Now that 30 July has been announced as the election date, it’s important for the electorate to get a broader overview of the electoral system. This BSR makes a contribution to this process through a discussion of key aspects of the electoral process.
Our system of elections is harmonised, which means presidential, parliamentary and local authority elections are all held at the same time. This was not always the case. Prior to the 2008 elections and after the 1990 elections, the presidential election was held separately. The presidential term was 6 years while parliament had a 5-year term.
In this series of BSRs which begins today, we will attempt to look at critical aspects of the electoral system, explaining the process and highlighting areas of concern that need to be carefully watched. We will also highlight opportunities that can be exploited to promote a free, fair and credible election which is critical to the question of legitimacy which is so critical to this election.
A complex system
Our electoral system is incredibly complex, partly because of the numerous piecemeal amendments to the Electoral Law which have made it look like a patched-up pair of old trousers. It has multiple patches which give it a hideous look. The task of explaining the electoral system would be a complete nightmare were it not for the excellent service provided by Veritas, an organisation which painstakingly ensures that the Electoral Law is updated as and when amendments are made to it.
Every effort has been made to ensure the accuracy of information in this BSR and although I have relied on others’ output, the responsibility for everything contained herein is entirely on my shoulders. Should there be any points that require rectification, please do highlight them and we will do the corrections to ensure that it is accurate and useful to the electorate.
It is common knowledge that the body responsible for running elections in Zimbabwe is the Zimbabwe Electoral Commission (ZEC). It has the constitutional mandate to manage or organise all elections, which function it must exercise independently. In a democracy, an election is a process that gives procedural legitimacy to the government. Procedural legitimacy requires elections to be conducted fairly and voters must able to make their choices freely. The electoral authority is the fulcrum of this process. It has the duty to ensure that the election is free, fair and credible. As the referee, ZEC must not only be fair, non-partisan and impartial. It must be seen to be fair, non-partisan and impartial.
ZEC took over from a predecessor whose reputation was heavily compromised. The Electoral Supervisory Commission (ERC) was widely regarded as politically-compromised. ZEC did not cover itself in glory when in 2008 it pronounced an egregiously violent and widely-discredited election as having been free and fair. It has been a long road to recovery since then. An Afrobarometer survey in early 2017 showed that ZEC was one of the least trusted public institutions, with just a 50% approval rate. The 2013 elections did not help its reputation, particularly after it failed to ensure electronic copies of the voters' roll were availed to contestants. The 2018 election is, therefore, a key test for ZEC. It has a new head, Judge Priscilla Chigumba after Justice Rita Makarau resigned abruptly last December which raised unasnwered questions as to whether she had been pushed or jumped voluntarily.
One of the areas of concern is the professional staff who make up its secretariat. There is concern among opposition parties and civil society that with at least 15% ex-security services personnel among its professional staff, the electoral body has an unhealthy military dosage. It is regrettable also that the country is going into this election without a substantive Chief Elections Officer – the executive head of the organisation. The current head, Utoile Silaigwana was appointed as the acting Chief Elections Officer in March this year. ZEC has the power to appoint the Chief Elections Officer and there is no good reason why it did not appoint a substantive executive head before a crucial election.
ZEC is entitled to recruit civil servants and staff of local authorities and parastatals to assist with electoral functions during elections. ZEC has the power to select, screen and train all persons who are seconded by these bodies and they will be under its direction and control for the duration of the election. These are the people –normally teachers, nurses and other staff – who perform the role of electoral officers. They have an important role in the running of the electoral machine.
There is, however, another important set of civil servants who have a key role in the electoral system. These are senior civil servants who form the National Logistics Committee, one whose function has been discussed in a previous BSR and will be discussed in Part 2 of this BSR Elections Special series.
Closure of the voters’ roll
The voters roll is one of the core instruments in the election process. It determines who is eligible to vote in the elections. ZEC has a mandatory duty to keep and maintain a voters roll for each polling station area in both printed and electronic form. This polling station voters roll is the register that determines who is entitled to vote in that polling station area.
However, the voters' roll was closed on 1 June 2018. The law makes it clear that the voters roll closes 2 days after the proclamation of elections. There will be no more registration of voters for the forthcoming elections and those who did not register will be ineligible to vote.
