Your ref: NAS/11/15/7
May 6th, 2026
The Office of the Clerk,
National Assembly of Zambia
Parliament Buildings
Lusaka
Dear Sirs,
Committee on Parastatal Bodies: Consideration of the Public Service Pensions Bill, NAB No. 69 of 2026 and the Local Authorities Superannuation Fund Bill, NAB No. 70 of 2026
Your letter dated May 4th, 2026 on the captioned subject matter refers. Thank you sincerely for inviting us to make written and oral submissions on the Public Service Pensions Bill, NAB No. 69 of 2026 and the Local Authorities Superannuation Fund Bill, NAB No. 70 of 2026.
We were pleased that we had been consulted throughout the process of the review and drafting of the Bills, and now their tabling before the National Assembly. We commend the Bill’s sponsors, among other stakeholders, for taking into consideration our submissions throughout the process.
We have noted that a number of issues we highlighted at the Tripartite Consultative Labor Council in January 2026, and at the Internal Legislative Committee of the Ministry of Justice in April, 2026, have been incorporated, leading to more refined Bills. There were however a number of lingering issues that are highlighted within our submissions enclosed herewith. They are principally on governance, legal accuracy, enforcement mechanisms and general grammatical errors.
We confirm that we will appear for oral submissions at the appointed time and venue of Thursday, May 7th, 2026 at 09.30 hours in Parliamentary Library, Parliament Buildings.
Kindly acknowledge safe receipt of this letter and its enclosure.
Yours faithfully,
ZAMBIA FEDERATION OF EMPLOYERS
Harrington Chibanda
EXECUTIVE DIRECTOR
Encl.
ZFE SUBMISSIONS ON
THE PUBLIC SERVICE PENSIONS BILL NO. 69 OF 2026
| CLAUSE | COMMENT | RECOMMENDATION | |
| 2. Interpretation“Estate” has the meaning assigned to the word in the Intestate Succession Act. | “Estate” is also defined under the Wills and Administration of Testate Estates Act, Cap 60.Clause 35 uses the term “estate”. Read in context, it is entirely possible that the member had died with a will. It would therefore create an ambiguity if only the Intestate Succession Act Cap 59 could be referred to. | Include the Wills and Administration of Testate Estates Act Cap 60 in this definition. | |
| 4. Functions of Public Service Pensions Fund4. The functions of the Public Service Pensions Fund are to—(a) administer and manage the Public Service Pensions Scheme, Occupational Pensions Scheme, Pensions Fund, and Occupational Pension Fund;(b) establish a home ownership scheme and other schemes;(c) register members to the Public Service Pensions Scheme and Occupational Pension Scheme;(d) collect contributions from members and the relevant authority under the Public Service Pensions Scheme and Occupational Pensions Scheme; and(e) pay benefits under this Act. | Clause 3 defines a “sub scheme” as:A distinct component within a larger scheme offering customized rules, benefits, value added services and contributions tailored to specific groups.There is no reference to sub schemes under the functions of the Fund in clause 4. Yet, sub scheme creation and administration are provided for under clause 59. | Are the “home ownership schemes and other schemes” under clause 4(c) the “sub schemes”? If they are, then paragraph (c) needs to reflect that. If they are not, clause 4 needs to include sub schemes within the functions of the Fund so that clause 59(2) has an anchor. | |
| 5. Board of Fund(1) There is constituted the Board of the Public Service Pensions Fund which consists of the following part-time members appointed by the President:…(k) one person from the private sector with knowledge and experience in matters relevant to this Act. | Paragraph (k) of subclause (1) does not sufficient criteria. “Knowledge and experience in matters relevant to this Act” can mean anything from investments to actuarial science to accountancy to law. Or to nothing more than having worked for the public service for some years and then retired. It is simply insufficient to guarantee that the position will not be used for political patronage or that someone competent will be appointed. That is more so that the President can select this individual as the chairperson of the Board under subclause (3).We submitted before the Committee on National Economy, Trade and Labor Matters on April 20th, 2026 in relation to the expanded inclusion of the private sector on statutory boards. We had submitted on, among other Bills, the Public Service Pensions (Amendment) Bill NAB No. 9 of 2026.We had submitted that “private sector” was vast and in the absolute majority in the country, when compared with the public sector. While we applauded the expanded inclusion of the private sector, we urged stronger criteria on the eligibility of candidates for Board positions.We advocated for at least four criteria:Skill identified by a recognized qualification;Identification of relevant specializations for the qualifications;A minimum level of experience; andRegistration with a recognized professional body.Item (iv) is particularly important for the aspect of “proven integrity” under subclause (5)(a). That is because recognized professional bodies tend to have codes of ethics or conduct. | The National Pension Scheme Bill No. 68 of 2026 has a good