of the black population. The shift to broad-based BEE has led to an increase in the number of BEE deals involving large black-owned consortia, which some commentators have suggested may have increased the scope of beneficiaries under those deals. However, with little detailed public information available about the composition of the relevant consortia, this claim has been difficult to verify. On other, non-ownership metrics, there has been positive transformation since 1994, but critics argue that the pace of change has been inadequate. The Institute of Race Relations found that the number of black South Africans employed as managers had increased by 176.3% between 2001 and 2017 (compared to 32.1% population growth in that group over the same period). Yet in 2021, the Commission for Employment Equity found that white people remained dramatically over-represented in the top levels of the private sector: they filled 67.8% of top management positions, 58% of senior management positions, and 43.2% of all professionally qualified positions. As of the second quarter of 2021, the unemployment rate for white South Africans, at 8.6%, remained significantly lower than that for blacks (38.2%), coloureds (28.5%), and Indians and Asians (19.5%). Corruption BEE fronting The government defines "BEE fronting" as occurring whenever entities deliberately misrepresent facts about their BEE compliance. However, the phrase is most commonly used in reference to so-called "window-dressing," a form of tokenism whereby entities improve their BEE status by appointing black directors, managers, employees, or suppliers, who are, in practice, discouraged or inhibited from substantially participating in or benefitting from the enterprise. Several large companies have been investigated for BEE fronting, including Netcare and MTN. The BBBEE Commission has increasingly raised concern about the extent of the practice. In 2021, Commissioner Zodwa Ntuli said that fronting was so widespread that improved measured performance against BEE objectives might not correlate with actual improvement in the economic situation of black people. She also called for a more stringent government response to those found guilty of fronting, which is punishable by fines, blacklisting, and up to ten years' imprisonment. Political corruption A notable criticism of BBBEE is that the policy has been co-opted by members of South Africa's political elite, mostly within the governing ANC, for the purpose of self-enrichment. From an early stage of BEE, analysts, extrapolating from the concept of a "patriotic black bourgeoisie," noted the likely contribution of BEE to the growth of a black capitalist