Deal sheet
- Status
- BOTSWANA'S REGULATOR-APPROVED DISTRIBUTION BASIS IS 70:30 IN FAVOUR OF CREATORS. COSBOTS'S OWN SIGNED MINUTES RECORD 61:39, AND ITS CHIEF EXECUTIVE TOLD THE SAME MEETING THAT BWP 6 MILLION OF INTERNATIONAL ROYALTY PROVISION WAS "PENDING, SONY'S PAYMENTS."
The Copyright Society of Botswana (COSBOTS) is the collective administration body established by name under section 36A of the Copyright and Neighbouring Rights Act, Chapter 68:02, as a non-profit company limited by guarantee. It licenses users, sets royalty rates and collects and distributes royalties to copyright owners whom it represents. It does not own those copyrights.
THE DOCUMENT. On 10 August 2024 COSBOTS held its annual general meeting by live stream across five locations: Gaborone, Ghanzi, Maun, Francistown and Palapye. 203 members attended. The meeting approved the audited annual financial statements for the period 1 July 2022 to 30 June 2023. The minutes of that meeting were signed by board chairperson Bakalanga Malikongwa and chief executive Letlhogonolo Makwinja and dated 13 September 2025, thirteen months after the meeting and roughly fourteen and a half months after the end of the financial year the meeting approved. One member, minuted as Mr Mantswe, told the meeting his AGM pack "consisted of the 2022 financials instead of 2023."
THE RATIO. Malikongwa is minuted stating: "The Distribution is 70: 30 which is stipulated by CIPA and COSBOTS is currently at 61:39. The 70% is for the creatives' distributions and 30% for administration." She said she had committed three years earlier to reaching 70 percent by 2025. Makwinja described the 61 percent as "just a small gap from the 70% stipulated by CIPA." The society's treasurer, Winnie Sekani, confirmed the 61 percent ratio in a trade report of the same meeting. On the society's own revenue of BWP 18,536,734, the nine-percentage-point gap between the approved basis and the reported outcome is worth approximately BWP 1.67 million in a single year.
THE AUDIT POSITION. The society's auditor, introduced in the minutes as being from MSD Mesotlo and Associates, reported a "CLEAN/ UNQUALIFIED OPINION" on the financial statements for the period ending 30 June 2023, with the report signed in March 2024. A clean audit opinion addresses whether the statements are free of material misstatement under IFRS. It does not certify that the distribution ratio met the regulator-approved basis, and nothing in the minutes suggests the auditor was asked to opine on that.
THE ARITHMETIC THAT DOES NOT HOLD. Within the one signed document, the same year's revenue growth is described as "47%" by the chief executive and as "a 14%" by the finance manager; the society's own two revenue figures give 47.6 percent. The same year's expense movement, from BWP 13.3 million to BWP 11.6 million, is described in the minutes as a "36% drop"; it is a 12 percent drop, and 36 percent is the distribution-growth figure from the preceding paragraph. In the trade report of the same meeting, the two stated components of the 16th Distribution, BWP 9,558,290 and BWP 2,027,577, add to BWP 315,796 more than the BWP 11,270,071 total stated alongside them. The chairperson's minuted reprography distribution figure, "1.7 million Pula," is roughly BWP 328,000 below the BWP 2,027,577 reported. The distribution increase is "35%" in the chairperson's report and "36%" in the finance report.
WHERE THE MONEY GOES. Malikongwa told the meeting that under an 80:20 local quota, "in the past only 20% distributions were allocated to our local creators, however currently 72% has been distributed to local members with 28% being distributed as foreign royalties." Two distributions earlier, in the 14th Distribution reported on 15 December 2021, the direction was close to the reverse: of BWP 3,428,127 paid out, BWP 2,134,348.70 went to foreign rightsholders and BWP 950,965.60 to local artists, with BWP 342,812.70 to the Social and Cultural Fund. Makwinja said at the time: "Once again, we are still seeing a lot of money taken out of the country." Local content was then 31 percent of airplay on the three monitored broadcast services. No source checked reconciles the two positions or dates the crossover. In the same 2024 minutes, the itemised provisions show international royalties held at BWP 7.5 million against local matched royalties of BWP 406,000 and local unmatched of BWP 1.2 million; provisions are money held, not money distributed, and this record does not treat the two measures as equivalent.
