This e-bulletin highlights key legislative and regulatory developments in the technology, media and telecommunications sectors in sub-saharan Africa. This issue covers the period 16 April 2021 to 15 July 2021 includes developments from Angola, Botswana, Eswatini, Ethiopia, Ghana, Kenya, Lesotho, Mauritius, Malawi, Namibia, Nigeria, Rwanda, South Africa, Uganda, Zambia and Zimbabwe.
Public Consultation on Regulation for the Determination of Operator with Significant Market Power
On 1 June 2021, the Angolan Institute of Communications (INACOM) published a Public Notice requesting comments from the public on the draft Regulation for Determining an Operator with Significant Market Power. The deadline for comments was 29 June 2021.
Final Report on Electromagnetic Field Monitoring, 2021-2022
On 28 June 2021, the Botswana Communications Regulatory Authority (BOCRA) published the Final Report on Electromagnetic Field Monitoring, 2021-2022. The objective of this Report is to show the outcome the Electromagnetic Field exposure measurements in selected mobile base stations across the country.
Draft Summarised Number Migration Report, 2021
On 28 June 2021, BOCRA published the Draft Summarised Number Migration Report, 2021. The aim of the migration exercise was to address the needs identified by the developed Numbering Policy in following areas: (i) uptake of the identified 10-digit numbering block for M2M communication services; (ii) expansion of the mobile numbering block to accommodate new allocations (including new MNOs or MVNOs); and (iii) activation of the SADC/CRASA harmonised numbers, Emergency Numbers and Child Helpline Numbers.
National Numbering Plan and List of Numbering Resource Allocations and Assignments, April 2021
On 6 July 2021, BOCRA published an updated Numbering Plan and List of Numbering Resources Allocations and Assignments as at April 2021. The prior version of this document was published on 19 March 2021. The purpose of the National Numbering Plan is to ensure transparent, non-discriminatory, and efficient number allocation, assignment and use of telecommunications numbers by service providers and end‑users for the provision and consumption of telecommunications services, respectively.
Type Approval Verification Guidelines (Sim-Enabled Devices), 2020
On 7 July 2021, BOCRA published the Type Approval Verification Guidelines (Sim‑Enabled Devices), 2020. The aim of these Guidelines is to (i) protect both the ICT networks and the consumers against adverse effects introduced about by the proliferation of non-Type Approved counterfeit and substandard devices; and (ii) ensure that the only registered devices are used in public networks.
National Cybersecurity Strategy, 2020-2025
On 3 June 2021, the Ministry of Information, Communications and Technology published the Eswatini National Cybersecurity Stratgy, 2020-2025, which describes the national approach to protecting Eswatini’s data, systems and networks from cyber threats and provides guidance to relevant stakeholders on their specific roles and responsibilities for cybersecurity.
Draft Mobile Network Operator Active Infrastructure Sharing and National Roaming Guidelines, 2021
On 12 May 2021, the Eswatini Communications Commission (ESSCOM) published the Draft Mobile Network Operator Active Infrastructure Sharing and National Roaming Guidelines, 2021 for public consultation. The objective of the Guidelines is to promote affordable and sustainable quality of active infrastrucure and national roaming services in Eswatini. The deadline for comments was 30 May 2021.
On 13 July 2021, the Ethiopian Communications Authority (ECA) published the following Directives:
- Telecommunications Interconnection Directive No. 791-2021;
- Telecommunications Licensing Directive No. 792-2021;
- Telecommunications Infrastructure Sharing and Collocation Directive No. 793‑2021;
- Telecommunications Quality of Service Directive No. 794-2021;
- Telecommunications Numbering Directive No. 795-2021;
- Telecommunications Dispute Resolution Directive No. 796-2021;
- Telecommunications Lawful Tariffs Directive No. 797-2021;
- Telecommunications Competition Directive No. 798-2021;
- SIM Card Registration Directive No. 799-2021; and
- Telecommunications Wholesale National Roaming Directive No. 800-2021.