formulation. In our view, only registration with a recognized professional association is what is missing from there and this was what we had submitted to the Committee on Media and ICT on May 4th, 2026.Clause 6(2)(c) of the NPS Bill No. 68 of 2026 provides, inter alia, that the board member –(c) has knowledge and experience of at least five years in—(i) social security administration;(ii) insurance;(iii) banking;(iii) accounting and finance(iv) auditing;(v) risk management;(vi) economics;(vii) law;(viii) investments;(ix) actuarial science;(x) data science; or(xi) any other discipline relevant to social security administration.We recommended the addition of registration with a recognized professional body.We therefore recommend that in this Bill No. 69 of 2026, paragraph (k) is expanded or subject to an additional provision that requires the four criteria we recommended for private sector participation on statutory boards, being:Skill identified by a recognized qualification;Identification of relevant specializations for the qualifications;A minimum level of experience; andRegistration with a recognized professional body. | |
| 7. Director General(3) A person qualifies for appointment as Director-General if that person—(a) holds a degree or an equivalent qualification relevant to the functions of the Public Service Pensions Fund recognized by the Zambia Qualifications Authority; and(b) has experience relevant to the functions of the Public Service Pensions Fund. | There is no reason whatsoever for the DG of PSPF to have fewer qualifications that the DG of NAPSA. They are both in charge of public funds under public social security schemes. There are more than enough qualified individuals in the country to recruit only the best.Clause 8(3) of the NPS Bill No. 68 of 2026 provides:(3) A person qualifies for appointment as Director-General if that person—(a) has proven integrity;(b) holds a degree or an equivalent qualification recognized by the Zambia Qualifications Authority in accordance with the Zambia Qualifications Authority Act, 2024;(c) holds a post graduate degree recognized by the Zambia Qualifications Authority in accordance with the Zambia Qualifications Authority Act, 2024;(d) has at least ten years work experience at seniormanagement level;(e) has not been convicted of an offence involving fraud or dishonesty; and(f) has not been convicted of an offence under this Act or any written law and is sentenced to imprisonment for a term exceeding six months without an option of a fine. | Amend subclause (3) to include all the criteria for the DG provided in the NPS Bill No. 68 of 2026. | |
| 17. Mandatory contributions(7) The relevant authority shall, where the relevant authority fails to pay mandatory contributions under this section, pay a penalty on the unpaid amount of the mandatory contributions at an interestrate of eight percent above the prevailing Bank of Zambia monetarypolicy rate.(8) Despite subsection (7), the Public Service Pensions Fund may waive the whole or part of the penalty referred to under that sub-section on terms and conditions as may be prescribed. | We appreciate that the purpose of a penalty for late remittance of contributions is to deter such late payment. However, the penalty should be reasonable and practical if enforced.PSPF is for the public sector, which is mainly the Central Government. Is it likely that Central Government will pay this penalty, or will the Fund that is within the portfolio of the Republican President simply grant waivers and thereby make subclause (7) redundant upon enactment?Furthermore, the monetary policy rate (MPR) fluctuates. That means that unlike in the case of the National Pension Scheme where contributing employers can project their financial exposure for failure to remit contributions on time, the “relevant authority” contributing to PSPF will not be able to. Government budgets can only be adjusted mid-year with difficulty. There must be greater certainty with the penalty for late remittance. | The interest rate is too high and uncertain.A rate comparable to the one under the National Pension Scheme can be used, being ten percent (we have already submitted that it should be less because that ten percent is still too high). | |
| 20. Contributions while on secondment or unpaid leave20. (1) Subject to subsection (2), where a member is absent from duty, and the absence is authorized by the relevant authority—(a) in the case of unpaid leave and the member elects to make contributions, the member shall pay the contribution consisting of the relevant authority’s contribution and the member’s contribution;…(3) The relevant authority, receiving employer or member who fails to pay contributions under this section is liable to pay a penalty on the unpaid amount of the contributions at an interest rate of eight percent above the prevailing Bank of Zambia monetary policy rate. | Clause 20 appears to provide that an employee on unpaid leave may elect to continue making contributions to PSPF. However, if they do make that election but are late in making the payment, they will face the penalty of MPR + 8%.Realistically speaking, an employee would never voluntarily put themselves in that position. They would prefer to accept that period of unpaid leave will not be part of their pensionable service. | Re-evaluate the practicality of this provision in relation to the member electing to continue contributing from their own funds.We recommend that such contributions be treated as voluntary. | |