Nevertheless, this does not mean the voters’ roll can no longer be checked or altered. We have already seen that parties, candidates and any person are allowed to get and inspect copies of the voters roll at any time. If there are any irregularities or discrepancies which are discovered after the closure of the voters roll they must be rectified. There is no point going to an election with a voters roll which is defective. If the closure of the voters roll is deemed to prevent such corrections, it would arguably be unconstitutional and would also taint the legitimacy of the election.
Removal of duplicates
ZEC has the power to remove duplicates to ensure that no person is registered as a voter more than once on the voters roll. More importantly, ZEC can remove these duplicates without giving notice to the affected voters. This provision is based on trust that ZEC would carry out this role honestly and without prejudicing voters. The problem is that trust levels in ZEC are low. The risk that innocent voters might otherwise be removed, even in error, weighs heavily on voters’ minds. It is regrettable that ZEC has this broad power to remove names deemed to be duplicated without informing affected voters.
The hope has to be that since ZEC has this broad power it will use it responsibly and correctly and those innocent voters will not be affected. Otherwise, there is a significant risk that some voters might find discover that they are not on the voters’ roll on polling day on account of this removal process. This has to be watched carefully and the number of voters who are turned away on the grounds that they are not on the voters roll when they registered must be monitored.
Consolidated national voters roll
It is very important for ZEC to prepare, maintain and avail the consolidated national voters roll. In terms of section 20(4) ZEC is also has a mandatory duty to keep at least one copy of a consolidated national voters roll at its head office. It states: “The Commission shall— … (c) keep at least one copy of a consolidated national voters roll at its head office.”
However, section 20(4a) suggests that this duty to keep a consolidated national voters roll is optional. It states, “The Commission may prepare and maintain, in printed or electronic form, a consolidated national voters roll and a consolidated voters roll for any constituency or ward, but such rolls shall not be used for the purposes of polling in any election.” The word may suggest that preparing a consolidated national voters roll is an option.
It is odd that the Electoral Law contains inconsistent provisions on the duty to prepare, keep and maintain a consolidated national voters’ roll. This might seem innocuous but it matters a great deal. Unlike separate polling station-based voters rolls, a consolidated national voters roll provides a facility to see the bigger picture of the electorate. The problem of duplicates is easier and quicker to identify on a consolidated national voters roll than on individual polling station voters rolls.
It is therefore critical that ZEC observes its mandatory duty to keep both polling station voters rolls and a consolidated national voters’ roll. Preparing and maintaining a consolidated national voters’ roll must not be optional as suggested in section 20(4a). Indeed, ZEC must ensure that it provides both polling station voters rolls and the consolidated national voters roll.
Provision of voters’ rolls
ZEC has an obligation to provide a free copy of an electronic voters roll to every nominated candidate within a reasonable time after the nomination. The law makes it clear that the electronic copy must be provided in a form that is searchable and analysable. ZEC can make this tamper-proof and impose conditions to prevent commercial or other unauthorised uses but it must be easy to search and analyse. Secondly, every nominated candidate is entitled to a printed copy of the voters roll upon request and payment of the prescribed fee.
Political parties and accredited election observers are also entitled to receive the voters roll upon request and payment of a prescribed fee.
In addition, any person, even those who are not candidates, is also entitled, within a reasonable time after the election is called, to receive the voters roll upon request and payment of the prescribed fee. This includes the consolidated national voters roll either in printed or in electronic form.
The law states that the prescribed fee for the voters roll should not exceed the reasonable cost of providing the voters roll. This means ZEC cannot impose prohibitive fees which make it impossible for the purchase of voters rolls (we await information on fees for the new voters' rolls).
It is also important to know that according to the law, every voters roll is a public document which is open to inspection by any member of the public without charge during ordinary office hours at the ZEC office or the registration office where it is kept. A person is entitled to make notes while inspecting the roll. This means inspection is not just about checking one’s name on the roll. You can ask for the whole voters’ roll and you don’t have to pay anything to do the inspection as long as you are doing it on the premises and during working hours. ZEC might tell you otherwise but this is the law.
It is important for parties to use this facility to ensure they have copies of voters rolls, particularly the electronic versions which opposition parties were denied in 2013. They must subject these voters rolls to strict scrutiny to ensure that they are credible. ZEC is not going to do an independent audit, so it’s entirely up to political parties and civil society organisations to carry out these audits and highlight any irregularities if any are identified. A voters’ roll will never be perfect but it must at least be substantially accurate in so far as it represents the electorate.
