25th March, 2009

The Honorable Minister Ministry of Tourism and Diasporan Relations Accra, Ghana Dear Honorable Madam Minister, FINAL GHATOF SUBMISSIONS ON THE TOURISM BILL We write on behalf of the Private Sector of Ghana’s Tourism Industry in general and on behalf of the Ghana Tourism Federation (GHATOF) in particular, to request your kind consideration of our final submissions regarding the Draft Ghana Tourism Bill as a follow-up to our previous one (attached), dated November 25, 2009 for which we received no reply from the Ministry: 1. GHATOF and private sector stakeholders were not given the opportunity earlier to comment on the proposed Tourism Bill; 2. The Final Report of the joint Policy and Finance Working Group of the Public-Private Partnership (PPP) on the Ghana Tourism Authority and the Ghana Tourism Fund were not taken into account when drafting the Tourism Bill; 3. The object of the Tourism Bill must be to establish the National Tourism Authority as a PublicPrivate Partnership (PPP) to market, promote, develop and regulate the tourism industry; 4. The title of the Bill is at variance with the Object and thus the Title must rather be National Tourism Authority Bill and not Tourism Bill; 5. Marketing and Promotion must be a primordial function of the National Tourism authority but not a subsidiary object of the Authority; 6. Reference to gender balance in Clause 5(1)(c) is discriminatory by referring only to the Private Sector and not the Public Sector; 7. In Clause 5(2) it will be an interference with the spirit of the PPP for the President to manipulate the appointment of Private Sector Representatives on the National Board as this is not wholly a public body but a Public-Private Partnership (PPP) 8. A transparent procurement process for the management of the National Tourism Authority will make it more efficient rather than make it a haven of political appointees being recruited by the President with the Public Services Commission (clause 16) managed and supervised by the National Board of Directors. 9. That ‘the Board shall perform the functions of the Authority’ (Clause 5(3)) is flawed as it makes redundant the management of the Authority;

Drafted by Jean Lukaz for the Ghana Tourism Federation (GHATOF)

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10. Regional and District Offices of the Authority are in addition a bureaucratic replication of chains of sub-Boards with staff to be appointed by the President (Clauses 17, 18, 19 and 20) according to article 195 of the Constitution; 11. It is recommended that the Accounts of the Authority are published for the purposes of accountability; 12. GHATOF’s recommendation to publish the Annual Report of the Authority to stakeholders for the purposes of accountability; 13. The Tourism Development Fund must be established by a different Act and not housed under the NATIONAL TOURISM AUTHORITY Bill; 14. The Tourism Development Fund with a Bank Account under the authority of the Accountant General (Clause 31) flaws the concept of PPP and makes the Authority a wholly government entity; 15. The key positions for the Tourism Development Fund shall be advertised and not managed by a Fund Committee and another Board appointed by the President; 16. The administration of the Tourism Development Fund is to be vested in the expertise of a Fund Administrator as his main function with responsibility to report to the Chief Executive of the National Tourism Authority; 17. A neutral financial institution acts as a Fund Manager with no direct business linkage with the National Tourism Authority to manage the finances of the Fund; 18. An External Auditor being a competent Private Auditing Firm to oversee the accountability of the Fund. 19. The provisions in PART TWO of the ‘Tourism Bill’ i.e., a. Licensing, b. Complaints Procedure, c. Inspection, d. Public-Private Partnership Forum (PPPF), e. Collaboration with Public Agencies, f. Consumer Protection Provisions,

question existing legislative instruments and regulations and create and further creates a bureaucratic environment that impedes the progress intended to come along with this Bill.

Drafted by Jean Lukaz for the Ghana Tourism Federation (GHATOF)

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It is our hope that you shall take our comments in good faith.

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Yours in Service to Ghana Tourism,

Stella W. Appenteng (President)

Enclosed (2): 1. First Submission Letter to Minister on Tourism Bill 2. Ghana Tourism Authority and Ghana Tourism Fund Final Report of the Joint Policy and Finance Workgroup

Drafted by Jean Lukaz for the Ghana Tourism Federation (GHATOF)

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