| 59. Sub schemes(1) The President may, on the recommendation of the Public Service Pensions Fund, by statutory instrument, establish sub schemes and provide for the rules of the sub-schemes. | Clause 3 defines a “sub scheme” as:A distinct component within a larger scheme offering customized rules, benefits, value added services and contributions tailored to specific groups.The selection of customized benefits, etc. should only be done after a full assessment of what is already available on the market. That will guard against unnecessarily incurring financial risk by providing services already available elsewhere, possibly more sustainably.The Pensions and Insurance Authority (PIA) has the statutory mandate to advise the Government on social security in the country. As the regulator, it is a key institution to consult on what is already on the market and on market development in pensions products. | We advocated for PIA to be consulted when NAPSA aims to create sub-schemes. That is now in Bill No. 68 of 2026. We recommend that the same be incorporated in this Bill.Amend subclause (1) to:The President may, on the recommendation of the Public Service Pensions Fund and in consultation with the Pensions and Insurance Authority, by statutory instrument, establish sub schemes and provide for the rules of the sub-schemes. | |
| (3) The funds of a sub-scheme shall be managed separately from the funds of the Public Service Pensions Scheme andOccupational Pensions Scheme. | Clause 3 defines a “sub scheme” as:A distinct component within a larger scheme offering customized rules, benefits, value added services and contributions tailored to specific groups.Thus, if the sub-scheme is only a component within a scheme, how practical is it to manage the funds separately? | Amend if appropriate. | |
| 66. Protection of benefits(2) The benefits of a member shall not form part of the benefits of the member in the event of the member’s bankruptcy. | This appears to be a typographical error, | Amend subclause (2) to:(2) The benefits of a member shall not form part of the assets of the member in the event of the member’s bankruptcy or insolvency. | |
| 69. Joint venture, partnership and co-investment | “the” person at line 25 under subclause (1) is a typographical error. | Correct to “a” person. | |
| 77. Regulations77. (1) The President may, on the recommendation of the PSPF, make Regulations for the better carrying out of the provisions of this Act.(2) Despite the generality of subsection (1), Regulations made under that subsection may make provision for the—…(j)investment of monies of the Pensions Fund and Occupational Pensions Fund. | The Pensions and Insurance Authority (PIA) is the regulator of private pension schemes, and there is an intention to include the supervision of public schemes within its mandate. PIA has substantial expertise in prudential supervision of investment of scheme funds. This is evident through the Pension Scheme (Investment Guidelines) Regulations, SI No. 50 of 2021, which revoked and replaced SI No. 141 of 2011.The investment of public funds should not be left to the decision of the President and PSPF. There must be wider consultation in the investment guidelines, to ensure transparency and prudent management. | Paragraph (j) of clause 77(2) must be subject to consultation with PIA as the technical and regulatory expert on prudential investments. | |
| FIRST SCHEDULEPart I: Administration of the Public Service Pensions Fund | |||
| 3. Tenure and vacancy of office of member of Board(1) The office of a member of the Board becomes vacant if that member—…(h) ceases to be an employee or a member of the ministry, institution or organisation that nominated the member; or | Clause 5(1) of the Principal Act does not use the description “employee or member” for the nomination of a Board member from the relevant institution. It uses the term “representative”.The “or” at the end of paragraph (h) is hanging because there is no provision that follows it to close the list. | Amend paragraph (h) to:(h) ceases to be a representative of the ministry, institution or organization that nominated the member.Delete the “or” at the end of the provision if there is nothing else that will be added. | |
| FIRST SCHEDULEPart II: Financial provisions | |||
| Paragraph 10. Funds of PSPF(4) There shall be paid from the funds of the Public ServicePensions Fund—…(b) reasonable travelling and other allowances for the members of the Board, members of a committee of the Board and staff of the Public Service Pensions Fund when engaged in the business of the Public Service Pensions Fund at rates that the Emoluments Commission may, on the recommendation of the Minister determine; and… | The entire Bill refers to the President as being the portfolio Office. Is it appropriate to bring the “Minister” in under this provision? | Amend as appropriate. | |
| SECOND SCHEDULESavings and Transitional Provisions | |||
