If you need a reminder, the headline is borrowed from the late Queen of the UK and other Commonwealth realms. If you take offence at ‘borrowed’, consider that the British have borrowed a lot from South Africa and, in many cases, are still borrowing things, or is it they have been gifted? Potato, potahto? But that’s a discussion for another day.

Speaking about varying recollections, when was the last time you read an annual report? When did you last do so voluntarily? The more pertinent question would be when you did so of your own accord. There was a time when hard-copy annual reports were all the rage, but now most people tend to read the electronic format.

I am reminded of a boss dropping off an annual report for analysis and citing the German proverb: Paper is patient, paper does not blush. There are, of course, many adages on this theme. A few favourites include Friedrich Engels’ ‘Paper will bear anything that is written on it’ and Leon Trotsky’s ‘Paper is long suffering and will reproduce any madness that is imposed on it in the form of ink’. My personal favourite comes from American farmer Jonathan Clark Eagle: ‘A piece of paper does not care what you write on it; it just lies there’.

So, what lies within the pages of the International Trade Administration Commission of South Africa’s (Itacʼs) 2022/23 annual report? For some context, you might want to skim through my piece published in this column on July 19, titled ‘It’s fee trade, not free trade’. If you do not have the time, note that Itac intends to charge you for, among other things, permits and tariff applications once it publishes its ‘Administrative Fees Regulations’.

As with all things in life, there is not much of an expectation when something is free. However, once you have to pay for it, there is an expectation of an improved service. This brings us to page 58 of the Itac annual report: ‘Report of the External Auditor to Parliament on International Trade Administration Commission of South Africa’. For a detailed look, turn to page 60: ‘Custom Tariffs Investigations’.

• ‘Indicator – Customs Duty Rebate and Drawback Permits Issued Within 14 days’. “An achievement of 93% was reported against a target of 80%. However, the audit evidence did not support this achievement. We could not determine the actual achievement, but we estimated it to be materially less than reported. Consequently, it is likely that the achievement against the target was lower than reported.”

‘Import and Export Control: Indicator – Number of Unscheduled Inspections conducted’: “We were unable to obtain sufficient appropriate audit evidence that systems and processes were established to enable consistent measurement and reliable reporting of performance against the predetermined indicator definitions. This was due to a lack of controls and planning in place for the reported indicator. We were unable to validate the existence of systems and processes by alternative means.”

• ‘Other Matters – Achievement of Planned Targets’: “The annual performance report includes information on reported achievements against planned targets and provides explanations for over- and underachievements. This information should be considered in the context of the material findings on the reported performance information. Reasons for the underachievement of targets are included in the annual performance report on pages 36 to 41.” The pages are under the heading ʻPerformance Against Predetermined Objectivesʼ.

“Other Matters – Material Misstatements’: “We identified material misstatements in the annual performance report submitted for auditing. These material misstatements were in the reported performance information of Custom Tariffs Investigations and Import and Export Control. Management did not correct all of the misstatements and we reported material findings in this regard.” The last sentence you have just read should be of the gravest concern. It begs the question: Which ‘misstatements’ have not been corrected and what were the ‘material findings’? Should these not be stated, or at least contested?

Returning to Itac’s intended ʻAdministrative Fee Regulations’ – these should not only include targets but also state the recourse (compensation) if these targets are not met and, most importantly, be subject to an external audit.