The Legal Protection of International Investments in Eastern and Southern Africa - Lessons From Case

International direct investments can promotebroad legal framework, the Governments assure
sustainable economic developmentinvestors security of title and guarantees that
The legal protection of international foreigninvestment in the country will not be expropriated.
investments by states is one key instrument and aThere are also statutory guarantees for contract
very important mechanism to ensure the sustainableenforcement, recourse to legal systems for redress
economic development in African countries. It is oneand binding arbitration conclusions. These are all part
complex issue of Public International Law domain,of a well-established legal system whose
especially when it comes to specific measuresindependence and integrity continue to be guaranteed
adopted by states at the level of the national legalby the national Constitution.
frameworks.The level of investment protection is generally
The legal, business and economic environment formeasured on the basis of criteria related to: the
FDI in Eastern and Southern Africa (ESA) and thestandard of treatment of investment (MFN and
protection of international foreign investments isNational treatment principles), the performance
regulated at various levels, by internationalrequirements, expropriation and nationalization regime
agreements / treaties, regional agreements andand dispute settlement laws.
national codes or legislation. The domestication ofThe commitment to sound and consistent
international agreements / treaties as well as regionalmacroeconomic polices, constitutional guarantees
agreements into national legal systems and theiragainst expropriation of investment and for
subsequent enforcement by individual states requiresprotection of investment are clearly outlined in the
specific procedures of ratification and implementation.Constitution and the national investment laws and
The UN Conference on Trade and Developmentregional strategic orientation documents. Since
(UNCTAD) describes investment agreements as "thedeveloped countries and international development
most important protection of international foreignagencies have emphasized the need for
investment." They are creating more rights anddemocratization as a determinant criteria for
powers for foreign investors - particularly theattributing funds to African countries, there are new
transnational corporations. In many African countries,trends and strategic approaches of attracting foreign
the implementation of international and regionalfunds, under the logic of good governance and
instruments is not as effective as one would expect.transparency.
The causes of this hiatus are to be traced in variousIn general, legal protection of foreign investments
structural and institutional structures inherent tocovers the following key aspects:
national legal systems in these countries.(a) Discrimination in treatment of foreign investments.
The topic under investigation relates to the state of(b) Expropriation requirements for foreign
effective legal protection of international investmentsinvestments.
in Eastern and Southern African countries, mainlyAccording to the new trends in investment regimes,
within two regional blocs; i.e. SADC and COMESA. Thisconstitutional provisions and investment codes
article is the summary of a study conducted withinadopted a general legal framework for investment
the region, with the objective to identify and analyzepolicy in the countries under review. These trends
international law instruments applicable in the region,can be summarized in the following important
as well as the national situation in Mozambique as aguarantees:
specific study case on the domestication and(i)Liberal, free market economic environment
enforcement of international agreements.together with appropriate political and social policy
Africa is working hard to improve its general policyand pro gram framework;
framework for FDI(ii) Adherence to the principles of democratic
The general policy framework of FDI on the Africangovernance, constitutional guarantee of rights to
Continent has improved greatly in recent years, afreedom and liberty, welfare, property ownership and
trend that is continuing in many countries that wereprotection. In this regard, the countries are
not in recent past or are not currently affected byconstitutionally obliged to encourage, promote and
wars. However, the environment for foreignprotect beneficial investment as the enabler of
investments protection in Africa is still inadequate tosocioeconomic change and progress.
attract high quality and efficiency-seeking(iii) Full integration into the wider global economy
investments and the incentive framework continuesthrough regional organizations membership of and
to suffer from a number of deficiencies. Faced withadherence to charters and principles of and a host of
increased international competition, foreign investors'bilateral trade agreements among others. These
global strategies seek to maximize theirtestify to these countries resolve at participation and
competitiveness by locating facilities in multipleintegration in the global economy.
locations around the world. In this "increasingly(iv) Articulation of policies and strategies to make
globalized" world, attracting foreign investmenttrade and investment development a gateway to
depends more on the ability to provide a favorableregional and the larger African continental market.