| 2. Member of former BoardA person who, immediately before the commencement of this Act held office as a member of the former Board shall continue to hold office until the expiry of the term of office, or removal by the President, after which the President shall appoint members of the Board in accordance with this Act | Clarify whether Board members of the former Board are eligible for appointment under the new Act, or will be subject to the two-term limit under paragraph 2(1) of Part I of the First Schedule. | ||
| 8. Transfer of assets and liabilities(2) Subject to subparagraph (1), every deed, bond and agreement, other than an agreement for personnel service… | The correct term is “personal service”, not “personnel service”. | ||
ZFE SUBMISSIONS ON
THE LOCAL AUTHORITIES SUPERANNUATION FUND BILL NO. 70 OF 2026
| CLAUSE | COMMENT | RECOMMENDATION | |
| 2. Interpretation“Estate” has the meaning assigned to the word in the Intestate Succession Act. | “Estate” is also defined under the Wills and Administration of Testate Estates Act, Cap 60.Clauses 36 and 42 use the term “estate”. Read in context, it is entirely possible that the member had died with a will. It would therefore create an ambiguity if only the Intestate Succession Act Cap 59 could be referred to. | Include the Wills and Administration of Testate Estates Act Cap 60 in this definition. | |
| “Sub scheme” means a sub scheme established in accordance with section 51. | Neither this definition not clause 51 have any description of what a “sub scheme” is. | Add the definition used under the PSP Bill No. 69 of 2026, being:A distinct component within a larger scheme offering customized rules, benefits, value added services and contributions tailored to specific groups. | |
| “Technical education, vocational and entrepreneurship training institution” means an institution that provides technical education, vocational and entrepreneurship training, whether by distance learning or otherwise. | This definition is inconsistent with the definitions of “higher education institution” and “school education”. Both those definitions refer to the legislation under which those levels of education are regulated. TEVET education is regulated by the Technical Education, Vocational and Entrepreneurship Training Act No. 13 of 1998.Other similar definitions refer to the enabling statute, including “Zambia Qualifications Authority”. | Amend the definition of “Technical education, vocational and entrepreneurship training institution” to include the legislation under which such institutions are regulated. | |
| 4. Functions of LASF4. The functions of the LASF are to—(a) administer and manage the Superannuation Scheme, Occupational Superannuation Scheme, Superannuation Fund and Occupational Superannuation Fund;(b) register members and employers to the Superannuation Scheme and Occupational Superannuation Scheme;(c) collect contributions from members and registered employers under the Superannuation Scheme and Occupational Superannuation Scheme; and (d) pay benefits provided under this Act. | There is no reference to sub schemes under the functions of the Fund in clause 4. Yet, sub scheme creation and administration appears at clause 51. | Include the administration and management of sub schemes as one of the functions, in order to anchor clause 51 on clause 4. | |
| 5. Board of Fund(1) There is constituted the Board of the LASF which consists of the following part-time members appointed by the Minister:…(f) two persons from the private sector with knowledge and experience in matters relevant to this Act; and(g) one person from the public sector with knowledge and experience in matters relevant to this Act. | “Knowledge and experience in matters relevant to this Act” can mean anything from investments to actuarial science to accountancy to law. Or to nothing more than having worked for the local authorities for some years and then retired. It is simply insufficient to guarantee that the position is not used for political patronage or that someone competent will be appointed. That is more so that these are the categories from which the Minister will appoint the chairperson.Moreover, that criteria effectively duplicates subclause (5)(b).We submitted before the Committee on National Economy, Trade and Labor Matters on April 20th, 2026 in relation to the expanded inclusion of the private sector on statutory boards. We had submitted on, among other Bills, the Public Service Pensions (Amendment) Bill NAB No. 9 of 2026.We had submitted that “private sector” was vast and in the absolute majority in the country, when compared with the public sector. While we applauded the expanded inclusion of the private sector on statutory boards, we urged stronger criteria on the eligibility of candidates for board positions.We advocated for at least four criteria:Skill identified by a recognized qualification;Identification of relevant specializations for the qualifications;A minimum level of experience; andRegistration with a recognized professional body.Item (iv) is particularly important for the aspect of “proven integrity” under subclause (5)(a). That is because recognized professional bodies tend to have codes of ethics or conduct.While these submissions were on the private sector, they apply equally to paragraph (g) because there should be criteria for that public sector appointee as well. | The National Pension Scheme Bill No. 68 of 2026 has a