25th August 2021

Attn: Mr. Felix Cudjoe Ahiable

Compliance Manager
SSNIT

Dear Sir,
RE: SSNIT DECISION IN PETITION OF SIX (6) EX-PASTORS V. LIGHTHOUSE CHAPEL
INTERNATIONAL
We are Lex Praxis Incorporated, Lawyers for the six ex-Lighthouse Church International Pastors. Our clients
received your letters headed as above on 25th August 2021.
We have noted your decision in response to the Petition by our clients with regards to the failure of the ex-
employer Lighthouse Chapel International (UD-OLG) (the Church) to pay the SSNIT contributions of our
clients.
We also note that in all your responses you stated that our clients
“could not provide evidence of being in the employment of Lighthouse Chapel International
Ghana for the period, and by extension any salaries earned on which social security
contributions were not paid”
We are instructed to write on behalf of our clients and respond as follows:
We find this decision grotesque, and indeed inconsistent with applicable law and settled judicial precedent.
We disagree entirely with it.
we had occasion during the process to express our dissatisfaction with the conduct of this investigation and
the posture of SSNIT, but the outcome still is shocking because it flies in the face of what the laws
establishing SSNIT dictate, and indeed undermines SSNIT’s purpose.
We have therefore decided that unless SSNIT itself is minded to amend its position, we have elected not to
engage with SSNIT further, or Appeal the decision under the dispute Sections of Act 766. We will let the
Labour court which is already seised with this matter rule on it and make consequential orders which will
be binding on SSNIT.
WHO IS AN EMPLOYEE?
The question of determining who is an “employee” or a “worker” is no longer subjective, It has been
cerebrated by legal scholars at length and agreed upon! The fundamental principles are trite, they are well
settled Common Law, Case Law and Statute Law, and they are being expanded to cover modern
manifestations within the workplace.
One would expect this to be a problem in some of these modern manifestations of work (such as in the case
of (‘Gig Workers” e.g. Uber drivers), but not in ancient professions such as the Clergy.
The question of whether a Pastor engaged by a church for decades, whose work is controlled closely by the
church, who is transferred (locally or internationally) at the behest of his Bishop, and who reports
consistently to the headquarters in Accra and remit funds to the Headquarters (or as the Headquarters will
dictate), and who receive their salaries from the headquarters or as the headquarters will dictate etc etc.
does not constitute a difficult task. Just a diligent application of the facts to existing law and established
practice would yield a good answer.
We find it strange that SSNIT failed at this task when it is established specifically, and resourced very well
financially, to answer these questions and bring people into compliance.
We would have left this matter alone, but we are moved to remark not just as lawyers, but also as citizens of
Ghana who SSNIT serve. We are aware of the deleterious effect such a decision could have on SSNIT. As citizens
We are concerned that SSNIT as an institution seems to be failing in almost everything it is tasked to do. We hope
this response will help revise the notes at SSNIT.
SSNIT which receives millions of dollars every month, simply because of the Pensions Law, and lacks no financial
resource, (indeed SSNIT is known to be a profligate spender on all manner of things and is not even diligent in
managing its loans to the point where over 90% of its loan book could be impaired), cannot be said to lack the
requisite human or other resources to perform this task satisfactorily. We are at a loss on how as an institution
with your various teams (including lawyers), could arrive at such a conclusion when the legal principles regarding
this matter are quite settled.

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DEFINITIONS
We deem it useful to reproduce some definitions from Section 175 of The Labour Act 2003 (ACT 651).
1. “Employer” means “any person who employs a worker under a contract of employment”.
2. “Contract of Employment” means “a contract of service whether express or implied, and if express
whether oral or in writing.
3. The “Workplace” “includes any place where a worker needs to be or to go by reason of his or her
work which is under the direct or indirect control of the worker”.
4. “Remuneration” includes “the basic or minimum wage or salary and any additional emoluments
payable directly or indirectly by the employer to the worker on account of the worker’s
employment”
5. Repatriation Expenses” includes – “(a) subsistence and traveling expenses of the worker and
accompanying members of his or her family during the journey to and from the place of employment”.
Section 9 of the Labour Act 2003 (ACT 651) provides that:
“Without prejudice to the provisions of this Act and any other enactment for the time being in force, in any
contract of employment or collective agreement, the duties of an employer include the duty to
(a) provide work and appropriate raw materials, machinery, equipment and tools;
(b) pay the agreed remuneration at the time and place agreed on in the contact of employment or collective
bargaining agreement or by law or agreed between the employer and the worker;
(f) furnish the worker with a copy of the worker’s contract of employment;
(g) keep open the channels of communication with the workers; and
(h) protect the interests of the workers”.
Section 12 and 13 of the Act further provide that:
12. (1) The employment of a worker by an employer for a period of six months or more or for a number
of working days equivalent to six months or more within a year shall be secured by a written contract of
employment. (2) A contract of employment shall express in clear terms the rights and obligations of the
parties.
13. Subject to the terms and conditions of a contract of employment between an employer and a worker,
the employer shall within two months after the commencement of the employment furnish the worker with
written statement of the particulars of the main terms of the contract of employment in the form set out
in Schedule 1 to this Act signed by the employer and the worker.
The Pension Act 2008 (ACT 766) in Section 211, provides the following definitions:
These and the definitions above are useful in determining the status of employees. We have taken the liberty
to reproduce same below:
1. An “Employer” means “
a. The owner of an establishment or the person who, or the Board which, has the ultimate control
over the affairs of the establishment, and where such affairs are entrusted to a manager,
managing director or managing agent, such manager, director or agent.
b. In any other case, the person with whom the worker entered into a contract of service or
apprenticeship and who is responsible for the payment of his salary.

