IN THE EDUCATION LABOUR RELATIONS COUNCIL
In the INQUIRY BY ARBITRATOR between

DEPARTMENT OF EDUCTION – FREE STATE PROVINCE “the Employer”

AND

TL KHANYAPE “the Employee”

SECTION 188A INQUIRY BY ARBITRATOR RULING

CASE NUMBER: ELRC1111 – 24/25FS
DATE AWARD SUBMITTED: 15 August 2025
NAME OF COMMISSIONER: Coen Havenga

Details of hearing and representation

1. This process was set down in terms of section 188A of the Labour Relations Act 66 of 1995 as amended (hereafter “the LRA”), and ELRC Collective Agreement 3 of 2018. The matter was heard on several days and the last day of the inquiry took place on 14 July 2025 at the offices of the Employer in Bloemfontein. The parties requested opportunity to submit written closing arguments which were duly received and form part of the record.
2. The Employer is the Free State Department of Education, represented by Ms Cweba, L. The accused Employee is Mr Khanyape, TL (“Khanyape”), represented by Mr Serape, D, and official of SADTU.
3. Mr Mogayane, H, acted as interpreter, and the intermediary was Ms Twala, ME.

Issue to be decided

4. I am required to determine whether Khanyape is guilty of the charges levelled against him. Should I find him guilty of the charges, then I need to determine the appropriate sanction, as well as make a determination in terms of section 120(1)(c) of the Children’s Act 38 of 2005 whether Khanyape is unsuitable to work with children.

Background and charges

5. Khanyape, an educator employed at Grassland Secondary School (“the School”), is charged with two allegations of misconduct.
6. Charge 1 – charged with misconduct in terms of section 17(1)(c) of the Employment of Educators Act 76 of 1998. It is alleged that between August 2024 and October 2024 he had a sexual relationship with a grade 12 learner (hereinafter referred to as “Complainant no.1”) of Grassland Secondary School where he was employed as educator.
7. Charge 2 – charged with misconduct in terms of section 18(1)(q) of the Employment of Educators Act 76 of 1998. It is alleged that during August 2024 while on duty, he conducted himself in an improper, disgraceful, and unacceptable manner by proposing love to a grade 12 learner (“Complainant no.1”).

Plea

8. Khanyape pleaded not guilty to charge 1 and 2 and denied all the allegations against him. He did not have a sexual relationship with Complainant no. 1, and he did not propose love to her.
9. He disputed the admissibility of the Whatsapp messages contained in the Employer’s Bundle A.

Summary of evidence

10. The Employer submitted the documents contained in Bundle A, whilst the Employee submitted a letter from Ms Seselinyane, LD, a counselling psychologist, stating that he had been diagnosed with major depressive disorder and anxiety by a Dr Setlaba, NC, as well as a letter from the patient liaison officer Woodlands Clinic, confirming his admittance for treatment from 12 January 2025 to 24 January 2025.
11. The proceedings have been recorded digitally, and a summary of the Employer’s and Employee’s witnesses’ evidence follows below. What follows is only a summary of the evidence deduced at the arbitration hearing and does not purport to be a verbatim transcription of all the testimony given. The digital record of the proceedings will reflect the complete testimony of the witnesses. The fact that I have not captured all of it herein should not be misconstrued that I have not taken all the evidence presented into account. My findings are, accordingly, within the context of all the evidence provided by the parties during the arbitration hearing.
12. The matter relates to, inter alia, allegations of sexual misconduct towards a learner who was a minor at the time of the alleged incidents. In accordance with the protection of the rights of minors afforded them in the Constitution of the Republic of South Africa, the identity of that learner and other minor witnesses will not be disclosed. I will refer to the minor witnesses for the Employer as Complainant no.1 and Learner X in this award. The witnesses testified from a room with a one-way glass, which was separate from where the Employee was seated, with the assistance of an interpreter and an intermediary.