good formulation. In our view, only registration with a recognized professional association is what is missing from there and this was what we had submitted to the Committee on Media and ICT on May 4th, 2026.Clause 6(2)(c) of the NPS Bill No. 68 of 2026 provides, inter alia that the board member –(c) has knowledge and experience of at least five years in—(i) social security administration;(ii) insurance;(iii) banking;(iii) accounting and finance(iv) auditing;(v) risk management;(vi) economics;(vii) law;(viii) investments;(ix) actuarial science;(x) data science; or(xi) any other discipline relevant to social security administration.We recommended the addition of registration with a recognized professional body.We therefore recommend that in this Bill No. 70 of 2026, the criteria for paragraphs (f) and (g) be elaborated upon with: Skill identified by a recognized qualification;Identification of relevant specializations for the qualifications;A minimum level of experience; andRegistration with a recognized professional body. | |
| 7. Director General(3) A person qualifies for appointment as Director-General if that person—(a) holds a degree or an equivalent qualification relevant to the functions of the Public Service Pensions Fund recognized by the Zambia Qualifications Authority; and(b) has experience relevant to the functions of the LASF. | There is no reason whatsoever for the DG of LASF to have fewer qualifications that the DG of NAPSA. They are both in charge of public funds under public social security schemes. There are more than enough qualified individuals in the country to recruit only the best.Clause 8(3) of the NPS Bill No. 68 of 2026 provides:(3) A person qualifies for appointment as Director-General if that person—(a) has proven integrity;(b) holds a degree or an equivalent qualification recognized by the Zambia Qualifications Authority in accordance with the Zambia Qualifications Authority Act, 2024(c) holds a post graduate degree recognized by the Zambia Qualifications Authority in accordance with the Zambia Qualifications Authority Act, 2024;(d) has at least ten years work experience at senior management level;(e) has not been convicted of an offence involving fraud or dishonesty; and(f) has not been convicted of an offence under this Act or any written law and is sentenced to imprisonment for a term exceeding six months without an option of a fine. | Amend subclause (3) to include all the criteria for the DG provided in the NPS Bill No. 68 of 2026. | |
| 19. Mandatory contributions(7) A registered employer who fails to pay mandatory contributions under this section is liable to pay an administrative penalty on the unpaid amount of the mandatory contributions at an interest rate of eight percent above the prevailing Bank of Zambia monetary policy rate.(8) Despite subsection (7), the Local Authorities Superannuation Fund may, for contributions in relation to the Superannuation Scheme, waive the whole or part of the penalty referred to under that subsection on terms and conditions as may be prescribed. | We appreciate that the purpose of a penalty for late remittance of contributions is to deter such late payment. However, the penalty should be reasonable and practical if enforced.Local authorities have struggled to remit social security contributions for a long time. Adding such a high penalty will not change that. It will only make it worse. LASF will end up granting waivers and thereby make subclause (7) redundant upon enactment.Furthermore, the monetary policy rate (MPR) fluctuates. That means that unlike in the case of the National Pension Scheme where contributing employers can project their financial exposure for failure to remit contributions on time, the “registered employer” contributing to LASF will not be able to. There must be greater certainty on the penalty for late remittance. | The penalty rate is too high and uncertain. A rate comparable to the one under the National Pension Scheme can be used, being ten percent (we have already submitted that it should be less because that ten percent is still too high). Local authorities have significant financial challenges that will take time to resolve before they have the capacity to pay fluctuating penalties that cannot necessarily be budgeted for. | |
| 22. Notification of termination of employment, resignation and placement on unpaid leave or secondment | Secondment does not automatically mean that the employer stops paying wages. The terms of secondment are to be agreed upon or set in the conditions of service. | Qualify the required notification of secondment to circumstances where the registered employer is not going to pay the member’s emoluments during that period.This qualification should also be made to clause 23 as the obligation to make contributions will only be if the other registered employer has taken on the emoluments of the member. | |