investment protection regime and competitive(v) Conducive legal and institutional framework with
factors of production.more open laws that support and encourage free
The former requires a stable, efficient, andcirculation of goods and persons, including modern
service-oriented environment that welcomeslabor laws.
investors into most economic activities withoutThe principles above highlighted are however more
discrimination. Modern legal and intellectual propertyoften on the papers than really implemented in
rights, effective competition policies, a strongpractice. The framework of regional cooperation is
judiciary and minimum bureaucratic harassment are allbecoming a more compelling channel for the
important to attract foreign investors. The latter areimproving of national laws and policies.
the ultimate determinants of FDI. Competitive factorsDuring the lat two decades, the overwhelming
of production no longer mean just cheap raw laborexperience in many Eastern and Southern African
and basic infrastructures. Today they requirecountries is of poor investment environment. African
adaptable labor skills, sophisticated supplier networkscountries in general, have not offered foreign
and flexible institutions. Tax incentives can enhance ainvestors the kind of investment climate that they
country's attractiveness but if other factors arefind attractive. For a number of years, some African
unfavorable, they will be insufficient to significantlygovernments were very suspicious of foreign
increase inflows of FDI.investors. In very recent years, many African
This study argues that African countries in thecountries have reformed their policies toward foreign
eastern and southern region have made so farinvestors. Some have also acted to reduce the
commendable efforts to reform their legal andadministrative barriers that have so commonly
institutional frameworks for the promotion ofremained long after policies were reformed. Yet, the
investments. However, there still need to take intoreforms have not led to the increased inflows of
consideration the requirements for attracting foreignforeign investment that were anticipated and needed.
investments. In some instance, as illustrated by thePart of the explanation derives from the fact that
case of Mozambique, investment laws wereinvestors often are ill informed about the changes
modernized. But the Investment Protection Centrethat have occurred in countries whose investment
still need to have the authority required to decide onclimates were once inhospitable. Another part of the
investments, and need to be empowered and givenexplanation lies in the tendency of many investors to
autonomy. An other issue relates to some outdatedthink of Africa, or at least parts of Africa, as facing
regulations which need to be harmonized with thesimilar problems, even those problems that may in
new investment regimes. Legislation on land andfact be quite localized. Thus, war, civil disturbances,
ownership of production factors, labour laws, financialcollapsed regimes, as well as continuing bureaucratic
procedures, and other administrative barriers are thebarriers and remaining inhospitable policies toward
main key issues which need to be streamlined ininvestors affect the reputation of neighboring
order to satisfy international standards for attractingcountries, as well as the country experiencing the
foreign investmentsproblems
In their attempted efforts to attract FDI andExperience in African countries has demonstrated
determined to benefit from it to the fullest, thethat creating an enabling environment for investment
countries under review reformed their legalrequires finding solutions to constraints, which include,
frameworks for a better protection of foreignamong others:
investments. These changes are currently taking-unstable macro-economic framework or conditions;
place in an environment characterized by theinadequate infrastructure; inappropriate banking and
proliferation of investment rules at the bilateral,financial systems and regulatory and supervision legal
sub-regional, regional and multilateral levels. Theand institutional frameworks;
resulting investment rules, numerous Preferential and-inadequate resource mobilization and allocation
Free Trade Agreements with investmentmechanisms; lack of or limited information;
components, Bilateral Investment Treaties (BITs) andsocio-economic problems;
Multilateral Investment Agreements (MIA) are-unstable political and social environment; cumbersome
multi-layered and multi-faceted, with a myriad oflegislation and procedures, rules and regulations etc.;
obligations differing in geographical scope and-lack of specialized or some legislation and
coverage and ranging from the voluntary to theprocedures;
binding commitments. They constitute an intricate-skilled human resources;
web of obligations that partly overlap and partly-market size, debt burden and balance of payments
supplement one another. This study is of actualproblems; ineffective and inefficient institutional
interest for research, as it attempts to review thisframework, set-up or delivery; etc.
proliferation of legal frameworks for the protectionAn enabling environment for foreign investment
of international investments in the Southern andshould include:
Eastern African regions. There is real need to-stable macro-economic environment , good and
understand the policies, mechanisms developed in thisreliable infrastructure , law and order; secure property
very sensitive area, and to analyze the issues thatrights; enforceable contracts; a functional financial
are raised in the implementation of such intricatesystem; market determined prices - including the
frameworks.exchange rate and interest rates; etc.
