RE: REPORT TO THE PORTFOLIO COMMITTEE ON SAFETY AND SECURITY ON BUDGET VOTE 22 OF THE INDEPENDENT COMPLAINTS DIRECTORATE (ICD)
13 June 2005
I refer to the Committee’s report on the Budget Vote 22 of the ICD, in particular to a section of the said report titled "Committee findings and concerns." While the report makes correct reflections on a number of issues including on key policy issues affecting the vote and broad expenditure trends, I respectfully wish to provide the following further details to the Committee with a view to clarify or address some of the findings and concerns contained therein. In addition I wish to apologize humbly to the Committee, that the information contained herein was not sufficiently presented to the Committee previously.
In addition to our response to the Committee’s aforesaid Budget Vote report, I have also been requested by the Chairperson to present two additional reports to the Committee, viz. the Harrismith investigation and the reports on the disciplinary matter involving the Western Cape Provincial Head, Mr R Saloojee. The latter two (2) reports are attached hereto as Annexures E and F.
Table: 1: Travel & Subsistence Expenditure Per Responsibility
ED |
CFO |
P1 Manager |
P2 Manager |
P3 Manager |
ACC |
SD:Inv (N/O) |
|
Domestic: |
|||||||
Accommodation |
57,874.25 |
41,418.80 |
35,620.71 |
61,001.42 |
5,812.51 |
55.10 |
|
Daily Allowance |
4,174.81 |
3,791.30 |
1,300.40 |
3,036.74 |
592.56 |
942.14 |
1,673.50 |
Incidental Cost |
592.00 |
3,091.90 |
203.60 |
6,491.07 |
647.80 |
36.30 |
492.00 |
Car Rental |
37,840.16 |
||||||
Own Transport |
1,395.10 |
678.46 |
|||||
Km Allowance(SMS>500km) |
6,527.42 |
13,039.50 |
6,466.87 |
8,032.89 |
1,424.33 |
||
GG Vehicle |
56,520.12 |
||||||
Other Transport Provided |
|||||||
Air Transport |
65,550.30 |
43,553.40 |
65,061.69 |
69,093.00 |
16,466.80 |
4,718.00 |
2,291.40 |
Road Transport |
585.03 |
||||||
Foreign: |
|||||||
Accommodation |
2,135.17 |
||||||
Daily Allowance |
7,134.23 |
1,074.93 |
|||||
Incidental cost |
|||||||
Air Transport |
16,375.00 |
||||||
Road Transport(Bus/Taxi) |
194 |
||||||
198,398.27 |
104,894.90 |
108,653.27 |
148,730.05 |
24,944.00 |
64,251.79 |
5,135.36 |
Total expenditure for the ED, CFO, 3 X Programme Managers & the two components in National Office = R675 565, 39
Total expenditure for Top Management (ED and four X CD’s) = R606 178, 24
Table 2: Travel & Subsistence Expenditure Per Provinces
GP |
KZN |
WC |
EC |
NC |
FS |
MP |
LP |
NW |
|
Domestic: |
|||||||||
Accommodation |
8,058.97 |
75,836.11 |
51,093.95 |
69,745.12 |
51,983.43 |
94,514.08 |
137,395.03 |
43,961.96 |
128,133.98 |
Daily Allowance |
674.36 |
15,983.31 |
4,162.54 |
65,557.35 |
7,131.92 |
18,224.25 |
8,447.94 |
21,757.41 |
16,531.47 |
Incidental Cost |
811.03 |
9,504.35 |
89,831.58 |
35.00 |
713.80 |
1,295.28 |
474.61 |
4,723.50 |
3.943.10 |
Car Rental |
336.18 |
80.00 |
|||||||
Transport |
168,879.11 |
152,916.03 |
111,298.45 |
145,856.27 |
59,422.77 |
111,952.95 |
65,188.10 |
138,880.34 |
41,189.95 |
Km Allowance(SMS> 500KM) |
1,878.56 |
2,223.44 |
|||||||
Other Transport Provided |
2,115.00 |
5,555.97 |
27,126.87 |
||||||
Air Transport |
9,248.90 |
57,077.95 |
55,374.00 |
77,467.80 |
12,522.33 |
3,152.00 |
3,499.40 |
8,636.80 |
|
Road Transport |
486.98 |
624.00 |
23.00 |
395.00 |
390.00 |
117.66 |
|||
Foreign: |
|||||||||
Accommodation |
814.51 |
- |
|||||||
Daily Allowance |
3,838.04 |
682.14 |
- |
||||||
Incidental Cost |
7,523.39 |
||||||||
Air Transport |
|||||||||
Road Transport |
30.69 |
||||||||
188,159.35 |
318,839.73 |
311,783.52 |
360,884.98 |
132,169.25 |
232,405.70 |
220,561.05 |
252,610.27 |
231,779.96 |
Total expenditure for the 9 Provinces = R2, 249, 193.81
Explanation in respect of Table 1:
Explanation in respect of Table 2:
Top Management team (that is the four Chief Directors).