Polling station voting
During this election, voting is based at polling stations. This means a person will only be able to vote at the polling station where they are registered as voters. The only exception is where a person is permitted to vote by post. Postal voting is only allowed in very limited circumstances (to be discussed in Part 2). By now, every person should know the polling station at which they are registered to vote. If you don’t know, you have to check with ZEC.
Location of polling stations
The law requires every polling station to be located at a place that is readily accessible to the public, including persons living with physical disabilities. There are certain places where polling stations cannot be located. These are:
• premises owned or occupied by a political party or candidate;
• a police station, barracks, cantonment area or another place where police officers or members of the Defence Forces are permanently stationed;
• premises licensed under the Liquor Act [Chapter 14:12] – so beerhalls and bottle stores can’t host polling stations;
• at or in any place which, for any reason, may give rise to reasonable apprehension on the part of voters as to the secrecy of their votes or the integrity of the electoral process.
Indeed, it would be wrong for ZEC to locate a polling station anywhere near these listed locations. A polling station outside the fence of a military barracks or police station would be illegal.
Public notice on polling stations
At least 3 weeks before polling day and also on polling day, ZEC is required to publicly inform voters of the location of polling stations and the hours during which the polling stations will be open. This notice must be published in a newspaper circulating in the constituency concerned and in such other manner as ZEC thinks fit. Since the election is on 30 July, the notice must be published on 9th July 2018.
Additional polling stations
Nevertheless, the law now allows ZEC to establish new polling stations to serve the same polling area where the electoral body determines that the number of people exceeds the limit which it thinks can be served by one polling station. In other words, where there are too many people per polling station, ZEC may establish new polling stations. ZEC has described these as “substations” or “Satellite stations” which are supposed to reduce the burden on the main polling station. This is a sanitised explanation and sounds alright if they follow it through to the letter.
However, the law is more liberal than ZEC is telling the electorate. It actually states that “the Commission may establish two or more independent polling stations to serve the same polling station area”. If ZEC sticks to its word, there might be little trouble. However, since the law allows it to establish independent polling stations, parties must remain vigilant to ensure that ZEC does not actually do this, thereby establishing polling stations far away from the main polling station which would result in challenges in monitoring. This is because the problem of ballot stuffing usually takes at these new and little-known polling stations.
In order to prevent problems, ZEC must stick to its word so that any new polling stations are within the vicinity of the main polling stations. Second, they must be established well in advance and in consultation with all parties. Third, they must be known to every contestant so that there is proper monitoring. Finally and perhaps more importantly, since ZEC will split the voters’ rolls between the multiple polling stations, it’s important that voters are advised in advance so that they don’t attend the wrong polling stations. The provision requiring publication of this information at least 3 weeks before polling day becomes critical.
On polling day, polling stations are opened at 7 am and closed at 7 pm – giving a 12 hour period of voting. Where it is necessary to make modifications, the electoral authority must make it clear but still ensure the 12-hour period is honoured. All voters who will be in the queue at the closing time must be permitted to cast their votes. It is absolutely important for party election agents and observers to exercise vigilance at the closing time of the poll because that is where irregularities and cheating are likely to occur. It will be dark, there will be fatigue after a long day of hard work and lapse of judgment can be easily exploited. Parties must make sure their election agents are well-provided for and well-fed and refreshed at this critical point.
The procedures before, during and after polling are specified by law and designed to ensure transparency. For example, 30 minutes before polling begins, the presiding officer must satisfy himself and all parties concerned that the ballot box to be used at the polling station is empty. Afterwards, the ballot box must be sealed and only opened for counting in accordance with the law.
Furthermore, the presiding officer is required, in the presence of all persons entitled to be within the polling station, to count and record the total number of ballot papers received at the polling station. Election agents must independently take note of this.
Who is entitled to be in the polling station?
Apart from the voters recording their votes, the law allows the following to be in the polling station: electoral officers performing their official duties; the candidates; election agents; police officers on duty; accredited observers. Note that police officers have no direct role in the polling process apart from keeping law and order. They cannot like they used to do before, assist voters. To her credit, the ZEC Chairperson has been clear regarding the role of police officers. This should be respected. Ideally, they should not even be permitted within the polling station and should only be called in when it is necessary in the opinion of the electoral authorities at the polling station.
