Notice of Clarification for the amended Codes of Good Practice as it has been gazetted and published today 05 May 2015

Dear Valued clients,

Please see attached communication from the DTI that provides some leeway and clarity on some issues that have been outstanding as we entered into the new phase of applying the 2013 Codes of Good Practice.  Important points to note:

1. If your financial year end is before 30 April 2015 and you have not yet completed your verification, you may continue to obtain a verification using the 2007 Codes requirements.  However, if your financial year end is after 01 May 2015, you will be required to use the 2013 Codes requirements, unless the Sector Codes are applicable to you.
2. If you are measured under a Sector Code, you may continue being rated according to that Code as the transition period has been extended to 31 October 2015.  New Sector Codes will only be effective from 01 November 2015, which means the current sector codes apply until then.
3. The big shocker- where your ownership includes Black participants in Broad-Based Ownership Schemes and Employee Share Schemes, these schemes will only be accounted for under paragraph 2.2.3 (Economic Interest for Broad Based Ownership Schemes and or Employee Share ownership Schemes ).  It is not yet clear what happens if a company has a normal trust that is neither broad based nor an employee ownership scheme.

There are other points raised in this clarification statement, and we would be happy to discuss further with you. Please do contact us.

The Empowerdex team