2. Insufficient details in the report and lack of data for 2004/2005
Complaints received by the ICD
Detailed report of all categories of cases received during the 2004/2005 financial year is attached and marked Annexure "A". The report indicates that the intake of complaints falling within the mandate of ICD from 1 April 2004 to 31 March 2005 amounted to 5 790, a decrease of 2% compared to the same period in the financial year 2003/2004. Cases recorded for the same period in 2003/2004 amounted to 5903. In the case of deaths, a decrease of 9% was recorded compared to the same period in 2003/2004. The actual number of deaths received during 2004/2005 is 652 compared to 714 received in 2003/2004. The decrease also manifested itself in respect of misconduct cases in that 3 407 misconduct cases were received in 2004/2005 compared to 3 716 received in 2003/2004. The said decrease translates to 8%. The only increase experienced was in respect of cases of criminality. 1 731 cases of criminality were recorded during 2004/2005 compared to 1 473 in 2003/2004. This increase translates to 18%.
The 652 death cases referred to above comprises of 128 natural deaths, 42 suicide cases, 45 cases of injuries sustained in custody, 71 cases of vigilantism, i.e. cases of injuries inflicted by members of the public prior to detention of the suspects and 366 cases of shootings. The 45 cases of injuries sustained in custody mainly refer to incidents where detainees fatally attacked fellow detainees.
The 42 suicide cases received in the 2004/2005 financial year represent a decrease of 59, 6% when compared to 104 suicide cases received in 2003/2004. Cases of injuries sustained in custody also fell by 44.4% when comparing the 45 cases received in 2004/2005 to 81 cases received in 2003/2004. The 366 shooting incidents also represents a 3.7% decrease in relation to 380 of such cases received in 2003/2004. It is however worth noting that cases of vigilantism have increased by 184% when comparing 25 cases received in 2003/2004 to 71 of such cases received in 2004/2005. A slight increase is also in respect of cases of natural deaths. 128 cases of natural deaths were reported in 2004/2005 compared to 124 of such cases in 2003/2004, representing a 3.2% increase.
In terms of a provincial breakdown of total cases received in 2004/2005, the following represents an intake at provincial level:
Hereunder follows brief commentary per province on the number and type of death related cases received during the period 2004/2005:
1.1 Eastern Cape
Eastern Cape received 70 death cases. The majority of death cases received relates to natural causes. There are a few cases pertaining to incidents of shootings.
Death cases reported in Free State are 38 and comprises largely of a combination of death due to natural causes, suicide and due to motor collisions.
Limpopo received 52 death cases. The majority of the death cases in this province relates to incidents of shootings. There are a few isolated cases of suicide or death due to natural causes.
Mpumalanga received 55 death cases. The death cases are a combination of shooting incidents and due to natural causes.
North West received 38 death cases. The province has a high number of death cases, which are attributed to natural causes. There are isolated cases of suicide and shooting incidents.
Most cases of deaths are attributed to suicide. This province received the lowest number of death cases, namely, eleven.
Death cases received number 65 and comprises of a combination of suicide, motor vehicle accidents and poisoning. There are however a few cases pertaining to shooting incidents.
KwaZulu Natal received the highest number of death cases viz. 175. This province has the largest number of cases pertaining to shooting incidents. There are a few isolated cases of natural deaths.
Gauteng received the second largest number of death cases, which numbered 148. Although Gauteng also has a large number of death cases pertaining to shooting incidents, suicide cases are just as high, followed by isolated cases of natural death. Interestingly, vigilantism seems to be a problem, but on an isolated scale at this stage.