THE SONY LINE. Answering a member's question about how a planned creative hub would be funded, Makwinja is minuted saying that "the Provision for International Royalties is at BWP 6m pending, Sony's payments." The minutes identify no Sony entity, state no date, term or territory, and do not say whether the BWP 6 million is money COSBOTS expects to receive or money it is holding to pay out. Nothing in the minutes or in any other source checked alleges any failure, breach or wrongdoing by any Sony company, and this record makes no such allegation. It records only that COSBOTS's chief executive used that phrase, on the record, at its 2024 annual general meeting.
UNCLAIMED MONEY BECAME A FIXED ASSET. Makwinja is minuted telling members that the claim window for unmatched royalties had been cut from seven years to two, which he described as an international rule followed by CISAC members, and that beyond that window "royalties cannot be claimed." Malikongwa is minuted explaining that "the funds that were used to buy the building were money that was not claimed after the agreed period," and that "the Act allowed COSBOTS to use the money appropriately after a certain time has passed." In the year under review, BWP 1.6 million of unmatched local royalties and BWP 1.5 million of uncollected Covid relief were "written off back into the distribution pool," so part of the record 16th Distribution was recycled unclaimed money rather than new collection. Malikongwa separately told the meeting that royalties exceeding BWP 500,000 remained unmatched.
A MEMBER ON THE RECORD. Minuted at the same meeting: "Mr Ephraim Khan highlighted that he is one of the first members of COSBOTS, registered as a Producer but has never received any royalty, he was also concerned with his international works on how COSBOTS would assist him for the international collections." The minutes record no figure, no case reference and no resolution for his position.
THE ARCHIVE IS OFFLINE. The documents this record rests on were published by COSBOTS on its own website. On 11 November 2026 cosbots.com did not resolve from this desk's server, returning NXDOMAIN on repeated DNS lookups. The signed 2024 minutes and the society's membership distribution rules were readable only through archived copies captured on 17 June 2026, and the last archived capture of the homepage returning HTTP 200 is dated 15 July 2026. No source checked explains the domain's status.
NET FINDING. A statutory collecting society, audited clean, told its members in its own signed minutes that it was running nine percentage points below the distribution basis its regulator approves, in a year when it posted record revenue, a BWP 4.6 million deficit, and a set of internal figures that do not reconcile with each other or with the trade account of the same meeting. No rights changed hands.
- Type
- Licensing
- Parties
- Copyright Society of Botswana
- Amount
- BWP Not a transaction amount. No consideration passed and nothing was bought or sold. The figures below are collection, distribution and balance-sheet figures for the financial year ended 30 June 2023, as recorded in COSBOTS's own signed annual general meeting minutes and in a Gaborone trade report of the same meeting. Several of them do not reconcile with each other, and the record states so rather than selecting between them.
REVENUE. BWP 18,536,734 for the year ended 30 June 2023, against BWP 12,556,034 the previous year. Chief executive Letlhogonolo Makwinja told the meeting the society "had made BWP 18.5 million, the highest that COSBOTS had ever made," and put growth at "47% revenue growth." The trade report of the same meeting gives 48 percent. COSBOTS's own finance manager, Laone Mareka, is minuted at the same meeting describing the same movement as "a 14% from the BWP 12.5 million." On the society's own two revenue figures the increase is 47.6 percent; the 14 percent in the signed minutes is not explained anywhere in them.
REVENUE SPLIT. Music rights BWP 13,247,981 and reprography BWP 5,288,757, per the trade report. Mareka's minuted figure for reprography collection is "BWP 5 million," reprographic rights having been approved in March 2022 with 2023 the first year of collection.
