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Purpose and scope

This procedure sets out how SAQCC handles misconduct by, or a complaint against, any registered Accredited Training Provider (SDP), Registered Assessor or Registered Moderator. SAQCC is authorised by the Department of Employment and Labour (DoEL) and the relevant SETAs to execute disciplinary policy and procedure for non-compliance with the Occupational Health and Safety Act, the Mine Health and Safety Act, the Driven Machinery Regulations and the National Code of Practice for Lifting Machinery.

Every SAQCC-registered provider, and every assessor and moderator it uses, must comply with the Code of Good Practice — the standards of conduct set by the QCTO, the relevant SETA and SAQCC, read together with the QCTO accreditation conditions and the relevant Acts and Regulations. Where a registered party acts in breach of the Code, a disciplinary process — including audit, verification and moderation — will be initiated.

Principles of the procedure

The procedure exists so that fair, prompt, firm and consistent action can be taken whenever the conduct or performance of a registered party falls short of the Code. It is built on the following principles:

  • The primary objective is corrective — to restore compliance — unless the offence is serious enough that de-registration is warranted.
  • All disciplinary action conforms to the Code of Good Practice and to Schedule 8 of the Labour Relations Act 66 of 1995.
  • No registered party may be sanctioned without a fair process: the right to know the allegations, to state a case, to lead evidence, and to be heard before a decision is taken.
  • This Code is not exhaustive. It lists a range of offences and recommended action as a guideline; each case is judged on its own merits with discretion and sound judgement.
  • Any offence not specifically listed may still attract a penalty — a written warning, fine, suspension or de-registration — after a proper process.

Key terms used in this procedure

  • Defendant — the registered Accredited Training Provider, Registered Assessor or Registered Moderator against whom a complaint has been lodged.
  • Complainant — any person or organisation that lodges a complaint: a member of the public, an employer, a learner, a SETA or Association, or SAQCC itself.
  • Initiator — the person who presents the case at a hearing; ordinarily the relevant SETA Association's representative or a SAQCC official.
  • Disciplinary Committee — four SAQCC Board members representing the different SETAs; meets at least once a year to review policy, past actions and the performance of the disciplinary process.
  • Disciplinary Hearing Panel — an impartial panel convened to hear a specific case: an independent Chairperson assisted by at least one assessor with sound knowledge of the field concerned.
  • Appeal Committee — the panel convened to consider an appeal against a finding or a sanction.
  • Business day — any day other than a Saturday, Sunday or South African public holiday.

Grounds for disciplinary action

The tables below detail the most severe penalty for each listed offence. Each case is judged on its own merits, so a lesser sanction — or none — may apply depending on the circumstances. All cases are subject to investigation through a proper disciplinary process and the observance of full procedural fairness.

Offences ordinarily warranting de-registration

The following offences are serious enough that, on a first offence, they are referred directly to a SAQCC Disciplinary Hearing and may result in de-registration from the national database.

OffenceMaximum sanction
Fraud — the intentional act of deception intended to secure an unfair advantage or wrongful gain, involving misrepresentation, concealment or omission of the truth for financial benefit. SAQCC Disciplinary Hearing — De-registration
Dishonesty and misrepresentation of facts. SAQCC Disciplinary Hearing — De-registration
Actual or attempted bribery. SAQCC Disciplinary Hearing — De-registration
Failure to observe safety procedures and drills where such failure may cause damage to property or injury to any person (including self). SAQCC Disciplinary Hearing — De-registration
Falsification of any document to mislead by misrepresenting facts, including non-disclosure of a conflict of interest. SAQCC Disciplinary Hearing — De-registration
Working outside the scope of registration. SAQCC Disciplinary Hearing — De-registration
Issuing, or causing the issue of, a competency certificate to a learner who has not been properly trained and assessed as competent against the registered unit standard or skills programme. SAQCC Disciplinary Hearing — De-registration
Delivering training or issuing competency certificates while not registered with SAQCC, or after registration or accreditation has lapsed, been suspended or withdrawn. SAQCC Disciplinary Hearing — De-registration
Unauthorised use or forgery of another registered provider's, assessor's or moderator's name, signature, registration number, or of a certificate serial number. SAQCC Disciplinary Hearing — De-registration
Contravention of one or more clauses of the "Code of Good Practice for Accredited Training Providers". SAQCC Disciplinary Hearing — De-registration

Serious misconduct

The following offences are ordinarily dealt with first by the relevant SETA Association through a warning. They escalate to a SAQCC Disciplinary Hearing if they are repeated or are part of an ongoing pattern.

OffenceSanction
Negligence of proper procedures and performance of duties, or carelessness. Association Hearing — Written Warning
Misrepresenting facts on any document, including non-disclosure of required information. Association Hearing — Written Warning
Disclosure of confidential or sensitive information to any party not authorised to receive it. Association Hearing — Written Warning
Bringing SAQCC, a SETA or another registered provider into disrepute through media platforms, or making false or defamatory statements about them. Association Hearing — Written Warning
Non-payment of registration, verification or other fees owed to SAQCC. Written Warning — escalating to suspension or de-registration on continued non-payment

Minor offences

Minor offences are administrative or procedural lapses that do not involve dishonesty, a safety risk or harm to a learner. They are addressed first through counselling or a corrective notice; a minor offence that is not corrected, or that is repeated, escalates to a written warning.