The ICD acknowledges in principle that while it is important to produce and publish statistics pertaining to the intake of new cases on an annual basis, in the same breath, it is equally important to publish statistics on the outcome of such cases. To this effect, the ICD wishes to take this opportunity to advise on the outcome of finalized cases. With regard to cases of death received during 2004/2005, i.e, 652 cases received, the ICD was able to finalize 198 cases. Out of the 198 finalized cases, our investigations found that only 29 cases were substantiated, representing 15% and 169 or 85% were found unsubstantiated. With regard to cases of criminality, 332 were finalized. Out of the 332 finalized cases only 66 or 20% were found substantiated while 266 or 80% were found to be unsubstantiated. Finally, with regard to cases of misconduct, 1 103 cases were finalized. Out of the 1 103 cases only 443 or 40% of such cases were found to be substantiated while 660 or 60% were found to be unsubstantiated.
The Committee alluded to the fact that it is not possible for the Committee to reflect accurately on the forthcoming budget when the figures in terms of expenditure for the previous year are not made available. To this effect, the figures for the 2004/2005 financial year are presented as follows:
* Budget allocated for 2004/2005 = R42 114 000-00
* Total expenditure for 2004/2005 = R42 113 395-76
* Amount not spent = R604, 24
The balance of R604.24 represents a percentage of 0.001. Please find a copy of a detailed budget report marked Annexure "B".
From the above figures, it is evident that the ICD was able to spend almost the entire budget for 2004/2005. It is also proper to take this opportunity and give an indication of whether targets for the 2004/2005 financial year have been met or not, and also provide reasons in the event where some of the targets have not been met. A brief summary of operational targets and the actual performance against the said targets is presented as follows:
2.1 Investigation of Complaints
The ICD determined targets in respect of investigation of cases of deaths and criminality on the basis that 80% of such cases should be finalized within 180 days. With regard to cases of deaths received, i.e, 652, only 314 were eligible for finalization within 180 days. These are cases received from 1 April 2004 to 30 September 2004. Cases received from 1 October 2004 to 31 March 2005 will have their finalization period of 180 days or six months as falling outside the financial year 2004/2005. Drawing from this, the ICD was able to finalize 198 cases of deaths, within 180 days, representing a finalization rate of 63%. Only 314 cases of deaths were eligible for finalization within the 2004/2005 financial year. With regard to cases of criminality, 1 731 were received during 2004/2005, while only 812 cases fell within the finalization period of 180 days or six months. Only 332 cases of criminality were finalized, representing a finalization rate of 41%. Finally, with regard to misconduct cases, while 3 407 cases were received, only 2 508 fell within the finalization period of 90 days or three months. Only 1 103 out of 2 508 were finalized within 90 days or three months, representing a finalization rate of 44%.
In short, the finalization rate of various categories of cases within 180 days (in respect of cases of death and criminality) and 90 days (in respect of misconduct cases) is as follows:
* Deaths = 63%
* Criminal cases or offences = 41%
* Misconduct cases = 44%
Although these figures appear to be falling below the set targets of 80%, it must be understood that backlog cases finalized during 2004/2005 have not been taken into consideration. The ICD is contending with huge case backlogs emanating from previous financial periods dating as far as 2002/2003 and, in a worse case scenario, to 2001/2002. The total number of active files or backlog cases preceding the 2004/2005 financial year is 25 452. The total number of 25 452 is made up of the following cases:
* Cases of deaths = 4 723
* Criminal cases or offences = 5 755
* Misconduct cases = 14 974
These cases, together with cases received in 2004/2005, i.e., 5 790 cases, amounted to a total workload of 31 242 cases. The majority of these cases are still active even though they were received prior to 2004/2005 simply because they are still pending either in court or within the SAPS disciplinary sections. ICD Investigators, by virtue of the fact that they were the original Investigating Officers in these cases are expected to attend to court or disciplinary proceedings. These backlogs will continue to impact on the finalization rate as years go by. The reality of the situation is that investigation resources, particularly in terms of personnel, are increasingly constrained by inevitable backlogs. Therefore, the 80% target is only achievable where there are no backlogs. In other words, the ICD’s resources are able to achieve finalization in 80% of cases received during the specific financial year in the circumstances where there are no other backlog cases arising from preceding financial years.