THE 16TH DISTRIBUTION. BWP 11,270,071 declared, against BWP 8,300,000 for the 15th Distribution the previous year, an increase of 36 percent. The minutes record Mareka giving "BWP 11.3 million" against "BWP 8.3 million" and the same 36 percent. Board chairperson Bakalanga Malikongwa is minuted describing the increase as "a commendable 35%" and an "increase of P3 million in total distributions."
THE 16TH DISTRIBUTION COMPONENTS DO NOT SUM. The trade report gives BWP 9,558,290 for music rights and BWP 2,027,577 for reprographic rights. Those two add to BWP 11,585,867, which is BWP 315,796 more than the BWP 11,270,071 total stated in the same report. Malikongwa's minuted figures for the same year are "9.5 million Pula in music category and 1.7 million Pula in reprography," which add to BWP 11.2 million. The reprography component therefore appears as BWP 1.7 million in the society's own minutes and BWP 2,027,577 in the trade report, a gap of roughly BWP 328,000. No source checked reconciles the three sets of figures.
OPERATING EXPENSES. BWP 11,643,447 against BWP 13,263,521 the previous year, per the trade report, which calls that a 12 percent fall. That arithmetic is correct: it is a 12.2 percent fall. The signed minutes record Mareka giving the same two figures, "previously BWP 13.3 million and currently are at BWP 11.6 million," and then describing the movement as a "36% drop due to sticking to a strict budget." 36 percent is the distribution-growth figure from the preceding minuted paragraph.
DEFICIT. A loss of BWP 4.6 million for the year, which Mareka attributed to COSBOTS being "not profit-driven but committed to distributions."
PROVISIONS, BWP 22.8 MILLION TOTAL, itemised in the minutes as: Distribution BWP 11.2 million; International royalties BWP 7.5 million; Local matched BWP 406,000; Local unmatched BWP 1.2 million; Social and Cultural balance BWP 981,000; undistributed mechanical rights BWP 192,000; Covid refund BWP 49,000; and a provision for other rights covering folklore, poetry and choral works of BWP 1 million.
THE INTERNATIONAL ROYALTY FIGURE IS GIVEN TWICE, DIFFERENTLY, AT THE SAME MEETING. The itemised provisions list records "International royalties BWP 7.5 million." Answering a member's question about funding for a planned creative hub at the same meeting, Makwinja is minuted saying "the Provision for International Royalties is at BWP 6m pending, Sony's payments." The two figures are BWP 1.5 million apart and neither is reconciled to the other in the document.
ASSETS. Right-of-use BWP 3.2 million; trade and other receivables BWP 3.6 million; short-term investments BWP 10.3 million described as "provisioned for royalties, money invested"; liquid assets BWP 11.6 million described as "operational funds and distribution."
UNMATCHED AND RECYCLED MONEY. BWP 1.6 million of unmatched local royalties, and BWP 1.5 million of a BWP 3 million pool of uncollected Covid relief funds, were "written off back into the distribution pool" in the year, per Mareka. Malikongwa separately told the meeting that royalties "that exceed BWP 500,000.00" remained unmatched.
MEMBERSHIP. 3,097 members, per Mareka. 203 members attended the meeting across Gaborone, Ghanzi, Maun, Francistown and Palapye; the board secretary is minuted confirming "181 Members including 8 proxies" as the quorum.
PRIOR-PERIOD FIGURES, FOR CONTEXT ONLY. The 14th Distribution, reported 15 December 2021: collections of BWP 7.3 million and a payout of BWP 3,428,127, of which BWP 2,134,348.70 went to foreign rightsholders, BWP 950,965.60 to local artists (BWP 782,514.34 to local COSBOTS members and BWP 168,451.26 to unmatched local works) and BWP 342,812.70 to the Social and Cultural Fund. Those three lines reconcile exactly to BWP 3,428,127, and the Social and Cultural Fund line is exactly 10 percent of it. The government news agency reported on 31 May 2022 that BWP 8.8 million had been approved and distributed for the 2019/20 and 2020/21 financial years combined, BWP 1.5 million for 2019/20 and BWP 7.3 million for 2020/21, and that royalties had been around BWP 500,000 in 2014.
