MISA-Zimbabwe’s submissions on the above-mentioned Bill are as follows:

1. Section 27 as read with section 3(d) restrict investments in Zimbabwe’s
telecommunications sector to Zimbabwean citizens who are ordinarily resident
in Zimbabwe.
1.1. Section 3(d) of the Bill limits investment in the Zimbabwean telecommunications
sector to Zimbabwean citizens. Section 27(1) expands on this by stating that
licences can only be granted to body corporates controlled by Zimbabwean citizens
who are ordinarily resident in Zimbabwe. It is acknowledged that foreign entities
can own telecommunications services in Zimbabwe with the written consent of the
Minister of ICT and Cyber Security.

1.2. This is an unnecessary restriction on ownership of telecommunications service
providers. More so when one considers the fact that globalisation, and
technological developments have given rise to multi-national telecommunications
service providers. The requirement that Zimbabwean citizens have a controlling
stake in all telecommunications ventures operating in Zimbabwe is a revival of the
recently scraped indigenous laws.

1.3. Section 29(3) states that radio stations can only employ Zimbabwean citizens. This
is an unjustified restriction on radio stations. Such a restriction might make sense
for state owned radio stations but not for privately owned radio stations.

1.4. Recommendations: Ownership of telecommunications services should be
widened to include foreign nationals with the requisite experience and expertise in
telecommunications, broadcasting and media.

1.5. The same goes for radio station employees. Private radio stations should have the
discretion on who to employ.

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