In spite of these challenges, the ICD was able to secure the following criminal convictions against members during the 2004/2005 financial year:
* Sixteen (16) Murder convictions
* Three (3) Attempted Murder convictions
* Five (5) Culpable Homicide convictions
* Seven (7) Assault convictions
* Two (2) Theft convictions
* One (1) conviction on a charge of pointing with a fire-arm
* One (1) conviction on a charge of Intimidation
The sentences given by courts in all these convictions amounted to a collective total of 178 years. Apart from securing above criminal convictions, the ICD was able to secure 13 departmental convictions resulting in the following sentences:
* Ten (10) dismissals of members from the service
* Two (2) warnings
* One (1) fine to the tune of R2000-00
2.2 Complaints Registry
The target set for registration of new cases on the database is that at least 72% of new cases should be registered within 24 hours. This target was exceeded in that 95% of new cases were registered within 24 hours.
2.3 Monitoring
The target set is that 72% of applications for exemptions by SAPS members in respect of cases of non-compliance within the Domestic Violence Act are finalized. This target was also met and exceeded in that 100% of such applications were finalized. With regard to outreach programmes, the target of 12 outreach programmes per year per province was also met.
2.4 Conducting research
The ICD set a standard of four (4) research reports annually plus additional two (2) reports which must be tabled before Parliament in compliance with the Domestic Violence Act. During 2004/2005, the ICD component tasked with research work lacked research personnel to conduct the said task. The section was comprised of one manager at Director level plus a secretary. Obviously, the Director who was tasked with a variety of functions such as supervising the entire programme, i.e, the Information Management and Research programme in respect of registration of new cases, handling applications of exemptions aforementioned, station audits pertaining to implementation of DVA, as well as performing senior management functions such as serving in various committees and producing advisory reports to the Executive Director in respect of programme related matters, was not in a position to conduct research. Instead, the component focused its limited energy to lobbying the National Treasury for more funds and upon securing the said funds, to setting up a new Research Unit consisting of a Deputy Manager and three (3) Assistant Managers. Consequently, the target of 4 research reports could not be met except for the production of the DVA reports, which are still to be tabled before Parliament. Kindly refer to paragraph 9 below on further elaboration about the newly established Research Unit.
The Committee’s concern that the ICD is not submitting its reports to the Committee has been addressed by mailing the said reports to the Chairperson of the Committee. The Domestic Violence reports for 2003 and 2004 are still outstanding and are yet to be tabled for Parliament. The lack of research capacity caused the ICD not able to meet the target in this regard. Now that we do have this skills capacity, there will not be a recurrence of the aforesaid.
The Committee raised a concern that the manner in which the ICD presents its figures with regard to death in police custody or death as a result of police action may play a hand in feeding misconceptions with regard to misconduct. The concern emanated from the fact that while ICD attributed an increase in reported cases to outreach programmes, the Human Rights Watch Report stated that there is an increase in police misconduct.
I wish to take this opportunity to assure you that all our reports in this regard, including Annual Reports will henceforth reflect details in a manner that will make distortion of facts impossible. We are not only presenting details of cases of death received, but will show the outcome of investigations in respect of the very same cases. In other words, the outcome of investigations will be matched with the case intake for the same period. This approach will assist in terms of clarifying which incidents of death, police should be held accountable for and which ones cannot be attributed to police misconduct. The statistics for instance, will show different categories or types of incidents of deaths such as suicides, deaths related to natural causes, vigilantism, etc. The next level of statistics would then necessitate the investigation of the outcome of the said cases, which would clearly make a distinction between substantiated and unsubstantiated cases.
I must however emphasize that the Human Rights Watch at no stage consulted with us or consulted our Annual Report prior to the compilation and release of their report. Against this background, we worked closely with the Minister for Safety and Security as well as GCIS to negate the said report. We produced a comprehensive opinion dismissing the said report, and putting facts in their correct perspective. The opinion was published in the media including the Sowetan newspaper. A copy of the opinion is attached and marked Annexure "C".
All ICD members, including those at senior and top management level, are governed by the rules and regulations governing the public service in general. Officials at senior management positions are further governed by the Senior Management Service Handbook. Where there are allegations of misconduct against any member of the Senior Management Service, the Executive Director may identify and appoint any senior member in the Department who is higher in rank than the senior manager to be investigated or may approach officials from other government departments to conduct the investigation as the ICD has a limited pool of senior managers.