- Rights covered
- STATUTORY COLLECTING-SOCIETY LICENSING, COLLECTION AND DISTRIBUTION RECORD ONLY. No master recording, composition or publishing right is owned, assigned, acquired or transferred as a result of anything recorded here, and no catalogue changed hands. COSBOTS does not own the copyrights it monetises.
WHAT COSBOTS ACTUALLY DOES, PER THE STATUTE. The Copyright and Neighbouring Rights Act, Chapter 68:02 of the Laws of Botswana, as amended by Act 6 of 2006, section 36A(1), provides that "there shall be established, for the various categories of works protected under this Act, a collective administration body to be known as the Copyright Society of Botswana." Section 36A(2) makes it "a non-profit making company limited by guarantee" responsible for "(a) the negotiation and granting of licences in written agreement with the owners of copyright" for adaptation, insertion in other scopes and use for publicity purposes; "(b) setting rates for royalties in accordance with acceptable international standards"; and "(c) the collection and distribution of royalties to appropriate owners of copyright." Section 36A(3)(a) requires it to "represent the owners of the copyright." So COSBOTS LICENSES users and ADMINISTERS and DISTRIBUTES royalties under a representation mandate. It does not take assignment of rights and it is not a publisher, a label or a distributor of recordings.
THE APPROVAL POINT THIS RECORD TURNS ON. Section 36A(3)(b) requires COSBOTS to "put in place rules and regulations, approved by the Copyright Office." Section 36B(2) provides that "the Copyright Society shall distribute royalties on an equitable basis, approved by the Copyright Office, to its members." Section 36B(1) requires COSBOTS, "as soon as reasonably practicable after the end of each financial year," to submit to the Copyright Office a report of its operations and performance, a copy of its audited financial statements, and any other reports the Copyright Office requests. The Copyright Office is headed by a Copyright Administrator under the Act; the Companies and Intellectual Property Authority (CIPA) is the body that houses that function in practice, and CIPA officers attended the meeting recorded here as regulators and observers without the right to participate or vote, per the minutes.
THE 70:30 BASIS. Board chairperson Bakalanga Malikongwa is minuted stating: "The Distribution is 70: 30 which is stipulated by CIPA and COSBOTS is currently at 61:39. The 70% is for the creatives' distributions and 30% for administration." She told the same meeting that three years earlier she had committed to reaching 70 percent royalty distribution by 2025, and that "currently the distribution stands at 61% of income as royalties and the administration fees constituting to only 39%." Chief executive Letlhogonolo Makwinja is minuted at the same meeting describing 61 percent as "just a small gap from the 70% stipulated by CIPA." Treasurer Winnie Sekani is quoted in a trade report of the same meeting confirming the ratio "stands at 61%" and saying COSBOTS is working to ensure that "copyright owners are the primary beneficiaries" of its collections. This desk located no CIPA-issued document stating a 70:30 figure; the characterisation of it as "stipulated by CIPA" is COSBOTS's own, made by two of its officers on the record, and sits logically under the section 36B(2) approval power rather than under any provision that names a percentage.
WHAT COSBOTS DOES NOT ADMINISTER. Section 35G of the same Act imposes a levy on "all imported and locally manufactured blank sound and audio visual carriers, compact discs and equipment capable of being used to copy protected materials," at a rate "prescribed by the Minister." Section 35G(2) provides that "the levy shall be collected by the Department of Customs and Excise and shall be deposited in a fund to be established by the Minister of Finance and Development Planning for the development of authors and publishers of works." COSBOTS appears nowhere in section 35G. Malikongwa is minuted confirming this from the society's side: the Levy on Technical Devices Fund "was left under the Administration of the Ministry instead of COSBOTS," which she called "an oversight when the Act was formed," adding that "COSBOTS has limited control of the funds and how it can be distributed." The statutory text and the chairperson's account agree on this point.