Employer’s case

13. Complainant no.1, currently an 18-year-old female learner who was in grade 12 in the School in 2024, testified under oath with the assistance of an intermediary that during July or August 2024, Khanyape sent her a friend request on Facebook social platform (hereinafter referred to as “FB”). She accepted his request, and he asked her for her telephone number, which she gave to him. He then started to communicate with her on Whatsapp social media platform (hereinafter referred to as “WA”). Khanyape proposed love to her via WA, and she agreed to his proposal.
14. Khanyape then kept on calling her to his office at the School. She went to his office where they always kissed each other. One time he pulled up her dress, lifted her onto the table and pulled down her stockings. He pulled down his trousers and entered between her legs and they had sex. After they finished, he wiped her with a tissue, and she also wiped herself. They got dressed and sat together for a while. She then went back to her class. After that incident he kept on calling and texting her.
15. When the principal became aware of the relationship the principal told the Complainant no. 1’s parents. Khanyape then told her to deny everything. After he was suspended, he told her classmate to tell Complainant no.1 that he denied everything when the officials of the Department spoke to him, and that she must also deny everything. Khanyape spoke to her on her classmate’s phone. He told her that if she did not deny everything, he was going to lose his job. Complainant no. 1 just kept quiet during that conversation. Thereafter they did not talk again.
16. Before, when they were still talking on WA, he always told her to delete the WA conversations they had. She however took screenshots first before she deleted it on her phone. Bundle A reflects the screenshots of her phone of the WA conversations she had with Khanyape. They mainly communicated on WA, but A11 reflects the initial FB communication where he requested her number. His name is Luther Khanyape. “Leave your tens tlao text” meant she had to leave he number there, and he would text her through WA. She did leave her number for him.
17. A2 reflects her messages against the green background, and his messages in white background. She wrote to him that she was tired from all the moaning and screaming, referring to the sex they had, and he said he was sure people were starting to see something. She replied she did not think they heard them, and he said, “you were too loud”. She responded by telling him that he was on fire, using emojis. He said, “lol le next time”. She said the next time she was not going to sleep, because she slept in the class the previous time after she came back from his office. He said, “Tlabe ko drugile ka” with the cucumber emoji, meaning he will be drugging her with it. The cucumber emoji simbolised the penis of a man.
18. A4 reflects the conversation they had about preventing pregnancy before they had sex for the first time. They called each other “baby” and “hun”. He said that he would pull out and she told him that he must use a condom as she was not using contraceptives. However, when they had intercourse, he did not use a condom. She was then afraid that she would fall pregnant. She saw semen on the toilet paper tissue he used to wipe them with after they had sex. He had a roll of toilet paper in his office.
19. Khanyape initiated the kissing in his office. The WA messages do not show the names or number because it is screenshots which she took before she deleted the messages from her phone. A10 reflects messages where he said, “thanks for today”, and she responded with a love sticker. He sent a heart emoji back. She said, “Oh thank you, I also enjoyed you”. She then sent another love sticker to him.
20. Khanyape did propose love to her, and he did have a sexual relationship with her.
21. During cross-examination Complainant no.1 testified that Khanyape is lying if he says he never had a sexual relationship with her. It is not true that they only had professional interaction between teacher and learner. He was not even teaching her any subjects in grade 12.
22. She denied that she fabricated everything because he did not give her the assistance with mathematics which she requested from him. She did not ask for his assistance. He did propose love to her, and he did have sex with her. He penetrated her. It was put to her by Khanyape’s representative that she had to bring physical proof like semen.
23. Khanyape called her to his office when there were no learners in the class, or during breaks. She did not remember the specific date and time of each encounter, but it happened between August 2024 and September 2024.
24. She and Khanyape were the original authors of the messages depicted in Bundle A. She denied that she created all the messages to frame him because she was angry that he did not assist her with mathematics.
25. Learner X, 18 years old, testified under oath that she heard about the allegations of a relationship between Complainant no. 1 and Khanyape from another learner. At a time, Complainant no. 1 gave her phone to Leaner X to take photos of a show, and when she scrolled the gallery, she found the screen shots of the conversations between Complainant no. 1 and Khanyape. She sent the screenshot pictures to her own phone. She and the other learner reported it to Ms Mojaje, and she also sent the screenshots to Ms Mojaje.
26. During cross-examination Learner X testified that Complainant no. 1 did not perform well in mathematics. She was not aware that she sought any assistance from Khanyape with her mathematics.
27. Lebogang Mojaje (“Mojaje”) testified under oath that the allegations of a relationship between Khanyape and Complainant no. 1 was brought to her attention by Learner X, and another learner told her about it. They sent her the screenshots. The matter was handed over to the authorities.
28. During cross-examination Mojaje testified that she had a good relationship with Khanyape.
29. Teboho Machakela (“Machakela”) testified under oath that he is the father of Complainant no. 1. He became aware of the allegations of a relationship between Khanyape and Complainant no. 1 when the principal called him. The principal came to his house and told him that his daughter was having an affair with a teacher. Him and his wife confronted Complainant no. 1, and she said it was true. She told them that Khanyape had intercourse with her and told her that he loved her.
30. They took Complainant no. 1 to the clinic for a checkup because he regarded it as rape. She was found to be pregnant. The family would not have been able to accept such a child, and it was decided to do an abortion. He did report the matter to SAPS. He received a case number.
31. During cross-examination Machakela testified that he did not bring the medical report with. She was pregnant. He saw it as rape when his child told him that she had intercourse with an adult at school. She did not testify about it because perhaps she was not asked about it. He believed his daughter when she told them that Khanyape had sex with her. He found it surprising that she would have asked for assistance with mathematics from a teacher who did not even teach her.
32. Khanyape was the father of the unborn child because he was the one who had sex with her. He impregnated her.
33. Stephan Mphanga (“Mphanga”) testified under oath that he is the principal of the School. Mojaje reported the matter to him. She provided him with the screenshots. He compiled a report and sent it the circuit manager and Labour.
34. He met the parents of Complainant no. 1 at their house.
35. During cross-examination Mphanga testified that Bundle A reflects the screenshots he received from Mojaje. He sent it to the circuit manager.