Where allegations of misconduct are directed against the Executive Director, the Minister as the Executing Authority and supervisor, may determine who and how such an investigation should be conducted. Alternatively, he may use the services of the Public Service Commission to conduct such an investigation and at the conclusion of such investigation they may make recommendations to him on the appropriate course of action. The Public Protector may on receipt of allegations of misconduct against the Executive Director or any of her top management, also institute an investigation.
The ICD has always been passionate about the plight of the rural communities and it is no surprise that our marketing drive has for the past four years targeted these communities. The challenges posed by areas that are very far from the provincial offices are real and not perceived and they involve delays in reaching the crime scenes timeously. A timeous arrival at a crime scene would be at least two hours from the time of receipt of notification of death. The police are obliged to notify the ICD of any death in custody or as a result of police action in terms of the National Instruction issued by the National Commissioner. We have been unable to reach some of the scenes reported to us within at least two hours due to the distance that has to be travelled from the provincial offices.
The offices which pose a bigger challenge in this case are the Eastern Cape, KwaZulu Natal, Free State and Northern Cape, to mention a few. If we use an example of the Northern Cape, it would take an ICD investigator at least eight (8) hours to reach a scene in Springbok, which is almost the furthest point of the province, while in KwaZulu Natal, it would take at least six (6) to seven hours to reach places such as Paul Petersburg, Pongola and Manguze which are about 750km from our office in Durban. The only solution to overcome this challenge would be to consider establishing satellite offices to ensure that the furthest service point is accessed within two hours or less. To this end, it would require strong investigation personnel to enable the ICD to establish these satellite offices. The idea of satellite offices has been discussed at various management forums in the ICD and there is agreement that this is a matter to be pursued but we all agree that it would require more than what we currently have to successfully run those satellite offices. This will not only ensure speedy response to scenes of deaths, but will speed up finalization of investigations and accessibility of our services. To illustrate the extent of the problem using two of our provincial offices, in the past few financial years, Northern Cape has recorded less than ten (10) deaths as opposed to KwaZulu Natal, which has recorded in excess of 150 deaths. The Northern Cape has three investigators while KwaZulu Natal has eight investigators to contend with cases of deaths and at the same time they have to deal with other categories of complaints of criminality and misconduct. If one considers the number of deaths recorded in Northern Cape, it makes sense, given the general staff complement of the ICD, that only three investigators have been assigned to do investigations in that province while eight investigators have been assigned for KwaZulu Natal. Truth of the matter is that the ICD requires more investigators to address these challenges.
The Department has a Personnel Performance Evaluation Policy in terms of which the performance of all employees is managed. The Performance Reward System is also built into the same policy to ensure that employees get rewarded for above average performance and corrective measures are implemented for below average performance.
In terms of process, the Department has three Evaluation panels, two for the employees below the level of Assistant Director and one for employees at the levels of Assistant and Deputy Director. This arrangement ensures that evaluations get finalized quicker. All Provincial Heads and their Deputies/Assistants, where applicable, are automatically members of these Evaluation Committees. Assistant and Deputy Directors are evaluated centrally at Head Office because they are very few and it wouldn’t be cost effective for the committee to move from province to province, to evaluate only one person. All other employees are evaluated at their respective workstations.
With regard to the alleged delay in paying employees who have been found to be performing above average, it takes about six weeks from the first day of evaluation to the last day of evaluation and about 2 to 3 weeks to process the results and payments. It is normal for employees to get disgruntled because they expect payments within days after they have been evaluated. Others feel they must be rewarded irrespective of their level of performance, whereas ICD has an obligation to manage performance honestly and to spend public funds responsibly.
There are various considerations that inform our decision as to which areas to conduct outreach programmes. These may be the result of an invitation by community structures such as NGO’s operating in a particular area, complaints of poor service delivery against a particular police station brought to our attention by community structures, advice centres or emanating from complaints we received on our database or policing problem gleaned from the media. We have dedicated periods of embarking on outreach programmes during the Imbizo, which occurs bi-annually and the Public Service Week. These outreach programmes are attended by the Senior Managers and the Executive Director and the Provincial Head of the province. The Provincial Heads are also expected in terms of their performance agreements to embark on dedicated marketing drives or community visits during the financial year and to report on their visits. More often than not the visits would also include visiting the local police stations.