2. A “Worker” includes “a person who is employed for salary in any kind of work, manual or otherwise,
in or in connection with the work of an establishment, and who gets his salary, directly or indirectly
from the employer, and any person employed by or through a contractor in or in connection with the
normal work of the establishment, who is …
(ii) outside Ghana but employed by an employer in Ghana.

3. An “Establishment” means “any office, shop, factory, mine, plantation, or any other place where
persons are employed on salary for work or business of any kind”.

4. A “Salary” includes “the emoluments which are earned by a worker while on duty in accordance with
the express or implied terms of the contract of employment or apprenticeship, and which are paid or
payable in cash to the worker at fixed or determinable intervals of time.
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The definitions provided in the Statutes quoted above sufficiently direct the “examiner” and help conclude
the matter when determining whether our clients were employees or not.

Our clients were offered work (employment) as Pastors and missionaries, within the Lighthouse Chapel
International (establishment). They accepted the work, (thus forming an employment contract) and
proceeded to perform the work for salaries which they received directly and indirectly over the various
periods of their engagement (from 6 to 20 years).
They were under the direct and constant control of the employer who instructed them on every aspect of
their work.
They were transferred within Ghana and outside Ghana as employees of the original establishment and in
some instances described the transfers as ”INTRA COMPANY transfers”.
Whiles they were on transfer, they remained in the full control of the original establishment and indeed
could be summoned at any time and moved at any time to any place which the Bishop heading the
establishment pleased, and this happened often. On several occasions they were called to accompany the
Bishop on his trips to various places.
These employees accounted to the Bishop and the original establishment directly, or indirectly through
officers designated by the original establishment. They were mandatorily required to attend periodic
meetings to account for their every action at the original establishment which ultimately received their
reports and determined their progress or dismissal from the establishment.

It beggars belief that given such facts (and more), which were made availed both in testimony and with
written evidence to SSNIT, you concluded that these were not employees. It didn’t even register that this
conclusion was anomalous after the Church admitted that our clients were employees at “various times” but
ceased to be employees at other times in between! How bizzare? All this was believed by SSNIT even
though the establishment was not able to produce evidence of termination of the original employment or
evidence that these employees had taken up other employment anywhere else.

ESTABLISHED LEGAL PRINCIPLES

We are of the considered opinion that whiles investigating this matter, you should have applied the proven
legal tests for determining who is an employee, these tests include:
• THE CONTROL TEST
– to what extent a person’s work schedule is controlled by the employer
• THE INTEGRATION TEST
– to what extent the work was an a recognised part of the whole of the functions of the organisation.
• EQUIPMENT TEST
– whether the equipment and tools for performing the work are provided by the employer or not
• THE CONTRACT FOR SERVICES OR CONTRACT OF SERVICE TEST
– whether the person is a contract employee or a regular employee
• THE PRESUMPTION OF EMPLOYMENT PRINCIPLE
– which puts the burden of proof on the employer NOT the employee.
• THE “RES IPSA LOQUITUR” RULE IN EVIDENCE LAW – which sums up a matter with the phrase
“The Matter Speaks for itself”.
In the extant case each of these tests is more likely to lead to a decision that. Our clients were employees
than otherwise, we explain below:
• The Control Test
We will show subsequently as we explained copiously in the meetings and with documented
evidence to SSNIT that every aspect of the work of our clients was controlled by the church,
Founding Bishop, and senior Bishops. This control was so close and so pervasive that some people
have accused the church of being a cult or being Cult-Like.