A party is allowed one election agent in the polling station. A candidate is also allowed one election agent inside. Two more agents are permitted outside, one of whom will be an alternate should he be required to fill in for the candidate’s agent inside.
Elections agents are critical to the election process. They are the guards that help to ensure that there is no cheating. They must be well looked after. They must be well-trained, well-fed and well-provided for. They are the most important people because they are the eyes and ears of the parties. But they are also vulnerable to rent-seeking behaviour of opponents. They can be bought off, especially when they do not have a strong moral and ethical constitution and if they are not well provided for. They are also targets of intimidation, especially in the remote areas and ruling party strongholds. ZANU PF has resources and generally looks after its agents well. The opposition parties have to improve in this regard. Without effective agents, the opponents will have a field day, especially in remote areas.
The law permits certain voters who are either illiterate or physically handicapped and require assistance to be given such help by persons of their choice or by the presiding officer. Where the presiding officer assists a voter, there must be two other electoral officers or employees of ZEC and a police officer on duty. No other person in the polling station is allowed to interfere with this process
Assisted voting is a big red flag in the electoral process as there were allegations of abuse in the 2013 elections, particularly in the rural areas. The law does have some safeguards which can be used to prevent abuse. Candidates and election agents are not permitted to perform this role. Furthermore, a person is only permitted to assist one voter. The law requires a register of assisted voters to be kept. Those who have been assisted and those who have assisted are recorded. This will be helpful when analysing election data in case there is suspicion of abuse. High levels of assisted voters in a country boasting a high literacy rate as Zimbabwe does are bound to raise suspicion.
More importantly, voter education must be used to give people confidence to vote on their own. There are suspicions that some have been forced to feign illiteracy or injury in order to facilitate assistance, which compromises the secrecy of the vote. Voters need confidence that they don’t have to fear and must be free to exercise their right to vote.
Election observers are accredited by a committee of ZEC called the Observers Accreditation Committee (OAC). Applications are made to the Chief Elections Officer who forwards the applications to the OAC for consideration.
The OAC is headed by the Chairperson of ZEC. The Deputy Chairperson of ZEC and 3 other ZEC commissioners complete the ZEC representatives of the OAC. The rest of the members are political appointees. They are a single nominee from the following: the Office of the President and Cabinet; the Minister of Justice; the Minister of Foreign Affairs, the Minister of Home Affairs and the Minister responsible for women’s affairs.
The job of the OAC is to recommend the accreditation of both local and foreign observers who have either applied or been invited to observe elections. The problem with this OAC is the heavy presence of political appointees in the form of Ministerial nominees. Since these Ministers represent the ruling party, it gives an unfair advantage to one party over others as they have a disproportionate influence in choosing election observers. The Minister of Foreign Affairs is also entitled to object to the accreditation of foreign observers in which case the OAC is required to pay due regard to the objection when deciding whether or not to recommend the observer’s accreditation.
Nevertheless, the Mnangagwa administration has undertaken to be open to the observation process and in particular to international observers. This spirit should also extend to local observers.
Observers are critical to the legitimacy of the electoral process. They are the first step in the process of certifying the proper conduct of the election. Their observations inform the response of their governments and organisations as to whether the elections are free, fair and credible.
Their role is to observe the election process in its entirety, particularly the conduct of polling on polling day. They are entitled to enter and remain at polling stations to observe the conduct of polling. They can raise any concerns regarding polling, collating or counting of votes. They are also entitled to be physically present at the counting or collating of votes and the verification of polling-station returns by presiding officers.
At the end of the process, observers provide a comprehensive review of the election. They consider a number of issues including ZEC’s impartiality, respect for political and related rights, political parties’ agents’ freedom to observe all aspects of the election, role of state media and access to use of state resources, the conduct of polling and counting of votes and any other issues that might affect the free and fair conduct of the election. A recent amendment also brought in considerations of gender equality in the elections. Observers must observe and review factors that impact gender equality in the conduct of elections.
The Electoral Act has a specific provision which makes the Zimbabwe Human Rights Commission as an election observer. Section 40K provides that the ZHRC can through any of its commissioners or employees observe any election to ensure respect for the human rights and freedoms under the Constitution. The ZHRC is one of the core institutions designed as a guardian of human rights and freedoms and its role in the elections is critical.
