawing agreements 10.4 Investment Size Seed Capital will cover required fees attached to the transaction for each application. It is a non-repayable fund that is 30% of the required capital Term Loans are repayable and cover such activities as working capital, input cost, machinery and equipment up to a maximum of R500 000.00 Technical Mentorship and Capacity Building will cover such activities as mentorship, technical skills, once-off auditing and governance training. These costs will be incurred by Imvabaas part of the approved funding structure. 10.5 Security ECDC will ensure that the equipment and material are used as a minimum security for the term loan of each co-operatives 15 | P a g e Imvaba Policy and Procedures Manual Where the co-operative has more than one investment of a similar nature and ECDC is required to invest in only one, cross guarantees is required from all the other investments 10.6 Moratorium A maximum moratorium of 6 months from first draw down is allowed on all new loan transactions. A moratorium on repeated funding can only be considered when the cash flow of the development investment indicates such requirement 11. Application Process The following process of application will be followed by co-operatives wishing to access Imvaba Funds: 11.1 Enquiries Stage Potential co-operative members can inquire about basic information from ECDC Regional Offices, DEDEA Regional Offices, ECDC and DEDEA websites; Potential co-operative members can visit the ECDC Regional Offices for clarification on the application forms and the required attachments Potential co-operative members express their interest in applying for Imvaba Funds with the Regional Account Managers. If applicants do not have a business plan, the ECDC will assist by appointing and funding the business planning development process 11.2 Interview Stage Account manager in the Region will interview members of that particular cooperative to ascertain their stage of readiness with the required checklist of documents; If the co-operative has all the required documents, the Account Manager then assist the co-operative in completing the application form; 16 | P a g e Imvaba Policy and Procedures Manual The Account Manager captures the details of the co-operative (demographic profile) on the IT system; The Account Manager must disclose to the co-operative (verbally and in writing) the process which will be followed before an approval can be obtained from ECDC; The Account Manager must ensure that all the required documents are provided by the co-operative as part of the application process to enable the ECDC to process the application and that their authenticity is verified with the relevant organizations (CIPRO, SARS, etc) The Account Manager must keep a record of the interview with the prospective client and submit as an attachment to the application form; The interview should serve as a basis for the Account Manager to know the co-operative in detail, verify its membership and non-membership, ascertain the existence of the market and members training & capacity building needs; The Account Manager should also ensure that the application complies with the requirements of this Imvaba Fund Policy. In instances where the application does not comply with this policy, the Account Manager should inform the co-operative upfront so as to avoid creating an expectation; 11.3 Basic Due Diligence and Site Visit On satisfactory completion of the application form and submission of relevant documentation, the Account Manager conducts a basic due diligence on the business of the co-operative; This will include a site visit of the address where the co-operative operates from; This site visit also includes visiting the potential clients and/or market of the co-operative to get confirmation that the products will be bought; This site visit also includes visiting potential suppliers of materials and equipment to confirm the authenticity of the quotations submitted with the application form 17 | P a g e Imvaba Policy and Procedures Manual The site visit includes confirming the existence of the bank account of the cooperative with the respective bank listed in the application form; The basic due diligence report must be compiled with key recommendations by the Account Manager and submitted as part of the application process; The due diligence should also assist in identifying capacity weaknesses within the co-operative members for capacity building purposes. 11.4 Compile a Funding Memorandum A proposed template will be used by the Account Manager to compile a funding memorandum for consideration by the Funding Committee; The Funding Memorandum is a summary of the findings of the interviews, due diligence, attachments of all required documentation, attachments of all quotations and recommendations for funding; The Funding Memorandum is presented by the Account Manager to the Funding Committee for consideration and approval; The Funding Committee is the only structure established within the ECDC that can approve applications of Imvaba Funds; The decision of the Funding Committee about the application is regarded as final and that decision is communicated through an official letter signed by Imvaba Fund Manager to the co-operative. 