Draft New Recommendation Approved and Published as ITU Standard
On 26 May 2021, National Communications Authority of Ghana (NCA) published a Ghana-led Draft New Recommendation E.805.1, QoS Operational Strategy for Improved Regulatory Supervision on Providers of Mobile Telecommunication Services, which has been approved and is currently in force as an ITU standard. The approval was given at the plenary of the ITU-T Study Group (SG) Twelve e‑meeting on Performance, QoS and QoE held from 6th to 7th January, 2021. In line with Resolution 95 of the World Telecommunication Standardisation Assembly (Hammamet, 2016), this Recommendation is expected to provide further guidance to Telecommunications Regulatory Authorities across the world on the best practices and policies related to service quality.
Terms of Reference for Development of Regulations for the National Information Technology Agency (NITA)
On 3 June 2021, the Ministry of Communications and Digitalisation published its Terms of Reference for the Development of Regulations for the National Information Technology Agency (NITA). The objective of this assignment is to review the legal and regulatory environment and develop appropriate draft regulations.
IPV6 Migration Strategy
On 4 May 2021, the Communications Authority of Kenya (CA) published the IPv6 Migration Strategy for public consultation. Noting the global trend regarding the use of Internet Protocol version 6 (IPv6), and taking into account the slow rate of adoption of IPv6 in Kenya, the CA developed the draft IPv6 migration strategy to increase the IPv6 adoption rate. The deadline for comments was 21 May 2021.
Draft Licensing and Shares Spectrum Framework for Community Networks
On 11 May 2021, the CA published the Draft Licensing and Shares Spectrum Framework for Community Networks for public comment. The Framework is intended to facilitate access to communications services in underserved areas by, among others, promoting the use of shared spectrum strategies. The deadline for comments was 1 June 2021.
Dynamic Spectrum Access Framework for Authorization of the use of TV White Spaces and the Procedure for Qualification of Geolocation Databases
On 13 May 2021, the CA published the Dynamic Spectrum Access Framework for Authorization of the use of TV White Spaces and the Procedure for Qualification of Geolocation Databases. The CA authorizes the use of TV white spaces (TVWS), in the 470-694 MHz UHF Spectrum band, currently allocated to the broadcasting service on a primary basis. White Space Devices will be authorized to operate in areas where specific channels are unused for Digital Terrestrial Television broadcasting.
Public Consultation on the Draft National Addressing System for Kenya Policy and National Addressing Bill, 2021
On 2 June 2021, the Ministry of ICT, Innovation and Youth Affairs published a Notice for Public Consultation on the Draft Policy on the National Addressing System for Kenya and National Addressing Bill, 2021, which are aimed at creating a legal framework for the development and regulation of addressing in Kenya. The deadline for comment was 15 June 2021.
Access to Information (General) Regulations, 2021
On 3 June 2021, the Kenya ICT Ministry, in consultation with the Commission on the Administration of Justice, published a Draft Access to Information (General) Regulations, 2021, for public comment, before it proceeds to the next stage. The objects and purpose of these Regulations is to (a) provide for the process for proactive disclosure of information by public entities and private bodies; (b) the procedure for requesting access to information pursuant to the Act; (c) record keeping by public entities and private bodies; (d) the procedure for reviewing a complaint of denial of access or refusal to correct a record; (e) oversight of compliance on the provisions of the Act; and (f) the procedure for reporting by public entities and private bodies. The deadline for comment was the end of June 2021.
Public Consultation on the Draft Guidelines for Network Redundancy, Resilience and Diversity on Information and Communication Networks in Kenya
On 20 April 2021, the CA published the Draft Guidelines for Network Redundancy, Resilience and Diversity (NRRD) on Information and Communication Networks in Kenya for public consultation. The Guidelines are intended to collect information on the status of NRRD by licensees in the sector and provide the empirical basis for potentially necessary regulatory interventions and appropriate procedures for use by network operators. The deadline for comments was 19 May 2021.
Draft Revised Guidelines for the Implementation and Provision of Voice over Internet Protocol (VoIP) Services, 2021
On 29 April 2021, the CA published a Summary of the stakeholder comments received on the Draft Revised Guidelines for the Implementation and Provision of Voice over Internet Protocol (VoIP) Services, 2021. The Draft Guidelines were published for comment on 30 March 2021 and the deadline for comments was 9 April 2021.
National Table of Frequency Allocations, 2020 Edition
On 13 May 2021, the CA published the National Table of Radio Frequency Allocations, 2020 Edition.