Party-list candidates: Senate, Women’s quota and provincial assembly
Party-list seats are filled by candidates who are elected on the basis of proportional representation in the Senate, the women’s quota in the National Assembly and the provincial assembly. Zimbabwe is divided into 10 electoral provinces. Each province has 6 party-list seats for the Senate; 6 party-list seats for the Women’s quota and 10 party-list seats for the provincial assembly. Nevertheless, in the outgoing tenure, the government failed to implement the devolution provisions and there were no provincial councils. It is unclear whether the provincial councils will be operationalised this year. Failing to do so undermines the constitution.
On Nomination Day, each party is required to submit a list of candidates to fill the party-list seats in the Senate, for the Women’s Quota and for the provincial assembly. In order to promote women’s representation in parliament and advance gender equality, party-lists must be structured in such a way that female and male candidates are listed in a zebra pattern but with the female candidate at the top of the list. This was to give first preference to female candidates and also to prevent a situation where male candidates would dominate the list at the expense of women, as is often the case historically.
The party-list seats are filled in accordance with a formula for proportional representation prescribed in the Eighth Schedule of the Electoral Act. It is calculated on the basis of the total number of valid votes cast for all the constituency candidates in the electoral province concerned except votes cast for candidates who are not political parties or if they are party candidates have not submitted names for the party-list seats. In simple terms, the party that gets the most votes for national assembly candidates in a province will have the largest number of party-list seats in the Senate and Women’s Quota (and if implemented, in the provincial assembly). Senate candidates and Women’s Quota candidates have an incentive to campaign for their National Assembly counterparts because their chances of filling their party-list seats are enhanced if they win more votes collectively.
In order to qualify as a party-list candidate, one must be listed on the voters roll in the constituency and must have accepted a nomination to be on the party-list. A person cannot be on more than one party-list and cannot also be a candidate in another election. For example, if one is contesting for a National Assembly constituency seat, he cannot also be on the Senate party-list. Likewise, a woman who is running for a National Assembly constituency seat cannot also be on the party-list for the Women’s Quota seat.
If a candidate on the party-list dies after nomination but before the election, ZEC will select the next eligible candidate on the party-list and if there is no such eligible candidate, the party concerned will be invited to submit a new candidate.
Nomination of National Assembly candidates
14th June 2018 has been appointed as the nomination day. This is when candidates for elections will submit their nomination papers after which they will formally become candidates in the election. In order to be confirmed as candidates must meet the minimum nomination requirements. For party-list candidates, the relevant party submits a party list on behalf of the candidates. For presidential candidates, National Assembly candidates, and local authority candidates, there are minimum numbers of nominators in the areas they are contesting.
For national assembly candidates, they need at least 5 nominators from their constituency. For the president, they need 10 nominations from each province. These nominators must be listed on the voters’ rolls. The nomination court sits from 10 am to 4 pm on nomination day. However, if at that time a candidate or his chief election agent is present in the court and ready to submit a nomination paper in respect of the candidate, the nomination officer is required to give him an opportunity to do so. In other words, you have to be in the nomination court by 4 pm and if you are inside and ready to submit, you cannot be turned down for lack of time.
Where a nomination officer has identified defects on the nomination form, the candidate or his agent must be given an opportunity to rectify the defects but this must be completed on the same day. There can be no adjournment to another day.
The nomination officer must also examine the papers carefully where the candidate purports to be representing a political party so that he is satisfied that this is true. If the nomination officer is doubtful, he may require the candidate or his chief election agent to produce proof as to such fact.
If the nomination officer rejects the nomination, he must do so publicly in open court. There are a number of reasons why a nomination officer might reject a nomination:
• if he considers that any symbol or abbreviation used by the candidate is indecent or obscene; or is too complex or elaborate to be reproduced on a ballot paper; or closely resembles another candidate’s symbol in the constituency concerned; or closely resembles the recognised symbol or abbreviation of another political party and this would cause confusion.
• if any symbol a prohibited symbol;
• if the nomination officer does not believe the candidate’s claims that he represents a particular party.
• if the nomination paper is not accompanied by two copies of the electoral code of conduct;
• if in his or her opinion the nomination paper is for any other reason not in order;
Finally, the law does not allow rejection on the basis of minor errors such as slight variations between the name on the nomination paper and the voters' roll. Indeed, the law recognises that the papers may be imperfect and the nomination is to be accepted where there is substantial compliance.