The policy strategy currently pursued by manyThe legal and institutional frameworks are not
Southern African countries is explicitly intended tosufficient to guarantee a flow of foreign investments
improve conditions for foreign direct investmentin the Eastern and Southern African region. Other key
(FDI). Over the past two decades many countriesfactors are equally important
have implemented broad ranging economic reforms,Conclusion
including the liberalization of domestic markets andIn its final conclusion, the study finds that over two
some privatization, which has had an effect on thedecades, countries in the Eastern and Southern
flow and nature of foreign investment. However, InAfrican region have made considerable efforts to
the past, Africa has, on average, been relativelycreate adequate legal and regulatory frameworks for
unsuccessful in attracting FDI in spite of very largethe protection of foreign direct investments.
increases in global flowsHowever there remain serious impediments which still
However, the general policy framework of FDI onaffect negatively the flow of foreign investments.
the African Continent has improved greatly in recentInconsistent policies and inadequate host country
years, a trend that is continuing in many countriesoperational measures HCOMs, together with outdated
that are not destroyed by wars. However, thelabour laws are some of the challenges which call for
environment for foreign investments protection inmore reforms.
Africa is still inadequate to attract high quality andIt further reaches the conclusion that there is need
efficiency-seeking investments and the incentivefor awareness within the governments in the region
framework continues to suffer from a number ofon key issues related to the promotion and
deficiencies. Faced with increased internationalprotection of investments. It can be formulated as
competition, foreign investors' global strategies seekfollows: foreign investors want to gain market
to maximize their competitiveness by locating facilitiesaccess, have their investments protected and be
in multiple locations around the world.free to operate in a manner of their choosing. Host
In this 'increasingly globalized' world, attracting foreigncountries want to develop services and
investment depends more on the ability to provide ainfrastructure, meet local needs, produce exportable
favorable investment protection regime andgoods and improve locally available technology.
competitive factors of production. The formerThe interest of foreign investors and host
requires a stable, efficient, and service-orientedgovernments can be harmonized if the investment
environment that welcomes investors into mostmeets both sets of agendas. This can be done if
economic activities without discrimination. Modern legalinvestors decide on the viability of specific projects
and intellectual property rights, effective competitionand the host governments decide on the priority
policies, a strong judiciary and minimum bureaucraticsectors and conditions of FDI consistent with their
harassment are all important to attract foreigneconomic and development objectives.
investors. The latter are the ultimate determinants ofAs in the case of Mauritius, this should be a credible
FDI. Competitive factors of production no longerdevelopment programme backed by credible policy
mean just cheap raw labor and basic infrastructures.framework conducive to long-term economic and
Today they require adaptable labor skills,social stability. With such policies, the countries are
sophisticated supplier networks and flexiblemore likely to have the capacity over time to service
institutions. Tax incentives can enhance a country'sthe repatriation of profits, provide a skilled and
attractiveness but if other factors are unfavorable,healthy labour force, and develop suitable
they will be insufficient to significantly increase inflowsinfrastructure.
of FDI.Part of this credible programme should cover the
Experiences in Eastern and Southern Africa for FDIneed for convergent bilateral and multilateral
protection are changing rapidlyinvestment and trading arrangements in the COMESA
Many countries of the Eastern and Southern Africanand SADC regions to avoid trade and investment
region, mainly through their respective Economicdeflection and diversion. This should also go along
Integration Organizations, have adopted adequateway towards removing administrative and fiscal
legal environment to attract foreign investments.barriers to the promotion of investments. There is
Legal guarantees and protections for foreignalso need to adopt appropriate legal, regulatory and
investments are generally contained in the nationalinstitutional frameworks to ensure efficient and
Constitutions and in specific Investments laws. In asmooth implementation of the Work Programme.