Draft Communications (Compliance Monitoring and Revenue Assurance) Regulations, 2021
On 25 June 2021, the Lesotho Communications Authority (LCA) published a Press Statement inviting the general public and industry stakeholders to submit written comments on the Draft Communications (Compliance Monitoring and Revenue Assurance) Regulations, 2021. The objective of the draft regulations is to provide conditions, requirements and procedures for monitoring of telecommunications traffic in Lesotho through the installation of the Compliance Monitoring and Revenue Assurance Tool (C-MART) that will assist in ensuring transparency in monitoring the regulatory compliance of the mobile network operators and mobile financial service providers. The deadline for comments is 24 August 2021.
Consultation Paper on Proposed Amendments to the ICT Act for Regulating the Use and Addressing the Abuse and Misuse of Social Media
On 29 April 2021, the Information and Communication Technologies Authority of Mauritius (ICTA) extended the deadline for comments on the Consultation Paper on Proposed Amendments to the ICT Act for Regulating the Use and Addressing the Abuse and Misuse of Social Media in Mauritius from 5 May to 20 May 2021.
Revised Deployment of Radiocommunication Infrastructure Technical and Administrative Standard for Electromagnetic Field (EMF) Safety
On 12 May 2021, ICTA published the responses to the consultation regarding the Revision of the Deployment of Radiocommunication Infrastructure Technical and Administrative Standards for EMF Safety, as well as the final Revised Deployment of Radiocommunication Infrastructure Technical and Administrative Standard for Electromagnetic Field (EMF) Safety document flowing from the consultation period.
Public Consultations on Communications (Tariff) Regulations, 2021
On 12 July 2021, the Malawi Communications Authority (MACRA) published its Final Report on the Public Consultation as well as the final version of the Communications (Tariff) Regulations, 2021. MACRA commenced the consultation process in November 2020 by publishing the draft of the Regulations and inviting stakeholders and the general public to submit written comments on the draft regulations. Following conclusion of the consultation process, MACRA has made a recommendation to the Minister of Information to promulgate the Regulations.
Request for Proposals (RFP) to Conduct a Market Definition and Competition Assessment for the Wholesale and Retail Communication Services Market
On 3 May 2021, MACRA published a Request for Proposals to Conduct a Market Definition and Competition Assessment for the Wholesale and Retail Communication Services Market. The main objective of the study is to define the wholesale and retail markets and undertake a market and competition assessment of the communication services sector in Malawi. The successful Consulting Firm is expected to carry out the assignment and deliver the final report within a period of six to nine months from the date of contract award. Opening of proposals took place at MACRA’s offices on 15 June 2021.
Public Consultation on Universal Service Projects, 2020/21
On 13 May 2021, MACRA published a Notice informing the public that the MACRA board and the Universal Service Committee have considered five Projects to be implemented under the Universal Service Fund in the 2020/2021 financial year. The projects are currently in the early stages of implementation and are the following: (i) Community Broadcasting Project; (ii) Digital Skills Project; (iii) Postal Service Project; (iv) Rural Broadband Project and (v) School Connectivity Project. On 18 May 2021, MACRA published a Stakeholder Consultation Notice on the Universal Service Projects requesting project proposals on Support for Digital Inclusion Projects, Support for Community Broadcasters and Support for Postal Projects and submissions for new areas of focus by stakeholders. The Fund will provide a series of grants for such small projects. The deadline for comments was 7 June 2021.
Regulations Prescribing Licence Fees and Regulatory Levies
On 22 June 2021, the Communication Regulatory Authority of Namibia (CRAN) informed stakeholders that it has revised the licence fees and regulatory levies, and gazetted the revised Regulations Prescribing Licence Fees and Regulatory Levies. CRAN also indicated that it will be hosting a workshop to educate all licensees on the methodology for the new license fees and levies framework. On 8 July 2021, CRAN informed stakeholders that the workshop will be held virtually on 23 July 2021.
Notice of Intention to Set Out the Frequency Channelling Plan for the Spectrum Bands 694-790Mhz
On 21 May 2021, CRAN gazetted a Notice of Intention to Set Out the Frequency Channelling Plan for the Spectrum Bands 694-790Mhz. Comments were due by 21 June 2021.