Withdrawal of a candidate
If a candidate withdraws before the election and there is only one candidate left, that candidate will be duly declared as the elected. If there are two or more candidates after the withdrawal, the electoral authorities will ensure that the name of the withdrawn candidate is either omitted or deleted from the ballot paper. In any event, the authorities must ensure that voters are informed of the withdrawal.
Death of a candidate
Where a candidate dies after nomination but before polling day, the Chief Elections Officer must declare that all proceedings relating to that election in the constituency are void. There will be a new election process for that constituency but there will be no need for the remaining candidates to submit new nomination papers if they still wish to contest.
Substitution of a candidate
The law allows parties to have substitute candidates if a candidate withdraws or dies within 7 days after nomination day. The party must inform ZEC no later than forty-eight hours after it becomes aware of its candidate’s withdrawal or death.
ZEC has the responsibility for printing ballot papers. It must ensure that the number of ballot papers does not exceed the number of registered voters by more than ten percent. This is in accordance with the international best practice and a point of progress from the situation in the 2013 elections when ZEC printed an extra 2 million ballot papers, which was excessive and raised suspicions. International observers such as the AU raised this issue as an irregularity that needed to be rectified.
ZEC is also required to be transparent on the issue of ballot papers. The law requires ZEC to provide the following information to all political parties and candidates contesting an election and to all observers:
• where and by whom the ballot papers have been or are being printed
• the total number of ballot papers that have been printed
• the number of ballot papers that have been distributed to each polling station
Opposition parties have been demanding an open and transparent procurement process and a role in that process. However, ZEC has rejected the demands, preferring a direct procurement as opposed to an open competitive tender process. This dispute has dented the process and raised suspicions that could have been easily dispelled had ZEC used an open tender just as it did with the Biometric Voter Registration process. ZEC has offered opposition parties to observe the printing process, although specific details regarding modalities are yet to be availed. It is critically important that the ballot paper printing and distribution is carefully monitored.
Counting the votes
The counting of votes is one of the most critical stages of the electoral process. The old cliché that it does not matter who votes, but who counts the votes couldn’t be more appropriate. Votes must be counted after the close of polling and following the opening of the seal on the ballot box. This critical process must be performed openly and transparently in the presence of witnesses. It’s very clear that there should be no undue delay between the closing of ballot boxes and their opening for counting. The law states that it must be done as soon as possible. Those who may be present at the counting are:
• the presiding officer and such polling officers as he may consider necessary
• Election monitors and observers
• the candidates, and every chief election agent and election agent of each candidate and of each political party is present within the polling station or its vicinity at the time of the commencement of the counting
• any roving political party election agent who, at the time of the commencement of the counting, is present within the polling station or in the immediate vicinity of the polling station.
After the counting is done and the results are recorded, the presiding officer must give an opportunity to agents to affix their signatures. The candidate or his agent must be given a copy of the completed polling-station return.
Results outside the polling station
Critically, the law requires the presiding officer to affix a copy of the polling-station return outside the polling station so that it is visible to the public. He is required to ensure that it remains there so that all members of the public who to inspect and record its contents may do so freely. This is a critical stage because it ensures that parties and members of the public have at their disposal a means of collecting data independent of ZEC. Parties can do the parallel process of recording votes and if done on a countrywide basis it can be useful to compare with ZEC’s official statistics. It worked fairly well in March 2008 but it was not so successful in 2013. In these days of smartphones and cameras, the public has an opportunity to participate actively in the election process by keeping a record of results at their polling stations as they are released.
The law provides for a process of transmitting results from the pooling station to the national command centre in Harare. ZEC has the ultimate power to declare the election result. However, it helps that parties can implement mechanisms to monitor results as they are published around the country. With an organised and efficient system, it can be a useful way to monitor the electoral process. This requires resources and this is where others, including Zimbabweans in the Diaspora, can chip in. They might not be allowed to vote in their foreign locations in this election, but they can still play a critical role of availing resources to support the monitoring of this election – from resourcing election agents and ensuring data is captured at source.
The next BSR this weekend will be a continuation of this analysis of our electoral system. There is a lot more that remains to be done so if your questions have not been answered, look out for the next BSR.