11.5 Funding Committee An Internal Funding Committee is established by the ECDC to process all applications brought in by Account Managers; This Committee is comprised of Managers of different units within the ECDC This Committee is established to be the only structure that processes, discusses, approves, rejects and defers applications with clear reasons; This Committee shall meet at least once a month to process applications The Secretariat shall keep minutes of all meetings and deliberations for future referencing and referral This is the only Committee mandated to process Imvaba applications. This Committee will be guided by its charter. 18 | P a g e Imvaba Policy and Procedures Manual 11.6 Signing of Legal Agreements Post approval of the application by the Funding Committee, the Account Manager shall officially (through a letter) inform the co-operative of the decision and the terms of such approval; The Legal Unit of the ECDC shall prepare a legal agreement to be signed between the ECDC and the Co-operative using an agreed template; The Legal Agreement shall include the terms of approval, obligations of the ECDC and the responsibilities of the co-operative On completion of the Legal Agreement, the Account Manager will arrange a meeting with the Co-operative where all the terms of the agreement are clearly explained to the members of the co-operative; Finally, the legal agreement is then signed between the ECDC and the cooperative. 11.7 Aftercare and Administrative Support Once the legal agreement has been signed, the ECDC will disburse funds in line with what has been approved by the Funding Committee; On a monthly basis, an independent service provider will also provide the needed support to the co-operative through the Institutional and Capacity Building Fund of Imvaba; On a quarterly basis, the Account Manager has an obligation to visit and collate reports about the activities of the co-operative, including management accounts; An analysis of these reports is done by the Account Managers in order to inform future drawdowns of approved funds and ascertain improvements in the business activities of the co-operative. Imvaba Fund Manager will review the reports with Account Managers and appraise the Committee on any matters needing attention. 12. Governance and Reporting 19 | P a g e Imvaba Policy and Procedures Manual DEDEA is the custodian of funds allocated for the Imvaba Funds and therefore the ECDC has an obligation in providing continuous reports on how the funds are being used. The following shall constitute a governance structure for the Imvaba Fund: 12.1 Signing of a Service Level Agreement A Service Level Agreement shall be signed between the ECDC and DEDEA to regulate the relationship pertaining to the use of the Imvaba Funds; The Service Level Agreement shall contain amongst others the following terms: o Purpose of the funds; o Amount allocated; o Transfer dates; o Roles of DEDEA and ECDC; o Reporting requirements and frequency; o Performance targets. The ECDC will develop an Imvaba Strategy, Implementation Plan and Budget as an attachment to the Service Level Agreement; The ECDC will revise and update the existing Imvaba Policy, Application Process and Criteria in line with the spirit of the Service Level Agreement and the developmental objectives of DEDEA. 12.2 Establish an Oversight Committee An Oversight Committee will comprise of officials from DEDEA, the ECDC and any other person that DEDEA feels should form part of this committee; This Committee that provides policy oversight on the overall functioning of Imvaba. This Committee will meet every month, championed and chaired by DEDEA, where the ECDC will present progress reports on the implementation, how the funds are used and challenges experienced; The monthly reports shall be submitted by the ECDC, on an agreed format, to this committee and discussed extensively. 20 | P a g e Imvaba Policy and Procedures Manual Minutes of these meetings shall be kept as records for future references, to be recorded by DEDEA. Quarterly Performance Reports will also be submitted to DEDEA and presented in this Committee for approval. 13. Check List of Required Documents 13.1 Business Plan of the Co-operative; 13.2 Fully completed Application Form; 13.3 Verifiable Co-operative Registration Certificate (signed by the Registrar or officially delegated official); 13.4 Constitution and Statute of the Co-operative (signed by all members); 13.5 Valid Tax Clearance Certificate; 13.6 Proof of Members Resolution to apply for the funds and designating members to conclude the necessary documents (signed by members); 13.7 Proof of Co-operative Bank Account and/or Bank Statement (signed by the Bank); 13.8 Quotations from different suppliers for needed equipment and material (signed by suppliers); 13.9 Short CVs (2 or 3 pages) of Board Members of the Co-operative, with their contact details including physical addresses. 14. Templates of Supporting Documents 14.1 Business Plan 14.2 Application Form Template 14.3 Loan Agreement Template 14.4 Criteria for accessing Imvaba Prepared by: ……………… Recommended by: ……………. Thabo Shenxane (Fund Manager) Ndzondelelo Dlulane Date: ……………………… Date:…………………… 21 | P a g e Imvaba Policy and Procedures Manual Approved by: ……………………………………… Sitembele Mase (ECDC:CEO) Date: ………………………………………… Approved by: ………………………………… Bulumko Nelana (HOD: DEDEA) Date: ……………………………………….. 22 | P a g e Imvaba Policy and Procedures Manual