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Our submission on the Lotteries Policy Document

Monday, December 3rd 2012

Our work is guided by the belief that ethical and strategic social investment, together with a professionally-run civil society sector, has the power to reduce inequality in South Africa. So we advocate for a long term, integrated and evidence-based approach to development.

GreaterGood South Africa and GreaterCapital welcome the majority of the proposals in the Draft Lotteries Policy Document and commend the DTI for a thoroughly researched, fair and well-articulated document. We endorse the submission on the Draft Lotteries Policy made by CMDS. Based on our experience of working with non profit organsations, corporates and development agencies, we have some additional comments and recommendations to make:

1. Independent advice and the use of impact metrics
Lottery funds should be channeled to the most efficient and responsible organisations that have the greatest impact in the communities they serve. we contend that the criteria for the awarding of Lottery funds should not be developed by a single individual (such as the Minister) nor the individuals that make up the National Lotteries Distribution Boards or the National Lottery alone but should be developed with independent advice, sector input and based on internationally accepted best practice as well as national priorities.Reporting on funds spent should be aligned to internationally accepted impact metrics such as IRIS.

2. Transparency, accountability and good governance
To improve the flow of funding into non profits, improve their effectiveness and counter public perceptions that donor funds are mismanaged, transparency, accountability and good governance within the sector are essential. We agree with CMDS that “The unification of the definitions and the qualifying/registration/exemption requirements of the Non-profit Organisations Act, the Income Tax Act and the Value-added Tax Act … will not only reduce administrative burdens for organisations but will also simplify the enabling environment that government has sought to introduce over recent years.” We also believe, in the interests of transparency and good governance, that the Income Tax Act should be amended to make it possible for the South African Revenue Service’s Tax Exemption Unit to make public the financial and compliance information they hold on public benefit organisations.

3. Sector sustainability
Organisations are unable to plan properly and deliver interventions that work when they are constantly in a hand-to-mouth fundraising position so we fully support the proposal to provide multi-year funding. We share CMDS’s concern about the proposal to limit the amount of NLDTF funding that can be used for personnel costs to 20%. The global evidence suggests that there is no correlation between staff and administration costs and impact and this practice can lead to funder-led development and ineffective programming. We believe that a professional and properly paid workforce in non profit organisations is essential for achieving the best outcomes in communities. 

GreaterGood SA and GreaterCapital are firmly committed to working to reduce inequality in South Africa and believe that civil society, with the support of National Lottery funding, has the ability to improve the lives of South Africans in marginalised communities and contribute substantially to a more equitable and caring society.

> Read the full submission

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GreaterGood SA Financial Report (2009/2010)
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