The Chamber provided comments on the draft NEEEF Bill. The table below summarizes our understanding of the core empowerment pillars and our perceptions of both their costs and benefits. We recommended the exclusion of pillars one and pillar two of the Namibia Equitable Economic Empowerment Framework.

Indicator	Beneficiary	Description	Assumptions	Perceived Costs	Perceived Benefits	Net Cost Benefit
Economic Ownership	Upper Class Well-connected	Selling of Equity stakes to FDPs	FDPs raises capital to pay for the stake in the company	Disruptive and intrusive law Lost FDI Capital flight Balance of payment pressures as foreigners sell out Over-exposures banks and diversion of funding from pressing challenges of housing and SME financing.	Improved corporate activity	Negative
Management control and employment equity	Upper Class and Middle Class	Racially representation on boards and top management and general employment	Company follow their normal appointment process to appoint directors and executives Employees are appointed on merit, companies remove ceilings in career advancement for previously disadvantaged persons	Requires formal racial classification and promotes racial polarization; blames white racism, brushes over complex causes of inter-racial inequality; erodes social trust and keeps focus on the past Pushes some citizens in the cold Brain drain divisive than cohesive racial quotas add to inefficiency	Diversified and expanded network of opportunities. Gained experiences provides formerly disadvantaged wider opportunities More diversified workforce	Negative
Human Resources and Skills Development	Middle Class	Skills development of racially disadvantaged employees	Requires companies to invest in the training of formerly disadvantaged persons which includes core skills	Increased labor costs	An improved skillset, improved productivity	Positive
Entrepreneurial development and marketing	Middle Class	Investing and supporting FDPs /entrepreneurs	Enterprise development becomes an effective tool to create or improve a company’s upstream and downstream partners	Sharing proprietary information Need to invest in program, monitoring and control systems	Reduced Costs Streamlined operations Improved quality products or reduced defective products More established businesses Significant business partners, suppliers or clients	Positive
Corporate Social Responsibility	Poor, Needy, Community	Investing in the community	Requires a company and its employees to be involved in the community	Increase in cost of doing business and reduced cash-flow to owners	Improved company positioning due to community involvement	Positive

Read the NCCI Comments on NEEEF here.