INTERNATIONAL AND RECIPROCAL POSITION. Makwinja is minuted telling the meeting "as members of CISAC, we follow the rules and acts for all CMOs," and citing a CISAC-aligned reduction of the unmatched-royalty claim window from seven years to two. Malikongwa is minuted saying funds for a planned creative hub "will not be from the local content but funds from other CMOs and that CMOs assist each other to grow creativity by these," and referring to submissions to ARIPO on an international levy remuneration strategy. The minutes also record WIPO Connect being used "for the first time for distribution." No bilateral reciprocal representation agreement between COSBOTS and any individually named foreign society was located in any source checked, and no territory, term or rate for any such agreement is established by this record.
LICENSEE-SIDE RELATIONSHIPS NAMED IN THE DOCUMENT. The minutes record that COSBOTS was, at year end, "in the process of extending the DBS memorandum," with "the key component on the memorandum" being the 80:20 local-content ratio. DBS is the public broadcaster. Makwinja is minuted saying private broadcasters "have now started paying and they are currently at 5%, and 41% is from retail shops," describing the composition of licence income. Audio-visual tariffs were "being drafted and are going to be submitted for approval."
- Territory
- Botswana
- Announced
- 2024-08-10
- Primary document
- Statement from a named party
- Sources
- Copyright Society of Botswana, "AGM for Members of the Copyright Society of Botswana," minutes of the annual general meeting held by multi-location live stream at 09:00 on 10 August 2024, 30 pages, signed by board chairperson Bakalanga Malikongwa and chief executive Letlhogonolo Makwinja and dated 13/09/2025, minutes recorded by Baker Tilly Botswana Advisory Services. THE DOCUMENT THIS RECORD TURNS ON. Carries the chairperson's statement that "The Distribution is 70: 30 which is stipulated by CIPA and COSBOTS is currently at 61:39"; the chief executive's statement that "the Provision for International Royalties is at BWP 6m pending, Sony's payments"; the full itemised provisions, asset and liability schedule; the 80:20 local quota figures; the Levy on Technical Devices Fund explanation; the unmatched-royalty claim window and the statement that unclaimed money bought the society's building; member Ephraim Khan's statement that he "has never received any royalty"; the clean/unqualified audit opinion for the period ending 30 June 2023; and the three resolutions passed. Published by COSBOTS on its own website and read here from the Internet Archive capture dated 17 June 2026, cosbots.com itself having returned NXDOMAIN when queried on 11 November 2026. Fetched as a binary PDF and read in full across all 30 pages. · Mmegi Online, "COSBOTS revenue and royalties increase," by Nnasaretha Kgamanyane, published 16 August 2024. THE AUDITED FIGURES IN FULL PRECISION, from a trade account of the same 10 August 2024 annual general meeting. Gives revenue of P18,536,734 against P12,556,034 (48 percent growth); music rights revenue P13,247,981 and reprography revenue P5,288,757; the 16th Distribution declared at P11,270,071, up 36 percent, split P9,558,290 music rights and P2,027,577 reprographic rights; the 15th Distribution at P8,300,000; operating expenses of P11,643,447 against P13,263,521, down 12 percent; and the 61 percent distribution-to-revenue ratio. Quotes treasurer Winnie Sekani that the ratio "stands at 61%" and that COSBOTS works to ensure "copyright owners are the primary beneficiaries." Does not mention the 70 percent target. Fetched and read in full. · The Botswana Gazette, "COSBOTS pays out P7.3m in latest distribution," Gosego Motsumi, published 15 December 2021. THE PRIOR-PERIOD FOREIGN AND LOCAL SPLIT. Gives the 14th Distribution: collections P7.3 million, payout P3,428,127, of which P2,134,348.70 to foreign artists, P950,965.60 to local artists (P782,514.34 to local COSBOTS members, P168,451.26 to unmatched local works) and P342,812.70 to the Social and Cultural Fund. Those three lines reconcile exactly to P3,428,127 and the fund line is exactly 10 percent of it, arithmetic performed by this desk. Records local