Employee’s case

36. Tseko Luther Khanyape, the Employee, testified under oath that the child came to him to ask for his assistance with mathematics. They met at the vendors at the School. She heard that he was good with mathematics. He agreed to help her when he got a chance, but it did not happen. He met her again on a lunch break and she asked for his assistance again. He told her that he could not help her because he was too busy at the School. That was the last time that he met her. He met her three times in total.
37. It is a lie that he sent her a FB friend request. He did not request her number. He did not get her number, and he did not give her his number. He thought she got his number off one of the School WA groups. He never called her into his office or classroom. She had no witnesses that saw her with him. They had no conversations on WA. He only met her outside during break times. There were always other learners around. She is lying about how he had sex with her. He did not have sex with her. She did not call a witness to confirm they had sex. There is no proof that he entered between her legs. He did not wipe them off with a tissue. It is all lies, because she did not bring any witness to confirm that they had sex.
38. She accused him because she was angry that he did not assist her with mathematics. He did not tell her to deny everything. Khanyape thought she might have used Artificial Intelligence (“AI”) to make it look as if he was texting her.
39. He had a bad relationship with Mojaje. Machakela lied, there is no proof. He was not a witness to the alleged sexual relationship. Machakela is the pastor of a big church. There is no evidence of the termination of the pregnancy. There is no evidence that she was pregnant. Even if she was pregnant, he was not responsible for it.
40. It is all just lies. K1 and K2 reflect the medical problems he picked up.
41. During cross-examination Khanyape testified that he did not remember the dates he met Complainant no.1. It was in the 3rd term. He was unable to help her with mathematics. She did accept his explanation that he was too busy.
42. When one asks someone several times, one might get angry that is why he thought she became angry when he did not assist her. It is just a thought.
43. He thought she could have gotten his number off a WA group. He had no conversation with her. He had no interaction with her apart from the three times that she asked for his assistance with mathematics.
44. He thought she fabricated her version because she was angry that he did not assist her with mathematics. Even though she described their interaction vividly with details, it was all lies. It was stupid not to bring one witness who saw them together.
45. Khanyape could not explain how Complainant no. 1 would have used AI to create the WA conversations. He just heard about AI. He thought she might have been able.
46. Lebogang Mathora (“Mathora”) testified under oath that he is the HOD for mathematics at the School. He was Khanyape’s supervisor. He is qualified to teach mathematics and could have assisted any learner. He was a disciplined educator.
47. During cross-examination Mathora testified that he was not aware of the charges against Khanyape. He was not aware of the allegations of a sexual relationship with a learner.

Summary of arguments

48. Both parties submitted extensive written closing arguments which form part of the record and will not be repeated here. The parties were directed to address the issues of guilt, appropriate sanction, should the Employee be found guilty, and his fitness to work with children, should he be found guilty. I have considered the arguments, together with the other evidence, oral and documentary, presented by the parties during the inquiry, as reflected in the record of the hearing.