OffenceSanction
Late or incomplete submission of learner uploads, or of the monthly Statement of Results. Verbal Warning / Corrective Notice
Failure to keep contact, accreditation or registration details current on the SAQCC database. Verbal Warning / Corrective Notice
Missing a moderation or verification deadline without prior arrangement. Verbal Warning / Corrective Notice
Failure to report observed non-compliance by another provider, assessor or moderator. Verbal Warning / Corrective Notice
Failure to produce the SAQCC registration or supporting documents when reasonably requested during an audit. Verbal Warning / Corrective Notice
Not using the prescribed SAQCC forms or templates for uploads, applications or site approvals. Verbal Warning / Corrective Notice

A minor offence is dealt with through the informal route by the relevant SETA Association. An uncorrected or repeated minor offence is escalated to a written warning and dealt with as serious misconduct.

Repeat offences. Regardless of the severity of any single offence, a registered party who commits more than one offence on a single occasion, or who receives more than two written warnings, may have its SAQCC registration removed.

De-registration outcomes

OutcomeWhat it means
De-register for 1 year, then under mentorshipDe-registered on the SAQCC national database. After completing a 1-year mentorship, the party may re-apply to SAQCC for re-registration.
De-register but work under mentorship for a fixed periodThe party works under a mentor for a fixed period agreed with the Association to fulfil specified requirements, then re-applies on completion of the mentorship period.
De-register for lifePermanent de-registration on the SAQCC national database.

Two disciplinary routes

Informal route — the Association

The relevant SETA Association investigates the alleged transgression. Where the breach is minor, the Association is empowered, on behalf of SAQCC, to issue a verbal or written warning and must copy SAQCC accordingly. Where the party is an employee of a company, the employer is also informed in writing. All written warnings are signed by the parties concerned, with a copy supplied to the SAQCC Disciplinary Committee. If the party refuses to sign, two witnesses may testify to that effect and sign the warning themselves.

Formal route — a SAQCC Disciplinary Hearing

Where the alleged transgression is of a serious or ongoing nature — or where guilt could lead to loss of registration — the Initiator informs the SAQCC Disciplinary Committee, which convenes a formal Disciplinary Hearing. The Code of Conduct is used as a guideline for laying charges and imposing sanctions; because the list is not exhaustive, the Chairperson applies reasonable discretion in deciding an appropriate sanction.

Who takes part in a hearing

  • Disciplinary Committee — four SAQCC Board Members representing the different SETAs; reviews policy and oversees the disciplinary process.
  • Chairperson of the hearing — appointed by the SAQCC Board; impartial and conversant with the Code and this Procedure. The Chairperson ensures the hearing is procedurally correct and makes recommendations on the finding and sanction.
  • Assessor / industry expert — at least one panel member with sound knowledge of the field concerned, to advise on the technical and practical application of the matter.
  • Initiator — the relevant SETA Association's representative, who presents the case and the evidence against the Defendant.
  • Defendant — the registered provider, assessor or moderator alleged to have contravened the Code.
  • Defendant's representative — another registered party or a subject-matter expert. Legal counsel is not permitted.
  • Witnesses — persons who witnessed the contravention or can lead relevant evidence.
  • DoEL — ordinarily does not participate in the hearing.

Lodging a complaint

A complaint may be lodged by a member of the public, an employer, a learner, a SETA or Association, or by SAQCC itself. A complaint must be brought within six months of the event — or within six months of the complainant becoming aware of it, where earlier knowledge was not reasonably possible.

The complaint must be made in writing on the prescribed form and must set out:

  • The full contact details of the complainant, the defendant and any witnesses.
  • A detailed description of the conduct complained of — including the time and place it occurred, and any injury or damage to a person, property or the interests of SAQCC.
  • Any aggravating or mitigating factors the complainant believes should be considered.
  • The specific offence relied on as the basis of the complaint.
  • All supporting evidence — statements, affidavits and documents — on which the complainant relies, and the signed declaration of the complainant.

Where a complaint is incomplete, SAQCC notifies the complainant of the defect. The complainant then has seven days to correct and resubmit it. A complaint is not referred to a hearing until it is procedurally correct.

Investigation and evaluation

Before any hearing is instituted, SAQCC — through the relevant Association — conducts an investigation to establish whether there are sufficient grounds to proceed. One or more investigators are appointed, and where specialist knowledge is needed an independent expert may be engaged. SAQCC may, at its discretion, first remind a party informally that its conduct may lead to a hearing and must be corrected; such counselling is not part of the formal disciplinary proceedings.