content at 31 percent of airplay on RB1, RB2 and Btv. Quotes chief executive Letlhogonolo Makwinja: "Once again, we are still seeing a lot of money taken out of the country." Names the board chairperson as Bakalanga Mahoko. Fetched and read in full. · Botswana Daily News (Botswana Press Agency, BOPA), "COSBOTS approves P8.8 million royalties," by Idah Basimane, Gaborone, published 31 May 2022. THE EARLIER DISTRIBUTION RECORD AND THE CIPA LICENSING FRICTION. Reports P8.8 million approved and distributed for the 2019/20 and 2020/21 financial years combined, P1.5 million for 2019/20 and P7.3 million for 2020/21, and royalties of around P500,000 in 2014; a revised constitution approved with 97 percent in favour; and members objecting to licensing conditions attached to COSBOTS by CIPA. Quotes board chairperson Bakalanga Mahoko, "We do this by optimising our business, by being transparent," and chief executive Letlhogonolo Makwinja, "At COSBOTS, we want to be among the best collective rights management society." Fetched and read in full. · Government of Botswana, Copyright and Neighbouring Rights Act, Chapter 68:02, consolidated text incorporating Act 8 of 2000, S.I. 65 of 2001, Act 6 of 2006 and S.I. 71 of 2006, 19 pages. THE STATUTORY BASIS. Section 36A establishes the Copyright Society of Botswana by name as a non-profit company limited by guarantee responsible for granting licences in written agreement with copyright owners, setting royalty rates and collecting and distributing royalties, and requires it to represent copyright owners and to put rules in place "approved by the Copyright Office." Section 36B requires annual submission of an operations report and audited financial statements to the Copyright Office, and provides that it "shall distribute royalties on an equitable basis, approved by the Copyright Office, to its members." Section 35G places the levy on blank carriers and copying equipment with the Department of Customs and Excise and a fund established by the Minister of Finance and Development Planning, not with COSBOTS, corroborating the chairperson's minuted account of the Levy on Technical Devices Fund. Fetched as a binary PDF, extracted with pypdf and read in full across 19 pages. · Copyright Society of Botswana, "Membership Distribution Rules," published on its own site in November 2021, read via the Internet Archive capture dated 17 June 2026. Located and retrieved as a binary PDF; cited here as the society's published distribution rulebook. The ratio and provision claims in this record are sourced to the signed 2024 AGM minutes and the trade account of that meeting, not to this document.
Read this before citing: WHAT COULD NOT BE ESTABLISHED, STATED PLAINLY:
(1) NO CIPA DOCUMENT STATING 70:30 WAS LOCATED. That the split is "stipulated by CIPA" is COSBOTS's own characterisation, made on the record by its board chairperson and echoed by its chief executive at the same meeting. The Copyright and Neighbouring Rights Act, Chapter 68:02, section 36B(2) requires COSBOTS to distribute "on an equitable basis, approved by the Copyright Office," and section 36A(3)(b) requires its rules to be approved by the Copyright Office, but neither section names a percentage. This desk attempted to fetch CIPA's collective-management page at cipa.co.bw on 11 November 2026 and the request timed out after 60 seconds. This record does not assert that CIPA has published a 70:30 rule; it asserts that two named COSBOTS officers said at its AGM that CIPA stipulates one.
(2) WHICH SONY ENTITY IS NOT ESTABLISHED, AND NEITHER IS THE DIRECTION OF PAYMENT. The minutes say only "Sony's payments." They do not name Sony Group Corporation, Sony Music Entertainment, Sony Music Publishing or any other specific company, and no Sony entity is recorded as a party to this record for that reason. Because the figure is described as a "Provision," which is a liability, the natural accounting reading is money COSBOTS holds for onward payment; the phrase "pending, Sony's payments" could equally describe money COSBOTS is waiting to receive. No source checked resolves this, and this record does not choose between the two readings. No wrongdoing by any Sony company is alleged or implied.