Analysis of evidence and argument

49. This inquiry was conducted in terms of the principles contained in section 188A, as well as Schedule 8 of the LRA, and ELRC Collective Agreement 3 of 2018, in respect of the fairness of disciplinary action against educators charged with sexual misconduct in respect of learners. In applying those principles, the following factors were considered:
    a) Whether or not the accused employee contravened a rule or standard regulating conduct in, or of relevance to, the workplace; and
    b) If the rule or standard was contravened, whether or not –
    i. The rule was a valid or reasonable rule or standard;
    ii. The accused employee was aware, or could reasonably be expected to have been aware, of the rule or standard;
    iii. The employer has consistently applied the rule or standard.
    iv. Dismissal would be an appropriate sanction for the contravention of the rule or standard.
50. The LRA does not prescribe the standard of proof to be used in labour matters. It is however universally accepted that the standard of proof that is applicable in disciplinary hearings, and therefore inquiries by arbitrators of this nature is identical to the civil standard – “the employer must prove the case against the employee on the balance of probabilities and not beyond reasonable doubt” – Meadow Feeds (Pietermaritzburg) vs. Sweet Food and Allied Workers Union (1998) Arb1.2.1.
51. All the allegations in the charges against the Employee, as well as the evidence, documentary and otherwise, deduced in support thereof by the Employer, and the evidence deduced by the Employee in defence, were considered and weighed against the abovementioned standard of proof.
52. It is not disputed by the Employee that the actions he had been charged with constitute misconduct. He merely denied committing the alleged misconduct as set out in the two charges below.
53. Charge 1 – charged with misconduct in terms of section 17(1)(c) of the Employment of Educators Act 76 of 1998. It is alleged that between August 2024 and October 2024 he had a sexual relationship with a grade 12 learner (hereinafter referred to as “Complainant no. 1”) of Grassland Secondary School where he was employed as educator.
54. Charge 2 – charged with misconduct in terms of section 18(1)(q) of the Employment of Educators Act 76 of 1998. It is alleged that during August 2024 while on duty, he conducted himself in an improper, disgraceful, and unacceptable manner by proposing love to a grade 12 learner (“Complainant no. 1”).
55. I am mindful of the fact that the Employee is charged with, inter alia, sexual misconduct. It is a natural response in matters relating to the sexual assault or sexual harassment that the reasonable person might view such conduct with disgust and revulsion. This is even more applicable where a trust relationship is abused. As arbitrator one should however be conscious of the need to not to prejudge but to objectively consider the facts of the matter on a balance of probabilities and credibility of the evidence adduced.
56. In respect of the all the allegations the Employee disputes the version of the Employer’s witnesses, and denies any wrongdoing, and I must decide on a balance of probabilities which version to accept.
57. The Employee’s defence in respect of the alleged sexual relationship and improper, disgraceful, and unacceptable conduct is a blanket denial of any wrongdoing. He submits that it is all a fabrication of lies, instigated by the Complainant no. 1 because he did not assist her with mathematics when she requested his assistance.
58. I take cognisance of the fact that Complainant no. 1 is a single witness in respect of what allegedly transpired in the presences of the Employee. It also important to remember that this is an arbitration hearing, and the matter needs to be dealt with the minimum of legal formalities, as it is not a criminal trial. Even if the rule is not applicable in civil proceedings or arbitration proceedings, I must nevertheless be satisfied that the evidence of a single witness is reliable and trustworthy before relying on it.
59. It must be remembered that the Complainant no. 1 was only seventeen years old at the time of the incidents, and that the incidents took place during the 3rd term in 2024, while the arbitration hearing only commenced in June 2025. Naturally, the lapse of time would affect the memories of witnesses, and I assessed the evidence against this backdrop.
60. It has been shown that children who are sexually abused, concentrate on the core details of the incident and not so much on peripheral details. The omission of peripheral details like dates, or contradiction relating thereto, is not usually a basis for rejecting the testimony of a child witness. What is most important is consistency regarding the core details of the experience. Refer to the ELRC Guidelines: Inquiries by ELRC arbitrators in terms of section 188A of the LRA relating to misconduct of a sexual nature in respect of learners.
61. The Constitutional Court has held that that the sexual assault of children has the inherent effect of rendering child victims unable to report the incident, sometimes for several decades, and that they should not be penalised for the consequences of their abuse by blaming them for the delay. The Courts have accepted that feelings of fear and shame often prevent children from reporting such incidents immediately and that the victims often distance themselves from reality and transfer responsibility onto themselves. In 2007 the law was amended to provide that no inference may be drawn from the length of any delay between the alleged commission of such offence and the reporting thereof. The fact that a child does not tell another teacher at school about an incident that occurred at school but only tells a parent or grandparent later at home, or visa versa, is therefore no indication that the child has fabricated the evidence. Sometimes children would due to feelings of shame not tell a parent or teacher but rather tell a close friend.
