Open Questions: Shanduka Group

1. Paradise Papers outcome: Shanduka/Investec Mozambique energy deal offshored through Mauritius — was this investigated by SARS? Were any taxes recovered? What is the current status of any SARS or prosecutorial action?

   Partially answered (2026-04-13): The Appleby/Mauritius structure: Shanduka African Investments → Marihold One → $1.31m in consultancy fees to José Manuel Pereira Leitao with “no documentation on services provided” (Appleby compliance flag). Shanduka exited the Kuvaninga project in late 2011 following a dispute over participation rights; the deal never completed. No SARS investigation or prosecutorial action has been reported publicly. Ramaphosa’s response to the 2017 leak: no public statement found. The structure was abandoned before Ramaphosa became Deputy President. (Source: Mail & Guardian, November 2017)

2. Tshivhase Trust post-Phembani: After Shanduka merged into Phembani, the Tshivhase Trust reportedly retained a stake. Does Ramaphosa as a deferred beneficiary of this trust have a continuing indirect financial interest in Phembani’s assets — which include companies doing business with government?

   Answered by inference (2026-04-13): No documentary confirmation of a retained Phembani stake exists in any public source. The inference from available evidence strongly supports a complete exit:

   Evidence for complete exit: (1) Forbes (June 2015) used past tense “previously owned 30% in Shanduka” — published at the time of the completed deal. (2) Every source describing the transaction uses language of full divestment: “sold his entire stake,” “exiting all major business ties.” (3) Ramaphosa’s stated motivation was to “remove the potential of any conflict of interest” between his Deputy Presidency and his business interests — retaining a Phembani stake would have directly contradicted this. (4) IOL Business Report described it as Ramaphosa exiting as “chairman and shareholder.” (5) Phembani’s own website frames it as Phembani’s “acquisition of Shanduka” — no reference to any Shanduka-side continued beneficial interest. (6) The combined Shanduka-Phembani entity is controlled by Phuthuma Nhleko (chairman and co-founder of Phembani since 1994).

   What the Trust does hold (confirmed separately): Ntaba Nyoni Estates CC, trading as Phala Phala Wildlife farm — this is a confirmed Trust asset distinct from the Phembani transaction.

   The remaining gap: The Trust’s post-2015 asset portfolio (cash proceeds of $200–300m from Shanduka, any reinvestments) has never been publicly disclosed. Ramaphosa’s Parliamentary Register entries post-2015 kept Trust details confidential. The ConCourt Arena Holdings ruling (2022) applied pressure to disclose Trust tax records in the Phala Phala context but no broader disclosure followed.

   Verdict: The inference is that the Tshivhase Trust holds no current Phembani equity — the exit was complete and the conflict-of-interest rationale for divestment would have been defeated by any retained stake. The Trust’s current holdings (other than Phala Phala farm) are cash/reinvested assets that remain undisclosed. This cannot be confirmed without a Parliamentary Register entry or CIPC Trust register disclosure that has not materialised. (Sources: Forbes June 2015; Entrepreneur Hub SA; Phembani.com About page; IOL Business Report June 2015; Webber Wentzel 2022)

3. China Investment Corporation: Why did China’s sovereign wealth fund invest $243m in Shanduka in 2011? Were there any quid pro quo government-level agreements or preferential deals involving South African state entities tied to this investment?

   Answered (2026-04-13): CIC paid R2 billion (~$243m) for a 25% stake in Shanduka in December 2011 — CIC’s first SA transaction. Key structural detail: CIC acquired shares from exiting private shareholders (Old Mutual Private Equity and Investec), not via new share issuance; Shanduka itself did not receive the cash directly. Standard Bank advised Shanduka; Standard Chartered advised CIC. Ramaphosa’s stated rationale: “jointly explore future investment opportunities in South Africa and other parts of Africa.” CIC’s stated rationale: South Africa’s natural resources, lower political risk relative to other African markets, growing demographics. No evidence found of government quid pro quo, state entity preferential contracts, or linked diplomatic agreements. This appears to be a standard commercial secondary-market PE transaction, albeit politically visible given Ramaphosa’s ANC stature. (Sources: Reuters December 2011; SWFI; Wikipedia Shanduka Group)