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In terms section 1 of the Broad Based Black Economic Empowerment Act (53 of 2003), fronting is any activity which undermines the Act. In effect this means trying to appear compliant with the Act when, in fact, you are not. This particularly means a company that supplies a list of shareholders, directors or other beneficiaries so as to appear to be in compliance when in fact they are not. Thus lower paid workers (such as gardeners or drivers) can be presented as directors without their knowledge or agreement.