Consequently, the ICD provincial offices visited the following communities during 2004/2005:
The establishment of the Proactive Oversight Unit (POU) by the ICD with effect from 1 May 2005 represents a significant milestone, and not only in terms of successful deployment of logistical support and personnel but also in terms of securing research skills and knowledge.
The process leading to the establishment of this Unit started in 2004. A partnership with a donor, namely, the Open Society Foundation (OSF) was entered into in terms of which OSF undertook to provide ICD with the following support:
Umhlaba Development Services (Umhlaba), a consultant, was then appointed and immediately assisted the ICD with the motivation for and business planning of the Unit. The said motivation and the business plan was then used successfully during the ICD presentation before the Medium Term Expenditure Committee (MTEC) in September 2004.National Treasury subsequently approved funding for the said unit to the tune of R1, 477 million for the 2005/2006 financial year.
Further discussions between ICD and OSF resulted in Umhlaba being requested to provide the ICD with the following support:
* Drafting of the advertisements for the vacant posts
* Shortlisting of candidates
* Convening the interviewing panel
* Participation on the interviewing panel
* Identifying external panelists for the interviewing process
To this effect, selection interviews were held on the 16 and 17 March 2005 in respect of four (4) newly created research posts, comprising of three (3) Assistant Managers and one (1) Deputy Manager. Final appointments have already been made. All three Assistant Managers assumed duty with effect from 1 May 2005. The Deputy Manager will assume duty effective from 1 June 2005.
The Unit, headed by the Deputy Manager, will report to the Programme Manager for the Programme: Information Management and Research. As mentioned previously, the Unit will be mandated to conduct quality research work on various policing aspects and to evaluate internal ICD efficiency. Also, of pivotal importance is the fact that an external Reference Group has been appointed to assist the Unit, mainly, in the identification of research projects and quality control.
I enclose for your attention a copy of a business plan, marked Annexure "D" which sets out the rationale behind the establishment and the research scope of the Unit and other general details pertaining to the Unit.
I must however take this opportunity to clarify the role of the ICD Research Unit vis-à-vis the Secretariat for Safety and Security. It is worth noting that while the Secretariat is tasked with providing oversight over the police strictly on matters of police performance, the ICD, on the other hand is strictly tasked to provide oversight on matters pertaining to police misconduct. Therefore, in as much as the Secretariat, at any stage, is not interested in conducting research on police misconduct, neither are the ICD’s research projects related to police performance. This means that the ICD’s research work is strictly within the confines of police misconduct, an area falling within ICD’s mandate. In other words, if ICD does not respond to this challenge, the area will still remain a void, as there would be no other oversight body to conduct research on police misconduct. Besides, the ICD is strategically positioned to carry out research on police misconduct by virtue of the wealth of information and data on this matter in its possession generated through its investigative activities. Our statistics, for instance, indicates that certain categories of misconduct cases such as criminal activities have increased immensely. Therefore, it would be inevitable to conduct study to establish why this is happening. Also, the statistics show certain police officers at a particular rank committing more offences than others. It is therefore important to conduct a study on why this is the case. In conclusion, there is no room for duplication between ICD research work and any other civilian oversight body including the Secretariat. The Reference Group will also bring together role-players from civil society, the ICD, SAPS and the Secretariat for Safety and Security. This Reference Group will serve to not only give direction and support to the research undertaken by the Unit, but also assist in ensuring synergy between the research functions of the Secretariat, SAPS and the Research Unit, thus avoiding any duplication of these functions. An initial Reference Group meeting, held on Tuesday, the 17 May 2005, assisted in identifying a number of research projects for the Unit to engage in, including an internal study into the backlog of cases waiting to be finalized, as well as a deeper study into the circumstances surrounding incidents of police misconduct and abuse of power. On the contrary, if the ICD does not carry out this function, it will not only amount to failure to execute its mandate and vision to the fullest, but there will certainly be a void in terms of this function. Civilian oversight bodies all over the world are moving towards complementing their reactive strategies with proactive methodologies including research strategies.
Having clarified the process leading to the establishment and the role of the Research Unit, it will suffice to mention that this process was fully motivated in writing to the Ministry for Safety and Security and then to the National Treasury’s Medium Term Expenditure Committee (MTEC).
Kind regards.
Yours sincerely
________________
ADV KD McKENZIE
EXECUTIVE DIRECTOR