On 1 June 2021, CRAN gazetted a notice indicating that it will hold public hearings on 17 June 2021 from 10h00 to 11h30 regarding (i) the proposed Frequency Band Plan of Namibia, as published in Government Gazette No. 7350, General Notice No. 409 dated 02 October 2020; and (ii) the proposed Frequency Channelling Plan for the Spectrum Band 694-790 MHz, as published in the Government Gazette No. 7539, General Notice No. 196 dated 21 May 2021.
Notice of Intention to Amend Regulations regarding Rule-making
On 1 June 2021, CRAN gazetted a Notice of Intention to Amend Regulations Rule‑Making Procedures. The deadline for comments was 1 July 2021. The proposed amendments are aimed at ensuring that the regulations are in line with s129 of the Communications Act, 2009 (“the Act”) and repeal the process for requests for reconsideration of regulations made in terms of s129 of the Act for being inconsistent with s31 of the Act.
Public Notice on the Radio Frequency Spectrum Auction for 885 – 890 MHz and 930 – 935 MHz
On 3 June 2021, CRAN published a request inviting all interested parties to participate in the Spectrum Auction or 885 – 890 MHz and 930 – 935 MHz by submitting their applications to bid on or before 11 June 2021.
National Policy for the Promotion of Indigenous Content in the Nigerian Telecommunications Sector
On 7 May 2021, the Federal Ministry of Communications and Digital Economy published the National Policy for the Promotion of Indigenous Content in the Nigerian Telecommunications Sector.
Revised National Identity Policy for SIM Card Registration
On 11 May 2021, the Nigerian Communications Commission (NCC) published the Federal Ministry of Communications and Digital Economy’s Revised National Identify Policy for SIM Card Registration.
Notice of Public Inquiry on Draft Regulations on Annual Operating Levy and Frequency Pricing
On 9 June 2021, the NCC published a Notice of Public Inquiry on the Draft Annual Operating Levy Regulations, 2021 and Draft Frequency Spectrum (Fees and Pricing, Etc) Regulations, 2021. The deadline for comments was 5 July 2021, and Public Inquiries will be held on 29 July 2021.
Guidelines on National Roaming in Nigeria
On 5 July 2021, the NCC published the Guidelines on National Roaming in Nigeria. The objective of these Guidelines is to prescribe a regulatory framework for the implementation of National Roaming services in Nigeria.
Guidelines on Co-location and Infrastructure Sharing, 2021
On 5 July 2021, the NCC published the Guidelines on Co-location and Infrastructure Sharing 2021. The primary object of these Guidelines is to establish a framework within which Access Providers and Access Seekers can negotiate Co-location and Infrastructure Sharing arrangements,
Emerging Role of Data and Fintech in the Development of Digital Economy
On 28 April 2021, the NCC published a Research document on the Emerging Role of Data and Fintech in the Development of the Digital Economy. The Study will focus on and answer the following research questions: (i) What is the role of FinTech in the development of Digital Economy in Nigeria? (ii) What is the role of Data in the development of Digital Economy in Nigeria? (iii) What are the challenges to the achievement of Digital Financial Inclusion as needed for a Digital Economy in Nigeria.
NCC 2019 Annual Report
On 9 June 2021, the NCC published its 2019 Annual Report.
Regulation Governing Licensing in Electronic Communication
On 7 May 2021, the Rwanda Utilities Regulatory Authority (RURA) published the final Regulation Governing Licensing in Electronic Communication. The purpose of this Regulation is to provide a regulatory framework for efficient licensing, processes and procedures in the information communication technology industry.
Regulation Governing Digital Terrestrial Television Services
On 8 May 2021, RURA published the Regulation Governing Digital Terrestrial Television Services, which was gazetted on 3 May 2021. The Regulation establishes a licensing and regulatory framework for digital terrestrial television services.
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Proposed National Data and Cloud Policy
On 13 May 2021, the Department of Communications and Digital Technologies (DCDT) extended the deadline for comments on the Proposed National Data and Cloud Policy to 1 June 2021. The Policy was gazetted on 1 April 2021, and the original deadline was 18 May 2021. The Data and Cloud Policy seeks to strengthen the capacity of the State to deliver services to its citizens, ensure informed policy development based on data analytics, as well as promote South Africa’s data sovereignty and the security thereof.
Draft White Paper on Audio and Audiovisual Content Services Policy Framework: A New Vision for South Africa 2020
The DCDT held public hearings on the Draft White Paper between 10 May and 14 June 2021. This Draft White Paper seeks to create an enabling environment for the provision of inclusive audio and audiovisual content services (AAVCS) to all South Africans in a manner that promotes social- economic development and investment.