| Another method of reduced or removed wages is through section 48 of the Employment Code Act Cap 268 on forced leave, and the exemption from paying basic pay during forced leave that can be granted by the Labor Commissioner under SI No. 48 of 2020.This must be provided for expressly to ensure that there are no gaps between the laws. Unpaid leave is not the same as forced leave with an exemption from paying basic pay. It is still “forced leave” under the law while unpaid leave is a contractual matter. | Include forced leave under subclause (1) and provide for the possibility of an exemption from basic pay.Include a new paragraph under subclause (2) as an event that leads to the ceasing of the requirement for contributions if the exemption from basic pay under the Employment Code Act Cap 268 has been granted by the Labor Commissioner. | ||
| 28. Attachment of debts(1) The Local Authorities Superannuation Fund may, where a contribution due from a registered employer or member remains unpaid, by notice, in writing, require that the unpaid contribution be paid to the Local Authorities Superannuation Fund by a person— | The NPS Bill No. 68 of 2026 at clause 29(1) provides:The Director-General may, where a contribution due from a contributing employer remains unpaid, by notice, in writing, require that an amount, or so much as is sufficient, to discharge up to fifty per cent of the contributions due from the contributing employer, be paid to the Authority by a person—Clause 28 in the LASF Bill provides for attachment equivalent to the entire unpaid contribution. The NPS limitation to 50% is more practical as it leaves something for the employer to continue operating. | Amend subclause (1) to reduce the power of attachment to 50% of unpaid contributions. | |
| 51. Sub schemes(1) The Minister may, on the recommendation of the Local Authorities Superannuation Fund, by statutory instrument, establish sub schemes and provide for the rules of the sub-schemes. | Clause 3 has no substantive definition of “sub scheme”. We recommended adopting the one in the PSP Bill No. 69 of 2026, being:A distinct component within a larger scheme offering customized rules, benefits, value added services and contributions tailored to specific groups.The selection of customized benefits, etc. should only be done after a full assessment of what is already available on the market. That will guard against unnecessarily incurring financial risk by providing services already available elsewhere, possibly more sustainably.The Pensions and Insurance Authority (PIA) has the statutory mandate to advise the Government on social security in the country. As the regulator, it is a key institution to consult on market development in pensions products and on what is already on the market. | We advocated for PIA to be consulted when NAPSA aims to create sub-schemes. That is now in Bill No. 68 of 2026. We recommend that the same be incorporated in this Bill.Amend subclause (1) to:The Minister may, on the recommendation of the Local Authorities Superannuation Fund and in consultation with the Pensions and Insurance Authority, by statutory instrument, establish sub schemes and provide for the rules of the sub-schemes. | |
| (3) The funds of a sub-scheme shall be managed separately from the funds from the funds of the Superannuation Scheme and Occupational Superannuation Scheme. | If the sub-scheme is only a component within a scheme, how practical is it to manage the funds separately? | Amend if appropriate. | |
| 66. Appeals(3) A person who is aggrieved with the decision of the Minister under subsection (2), may appeal to the High Court. | There must be a limitation period for appeals to the High Court. | Amend subclause (3) to include a limitation period. We recommend 90 days. | |
| 67. Immunity from execution of judgment against assets… but the Local Authorities Superannuation Fund may pay an amount that may, by judgment or court order, be awarded against the Local Authorities Superannuation Fund to the person entitled to the amount. | There is no discretion on whether to pay a judgment debt. The immunity from execution does not make a party immune also from the debt. It only affects how that judgment can be enforced. | Replace LASF may pay an amount to LASF shall pay an amount… | |
| FIRST SCHEDULE: Part I: Administration of the Public Service Pensions Fund | |||
| 3. Tenure and vacancy of office of member of Board(3) The office of a member of the Board becomes vacant if that member—…(g) ceases to be an employee of the ministry, institution or organization that nominated the member. | Clause 5(1) of the Principal Act does not use the description “employee” for the nomination of a Board member by the relevant institution. It uses the term “representative”. | Amend paragraph (h) to:(g) ceases to be a representative of the ministry, institution or organization that nominated the member. | |
| SECOND SCHEDULE: Savings and Transitional Provisions | |||
| 2. Member of former BoardA person who, immediately before the commencement of this Act, held office as a member of the former Board shall continue to hold office until the expiry of the term of office, or removal by the Minister, after which the Minister shall appoint members of the Board in accordance with this Act | Clarify whether Board members of the former Board are eligible for appointment under the new Act, or will be subject to the two-term limit under paragraph 2(1) of Part I of the First Schedule. | ||
| 8. Transfer of assets and liabilities(2) Subject to subparagraph (1), every deed, bond and agreement, other than an agreement for personnel service… | The correct term is “personal service”, not “personnel service”. | ||