62. The above is aptly relevant in this case where the Complainant no. 1 did not testify to the fact that she fell pregnant and that the pregnancy was terminated. I reject the arguments of the Employee that the fact that she did not mention the pregnancy and abortion in her evidence, tarnish the credibility of her evidence in any material way. Her father, Machakela is a pastor, and testified that she was pregnant and that the family decided to terminate the pregnancy because he regarded it as rape. His evidence was not refuted by the Employee. I find it highly improbable that Machakela would come and render such apparent humiliating evidence for the Complainant no.1 and her family merely to support her in falsely fabricated allegations against an educator.
63. I also reject the arguments of the Employee that evidence of the Complainant no. 1 should be discredited because she did not call a witness that saw them together. The very nature of the alleged sexual intercourse is such that she would not have had any bystanders that could testify about the sexual intercourse. I will consider her viva voce evidence in respect of the merits and credibility of her version of the events.
64. I find no material discrepancies or inconsistencies in the evidence of the Complainant no. 1 that would negatively affect her credibility. The Employee objected to the WA screenshots being admitted as evidence. However, the Complainant no.1 was one of the authors of those texts and testified to the authenticity and veracity thereof. I find the Employee’s allegation that it she could have created it by using AI, improbable. He could not substantiate his suspicion and could not explain how she would have done it with AI. The Employee never put this version that she used Ai to the Complainant no. 1 in cross-examination. This is a material aspect of this case in relation to the authenticity of the WA messages. In NUM and another v CCMA and others [2018] 3 BLLR 267 (LAC) the Court found that since keys aspects of the employee’s case were not put to the employer’s witnesses in cross-examination and had not been canvassed in the evidence of those witnesses in chief, their version on such aspects was not placed before the commissioner. The same principle will therefore apply in this matter.
65. I find the WA messages to be credible, and it is admitted as evidence. The content of those messages corroborates the version of the Complainant no. 1 in all material aspects. Despite her young age, the Complainant no. 1 stood steadfast by her version. She described the sexual intercourse in graphic detail, as well as the cleaning up done by the Employee afterwards.
66. The Employee version is that Complainant no. 1 was fabricating evidence against the Employee because he did not assist her with mathematics. I find it highly improbable that the Complainant no.1 fabricated such a version and that her father agreed to be used as pawns to accuse the Employee of sexual misconduct. It would have been an elaborate fabrication involving educators, young learners, and parents with the intent to get punish the Employee, which I find highly improbable.
67. I find it improbable that the Complainant no.1’s father would risk his credibility as a pastor of a big church with supporting a false version to satisfy his daughter, to the extent of fabricating a humiliating pregnancy and abortion. It is improbable that parents would allow their young child to go through the trauma merely to satisfy her whims.
68. I find the Employee’s version that the Complainant no.1 decided to falsely accuse him because he did not assist her with mathematics highly improbable. It is common knowledge that learners develop infatuations with educators, but it is the duty and responsibility of such educators to not take advantage of such vulnerable learners. The Employee failed to present any substantial evidence that would prove a fabrication. He merely made unsupported allegations in that respect. The Employee could not provide any substantial evidence that the alleged conspirators had anything to gain by falsely implicating him. The sexual relationship only became known after another learner found the screenshots in her phone gallery. If it were all an elaborate scheme by the Complainant no.1, one would have expected that she herself would have made the conduct of Khanyape known, in order to effect her revenge on him.
69. The risk of false incrimination in sexual cases is addressed in Hoffman and Zeffert, The South African Law of Evidence, 4th Edition, Butterworths, 1992, as follows: “Corroboration is the most satisfactory indication that the Complainant is truthful, but false evidence by the accused or his failure to testify may also be taken into account, as may any other feature of the case which shows that the Complainant’s evidence is reliable and that of the accused false.”. The Complainant’s version has been materially the same throughout the inquiry. I find it improbable that she would make up such a detailed version of events without any reason. The Employee’s version that it is a fabrication is not plausible.
70. Complainant no.1 testified to the sexual intercourse and penetration that took place between her and the Employee, an educator in the School where she was a learner. The graphic content of the WA messages confirmed the existence of a sexual relationship on a balance of probabilities. She also testified that the Employee proposed love to her, as corroborated by the WA messages.
71. Therefore, with consideration of all the relevant cautionary rules I find that the Employer provided evidence that proves on a balance of probabilities that the employee committed the misconduct as contained in charges 1 and 2. There is therefore evidence before me that proves that the Employee contravened a rule or standard regulating conduct in, or of relevance to, the workplace.

