This means that those that are lawful and currently registered as Trusts will cease being lawful and have to stop functioning in accordance with the law as they try to register. This disrupts the smooth operation of NGOs. With regards to ZESN in particular, this Bill is actually an obstacle to full political participation of the electorate in that activities that benefit the electorate would have to be stopped whilst the organisation is seeking registration and in the meantime Zimbabwe is geared for elections early next year in March. It is not even clear how long the registration process takes. It might take years since all currently functioning NGOs and new ones will all be competing for registration. ZESN has been in the process of registration under the PVO Act for the past two years and up to now; it has not yet been finalized. Moreover if the idea is to register NGOs, then why de-registration in the process. PROPOSAL 1: SELF REGULATION Whilst it would be understandable that NGOs are regulated in such a way as to avoid questionable NGOs that may deceive the general populace, we would however prefer the system of self-regulation for example the Law Society of Zimbabwe. However this could be combined with a code of ethics. PROPOSAL 2 It is our strong view that organisations operating currently as nongovernmental organisations effectively as Trusts (both under Deeds Registries Act and with the High Court) be automatically deemed registered under the new PVO Act. PROPOSAL 3 NGOs not currently registered under PVO Act should be allowed at least one year transitional grace period, as they await registration. This will ensure that NGOs fully acquaint themselves with the new system and comply fully with the requirements. 4.3 FOREIGN FUNDING SECTION 17 reads: 8

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