(3) THE TWO INTERNATIONAL ROYALTY FIGURES ARE NOT RECONCILED. BWP 7.5 million appears in the itemised provisions in the same minutes in which the chief executive gives BWP 6 million. They may be the same balance measured at different dates or on different bases, or they may be different balances. The document does not say.
(4) THE LOCAL AND FOREIGN SHARES ARE NOT RECONCILED ACROSS DISTRIBUTIONS. The 14th Distribution, reported December 2021, sent roughly 69 percent of the local-and-foreign distributable to foreign rightsholders. The chairperson told the August 2024 meeting that 72 percent was currently going to local members and 28 percent out as foreign royalties. Those are different distributions, measured two cycles apart, and the increase in local airplay the chairperson credits is a plausible driver, but no source checked gives a year-by-year series that would let this desk verify the shift or date it. The record states both figures and does not average, interpolate or pick between them.
(5) "72 PERCENT" IS USED TWICE AT THE SAME MEETING FOR TWO DIFFERENT THINGS. The chairperson uses it for the share of distributions going to local members. The chief executive uses it in "72% of this money has been distributed," referring to the BWP 11.2 million distribution figure. These are not the same measurement and this record does not treat them as corroborating each other.
(6) THE BOARD CHAIRPERSON'S SURNAME IS GIVEN DIFFERENTLY ACROSS PERIODS. Reports dated 15 December 2021 and 31 May 2022 name the board chairperson as Bakalanga Mahoko, with one of them also rendering it "Makalanga" in a single instance. The 10 August 2024 minutes name her as Bakalanga Malikongwa throughout, including in the signature block. Whether this is the same person under a changed name, or two people, could not be established from any source checked, and this record does not assert either.
(7) THE AUDITOR'S NAME IS GIVEN TWO WAYS IN ONE DOCUMENT. The minutes introduce "Thero Rahuwe from MSD Mesotlo & Associates" and then refer to "Mr. Rahube" when recording the opinion, with the attendance list giving "Mr T Rahube" of "MSD and Associates." The resolution appointing auditors for 2024 names "MSD and Associates." This record does not resolve the spellings.
(8) ATTENDANCE AND QUORUM DO NOT MATCH. The attendance table totals 203 members across five locations. The board secretary is minuted confirming "181 Members including 8 proxies" at commencement. The minutes do not explain the difference.
(9) NO 2025 OR 2026 AGM MINUTES WERE LOCATED. The signed 2024 minutes, covering the year to 30 June 2023, are the most recent COSBOTS governance document this desk could obtain. No source checked reports a subsequent AGM, a 17th Distribution, or any 2025 or 2026 figures.
(10) NO NAMED RECIPROCAL AGREEMENT. The chief executive states CISAC membership and the chairperson refers to "funds from other CMOs," but no bilateral reciprocal representation agreement with an individually named foreign society was located, and no territory, term or rate for any such agreement is established. CISAC's public societies list at members.cisac.org returned HTTP 500 when fetched on 11 November 2026.
(11) THE SOCIETY'S WEBSITE DOES NOT RESOLVE. cosbots.com returned NXDOMAIN on repeated DNS lookups from this desk's server on 11 November 2026. Whether this reflects a lapsed registration, a migration or a deliberate takedown could not be established. The primary document underlying this record was therefore read from an archived copy captured 17 June 2026.
(12) UNVERIFIED SELF-DESCRIPTION NOT ADOPTED. The minutes record the finance manager saying "COSBOTS is ranked number 3 in Africa in 52 countries," and the chairperson saying the society's BWP 20,000 bereavement benefit "places COSBOTS funding as the highest in Africa with SAMRO in South Africa coming in second." Neither claim carries a source or methodology in the document and neither is asserted by this record.
(13) NO RIGHTS CHANGED HANDS. This record documents a statutory collecting society's licensing, collection and distribution activity and its own officers' statements about its distribution basis. No master recording, composition or publishing right is owned, assigned, licensed, administered or distributed differently as a result of anything recorded here. COSBOTS represents copyright owners; it does not own their copyrights.