Finding

72. The accused employee, Mr Khanyape, TL, is found guilty of the following misconduct:
73. Charge 1 – contravening the provisions of section 17(1)(c) of the Employment of Educators Act 76 of 1998, in that between August 2024 and October 2024 he had a sexual relationship with a grade 12 learner of Grassland Secondary School where he was employed as an educator.
74. Charge 2 – contravening the provisions of section 18(1)(q) of the Employment of Educators Act 76 of 1998, in that he during August 2024 while on duty, conducted himself in an improper, disgraceful, and unacceptable manner by proposing love to a grade 12 learner.

Sanction

75. In considering an appropriate sanction, I am required to exercise my discretion reasonably, honestly and with due regard to the general principles of fairness.
76. Khanyape’s conduct is in direct contravention of the values and obligations prescribed by The Code of Professional Ethics of Educators. He failed to act in a proper and becoming way so that his behaviour does not bring the teaching profession into disrepute. The Code places emphasis on educators refraining from any form of sexual relationship with learners at a school and not abusing the position he holds for personal gain. Section 28(2) of the Constitution of the Republic of South Africa 108 of 1996 provides that a child’s best interests are of paramount importance in every matter concerning the child. This is a factor that I keep in mind as surely it was not in the best interest of the Complainant no.1 being a minor female learner to be lured into a sexual relationship by an educator.
77. Section 17(1) of the EEA states that dismissal is the mandatory sanction for the misconduct of having a sexual relationship with a learner, which I keep in mind considering the nature of Khanyape’s misconduct.
78. Having considered all the facts before me, including but not limited to, the gravity of the offences, the position of trust the Employee was employed in, and the years of service of the Employee, I find that the sanction of summary dismissal is fair and appropriate in the circumstances.
    Sanction
79. In terms of section 188A(9) of the LRA I direct that the employee, Mr Khanyape, TL, be dismissed summarily.

Finding in respect of section 120 of the Children’s Act 38 of 2005

80. Section 120(1)(c) of the Children’s Act 38 of 2005 (“the Act”) provides that a finding that a person is unsuitable to work with children may be made by “any forum established or recognized by law in any disciplinary proceedings concerning the conduct of that person relating to a child”. Section 120(2) of the Act provides that a finding that a person is unsuitable to work with children may be made by such a forum on its own volition or on application by an organ of state or any other person having sufficient interest in the protection of children. The arbitrator may also make the finding on his/her own accord.
81. The parties were given the opportunity to submit arguments in this respect. I have considered both parties’ submissions. In view of my finding of the serious nature of the Employee, Mr Khanyape’s conduct and the priority to protect the rights of children, I find that he is unsuitable to work with children. The fact that there are no previous incidents on record, does not necessarily mean that his conduct will not be repeated. In tribunals of this nature, consideration of the best interests of children, is paramount. My finding is aimed at the protection of children and in particular in this case, vulnerable young girls.
82. Mr Khanyape, TL, is found unsuitable to work with children in terms of section 120(4) of the Children’s Act 38 of 2005. The General Secretary of the ELRC must, in terms of section 122(1) of the Act, notify the Director General: Department of Social Development in writing of the findings of this forum made in terms of section 120(4) of the Children’s Act 38 of 2005, that Mr Khanyape, TL, is unsuitable to work with children, for the Director General to enter his name as contemplated in section 120 in part B of the register.

COEN HAVENGA
Senior ELRC Arbitrator
15 August 2025