Cybercrimes Act No. 19 of 2020
On 26 May 2021, the President assented to the Cybercrimes Act No. 19 of 2020, and it was gazetted on 1 June 2021. The Act seeks to, among others, create offences which have a bearing on cybercrime and criminalise the disclosure of data messages which are harmful and to provide for interim protection orders. The Act will come into operation on a date fixed by the President by proclamation in the Gazette.
Copyright Amendment Bill and Performers’ Protection Amendment Bill
On 4 June 2021, the Portfolio Committee on Trade and Industry invited stakeholders and interested parties to submit written submissions with reference only to clause 13 (sections 12A, 12B, 12C and 12D), clause 19 (section 19B) and clause 20 (section 19C) of the Copyright Amendment Bill [B13B-2017].
Furthermore, the Committee invited stakeholders and interested parties to submit written submissions on the alignment of the Copyright Amendment Bill [B13B-2017] and the Performers’ Protection Amendment Bill [B24B-2016] with the obligations set out in international treaties, including the World Intellectual Property Organisation (WIPO) Copyright Treaty, the WIPO Performance and Phonograms Treaty, and the Marrakesh Treaty to Facilitate Access to Published Works for Person Who Are Blind, Visually Impaired, or Otherwise Print Disabled.
Submissions must be limited to the President’s reservations, issues raised beyond this cannot, in accordance with the Joint Rules of Parliament, be considered by the Portfolio Committee. The deadline for comments was 9 July 2021. Public hearings will be held on 4 and 5 August 2021 via a virtual platform.
South African Broadcasting Corporation SOC Ltd Bill, 2021
On 16 July 2021, the DCDT published the South African Broadcasting Corporation SOC Ltd Bill, 2021, for public comments. The Bill is intended to repeal the Broadcasting Act, 1999 (Act No. 4 of 1999) and to regulate the continued existence of the South African Broadcasting Corporation SOC Ltd. The deadline for comments is 31 August 2021.
Review of Information and Communications Technology (ICT) Covid-19 National Disaster Regulations
On 22 April 2021, the Independent Communications Authority of South Africa (ICASA) published a Media Release inviting written submissions from interested stakeholders in respect of the review of the Information and Communications Technology ICT COVID-19 National Disaster Regulations, as amended. The deadline for submissions was 7 May 2021. On 28 May 2021, ICASA gazetted the ICT COVID-19 National Disaster Fifth Amendment Regulations.
Digital Sound Broadcasting Services Regulations, 2021
On 23 April 2021, ICASA gazetted the Digital Sound Broadcasting Regulations, 2021. The objectives of these Regulations are to (a) set out the framework for the introduction of DSB services; and (b) prescribe the procedure for an applicant seeking to provide DSB services.
Draft Mobile Broadband Services Regulations, 2021
On 10 May 2021, ICASA extended the deadline for comments on the Draft Mobile Broadband Services Regulations, 2021 from 12 May 2021 to 28 May 2021. ICASA gazetted the Draft Mobile Broadband Services Regulations, as well as its Findings Document on the Mobile Broadband Services Inquiry on 26 March 2021.
Second Sport Broadcasting Services Amendment Regulations, 2021
On 13 May 2021, ICASA gazetted the Second Sport Broadcasting Services Amendment Regulations, 2021.
Draft Equipment Authorisation Regulations
On 24 May 2021, ICASA gazetted a Notice that the period for submitting written comments on the Draft Equipment Authorisation Regulations was re-opened from the date of publication of that notice until 31 May 2021.
Notice of Intention to Review the Pro-Competitive Conditions Imposed on Relevant Licensees in terms of the Call Termination Regulations, 2014 (as amended)
On 27 May 2021, ICASA’s gazetted a Notice of Intention to Review the Pro-Competitive Conditions Imposed on Relevant Licensees in terms of the Call Termination Regulations, 2014 (as amended). ICASA will commence and conduct the review in a series of phases. On 4 June 2021, ICASA published a Notice of its virtual workshop to be held on 11 June 2021, which was aimed at clarifying questions relating to the published questionnaire and any other matters related thereto.