The Chairperson of the relevant Association then scrutinises the complaint to confirm that it concerns a permissible offence, was brought within the time limit, and discloses a prima facie case. Only then is the matter referred to a Disciplinary Hearing Panel.

Notice of the hearing

For a hearing to be procedurally fair, the Defendant must:

  • Be informed of the allegations in clear and understandable language.
  • Be given at least seven days' notice of the hearing, in writing, stating the date, time and venue.
  • Be informed of his or her rights in writing on the Notice to Attend.

The Defendant must notify SAQCC, in writing and at least three days before the hearing, of the names of any representative and witnesses. A request for a postponement must reach SAQCC at least five days before the hearing and must set out its merits. The Defendant may object to the impartiality of the Chairperson before proceedings begin; the Chairperson will recuse himself or herself if reasonable grounds exist.

If the Defendant fails to attend without a legitimate reason, or fails to respond to the notice, the hearing may proceed in his or her absence on the basis that the facts and evidence in the complaint are correct, and no representation by the Defendant will be allowed.

Conduct of the hearing

  1. The Chairperson opens the hearing, introduces the parties and explains the procedure.
  2. The allegations are read to the Defendant one by one, and the Defendant pleads to each.
  3. The Initiator presents the evidence and witnesses, each heard one by one; the Defendant may cross-examine.
  4. The Defendant presents his or her case and may call witnesses, who the Initiator may cross-examine.
  5. The Chairperson may ask questions for clarification, then adjourns to consider the evidence.
  6. The finding — guilty or not guilty — is announced. If not guilty, the Defendant is released.
  7. If guilty, the Defendant may present factors in mitigation and the Initiator any factors in aggravation, before the sanction is determined.
  8. The hearing is digitally recorded by the Chairperson and kept in safe custody by SAQCC. The finding, sanction and the right of appeal are confirmed to the Defendant and complainant in writing, ordinarily within seven days of the conclusion of the hearing.

The Defendant's rights

At a formal hearing, the Defendant is entitled to:

  • Adequate time to prepare, and to confer with a representative at reasonable times.
  • Be represented by another registered party or a subject-matter expert (not legal counsel).
  • Submit written statements and call witnesses relevant to the case.
  • Question the Initiator and any witnesses called against him or her.
  • Lead evidence and argue on whether the misconduct occurred, and argue in mitigation before a sanction is imposed.
  • The services of an interpreter, where requested in writing at least five days before the hearing.
  • Appeal the finding or the sanction within the time limit set out below.

Costs incurred by the Defendant or his or her witnesses — including travel, accommodation and any representation — are for the Defendant's own account, whatever the outcome of the hearing.

Sanctions

The Disciplinary Hearing Panel may impose one or more of the following sanctions, in proportion to the offence and after considering mitigation and aggravation:

  • Verbal warning or written warning — for less serious or first-time misconduct.
  • Final written warning — for repeated or more serious misconduct.
  • Fine — payable as the Panel determines, with an alternative sanction in the event of non-payment.
  • Mandatory re-training or re-assessment — the party must redo the applicable training or be re-assessed before continuing to operate.
  • Suspension of registration — for a defined period, with conditions for reinstatement.
  • De-registration — removal from the SAQCC national database, for a fixed period (with or without mentorship) or for life.

When imposing a sanction the Panel records the grounds on which the Defendant was found guilty and the reason for the sanction. Where a provision of law has been breached, SAQCC may also lay a criminal charge or institute legal proceedings.

Right of appeal

A Defendant may appeal a finding or a sanction within 30 days of receiving the outcome, by lodging a written Notice of Appeal with the SAQCC Disciplinary Appeal Committee. The notice must state the grounds of appeal — the substantive or procedural error relied on — and attach all supporting documentation.

The Appeal Committee ordinarily comprises:

  • A Chairperson nominated by the Disciplinary Committee;
  • A SAQCC Director;
  • The SAQCC Administrator / General Manager; and
  • A representative of the Department of Employment and Labour.

Appeals are ordinarily decided on the written record and submissions, although the Committee may call for oral submissions. No new facts may be introduced except in mitigation or aggravation; genuinely new evidence is referred back to the Disciplinary Hearing Panel. The Appeal Committee may uphold, set aside, reduce, alter or — after giving notice and convening a further hearing — increase a sanction, or refer the matter back for re-hearing. The parties are notified of the decision in writing.

If the Defendant remains dissatisfied after the appeal, a further appeal may be made to the Department of Employment and Labour within a further 30 days of receipt of the appeal outcome. The DoEL assesses the appeal and makes its findings known to the Defendant in writing.

Publication of disciplinary outcomes

SAQCC may publish a record of disciplinary action on the SAQCC national database and website, and may notify the relevant SETAs, Associations and regulatory authorities of any provider, assessor or moderator that has been suspended or de-registered. Any such publication complies with applicable legislation, including the Protection of Personal Information Act. The database is updated so that employers and the public can confirm, at any time, whether a provider's registration is current.

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