On 18 June 2021, ICASA published the Notice of Public Hearings on the Discussion Document on the Review of the Independent Broadcasting Authority (Advertising, Infomercials and Programme Sponsorship), Regulations, 1999, which were held virtually on 14, 16 and 26 July 2021. The Discussion Document was gazetted for public comment on 26 March 2021, and the deadline for comment was 7 June 2021.
Public Hearings on Must Carry Regulations, 2021
On 2 June 2021, ICASA gazetted the Notice of Public Hearings on the Must Carry Regulations, 2021. The hearings were be held virtually on 28 June 2021.
Notice to Amend the Ordering System Specifications for Number Portability
On 27 May 2021, ICASA’ gazetted a Notice to Amend the Ordering System Specifications for Number Portability. The deadline for written representations was 17 June 2021.
Notice Calling for Comments on the Application for the Amendment of Transnet SOC Radio Frequency Licence
On 3 June 2021, ICASA issued a Notice calling for comments on the application for the amendment of Transnet SOC (“Transnet”) radio frequency spectrum licence in the 450 – 470 MHz band pursuant to Section 31(3) of the Electronic Communications Act 2005. The deadline for comments was 30 June 2021.
Draft Update of the National Radio Frequency Plan, 2021
On 9 July 2021, ICASA published the Draft Update of the National Radio Frequency Pan, 2021 for public consultation. The deadline for written submissions is 27 August 2021. Persons making representations are further invited to indicate whether they require an opportunity to make oral representations, including response to questions asked by the public and ICASA, which shall not exceed one hour. The public hearings will be held from 7 to 9 September 2021.
5G Annual Report, 2021
On 13 July 2021, ICASA published its 5G Annual Report, 2021, which provides an analysis and evaluation of the current status, readiness, and prospects for 5G in South Africa.
Draft E-Commerce Strategy
On 5 July 2021, the Ministry of ICT and National Guidance (Department of E-Services) indicated that it is undertaking the formulation of an E-commerce Strategy for Uganda. Stakeholders were invited to consider the draft E-Commerce Strategy and submit comments thereon.
Market Performance Report, Q1 2021
On 14 July 2021, the Uganda Communications Commission (UCC) published its Market Performance Report for Q1 of 2021. The first quarter saw increased digitisation and dependence on online messaging channels as social distancing, and remote work remained deeply ingrained in the workplace and social relationships.
Consultation Paper on the Proposed Revisions to the ICT Licensing Framework
On 4 May 2021, the Zambia Information and Communications Technology Authority (ZICTA) extended the deadline for comments on the Proposed Revision of the ICT Licensing Framework to 7 May 2021. The original deadline was 27 April 2021.
Draft Information and Communications Technologies (Radio Frequency Spectrum) Regulations, 2021
On 13 May 2021, ZICTA published the Draft Information and Communications Technologies (Radio Frequency Spectrum) Regulations, 2021.
Tariffs 2021 – Directives on the Implementation of Tariffs for Electronic Communication Services
On 11 June 2021, ZICTA published a Public Notice on Directives on the Implementation of Tariffs for Electronic Communication Services. ZICTA indicated that it had recently conducted an assessment of existing tariff plans on the market as well as their implementation modalities, and the assessment revealed a number of gaps related to compliance to the existing regulatory framework on the application and implementation of tariffs for electronic communication services. Consequently, ZICTA will be issuing directives aimed at enhancing compliance with all tariff regulatory requirements on the setting and implementation of tariffs for electronic communication services:
Draft Revised Type Approval Guidelines
On 21 April 2021, ZICTA published the Draft Revised Type Approval Guidelines for public comment. The revision of the Guidelines is aimed at addressing grey areas and insufficiencies in the current Guidelines. The deadline for comments was 30 April 2021.
Relatório Anual de Numeração, 2021
On 15 June 2021, ZICTA published the Annual Numbering Report, 2021.
Guidelines and Procedures for the Licensing of Converged Electronic Communications Services
On 29 July 2021, the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ) published the Guidelines and Procedures for the Licensing of Converged Electronic CommunicaNewtions Services in Zimbabwe.
This e-bulletin provides only general information on legislative and regulatory developments, which we consider key. It is not our intention to list all developments in the sector across Sub-Saharan Africa. For further information, please contact Wendy Rosenberg or Tebogo Sibidla of Advogados de Werksmans