• The Integration Test

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 The work of all our clients were closely integrated and central to the church. These were
missionaries in a church which emphasised Missions above anything else (maybe except
obsequious loyalty). The details were explained to SSNIT ans are partly set out herein.

• Equipment Test
All equipment and facilities used by our clients in the performance of their work were provided by
the church. Indeed even when our clients made substantial contributions to the purchasing of
equipment or even building church halls or schools, the church took them over. Our clients were
not visiting preachers, they were resident missionaries who were transferred from their normal
abodes to faraway places with the sole aim of planting and pastoring Lighthouse International
churches. This is what they did consistently for between 6 to 20 years as full time missionaries of
the church.

• The Contract for Services or Contract of Service Test

Our clients were not evangelists who went from place to place or church to church preaching and
leaving. They were not contract or short-term employees whose services had been contracted for a
specified period. None of them had a terminable contract with a predetermined end. Each of them
were engaged under a contract of Service on a continuous basis. This Contract of Service meant
they were employee and not contract workers.

• The Presumption of Employment Principle

A person is presumed by law to be an employee once they work continuously for 6 months or for a
number of days making up 6 months of work within a year. This presumption makes it mandatory
for every establishment to issue the worker a contract of employment spelling our the terms of their
employment. The legal rule also flips the burden of proof from the employee to the employer, so
that instead of the employee proving that he is an employee, once he works beyond the 6 month
period, it is the employer who has to show that a person who has worked for that period is NOT an
employee. He has to show a termination letter or a contract which specifies the persons terms for
which he has worked for over 6 months.
Our clients worked from 6 to 20 years continuously for the Lighthouse Church. By law they were
presumed to be employees. They also showed various evidence to that effect. SSNIT should have
applied this rule and made the church prove that they terminated the employment or otherwise of
our clients. The church could not show any such evidence except to say that they were volunteers,
a term which is not known or used in any of the church’s HR manuals. Even if they were volunteers,
the presumption of employment converts them to employees unless there is a contract to the
contrary. How SSNIT managed to ignore this principle is a mystery to us.

The “Res Ipsa Loquitur” Rule

‘The Res Ipsa Loquitur’ (The thing speaks for itself) rule is used in Evidence Law, especially with
regards to the Tort of negligence.
The rule however can be applied whenever a matter by its obvious manifestation is so glaring or
notorious that any further request for evidence becomes absurd. In the present matter regarding our
clients, this rule squarely applies.

How is it that 6 gentlemen who are well educated, many with university degrees, who as adults
were engaged by a church, and used in the work of the church for 6 to 20 years continuously, with
the church exercising control over every aspect of their work, transferring them locally and
internationally, under the conditions that have been described in this letter, are asked to prove that
they were workers for the church??? When the laws and legal principles provide clearly that the
proof must come from the employer to negate their claim??

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 How is it that the demand for evidence comes from the specific institution which is charged with
the function of identifying employers who flout the Social Security and Pensions Laws, an institution
endowed with more financial resources than any in Ghana, and for whom specific laws have been
passed to ensure they are effective in this effort, and for whom many other resources have been
given to actually go out and investigate establishments, and bring them to book if they flout the law,
or help them to be compliant with the law, is the one asking these long term workers to provide
evidence that they are employees??

The obvious facts of this case are sufficient to proceed on. If the officers of SSNIT do not see the
obvious, it cannot be because they do not see, it is more likely to be because they do not wish to
see!!
This is a matter where the Res Ipsa Loquitur rule fits perfectly. The matter speaks loudly for itself that
given the experience and facts surrounding the issues brought by these gentlemen, if SSNIT does
not appreciate the obvious facts and that the matter speaks for itself, then SSNIT cannot claim any
competence in the areas of its operation especially regarding the management of pensions and
ensuring that everyone is contributing.
The request by SSNIT for further evidence was indeed misplaced. SSNIT clearly showed no passion
or interest in getting to the facts of this matter, the result is what we are questioning. Without any
further evidence this matter could have been resolved in line with law, yet our clients provided a
lot of evidence and still SSNIT concluded that. They were not employees.

EVIDENCE WAS PROVIDED

Contrary to your assertion, and in addition to the above, our clients provided you scores of documents and
emails showing correspondence between them and their employer, etc. They explained in detail the nature
of their engagement with the church. They explained how funds moved from Ghana to other branches
where needed, to pay salaries and for projects, and from overseas branches to others for projects and various
reasons. They gave evidence of significant control.
Our clients showed you scores of documents, including a Visa the church had obtained for one of them
stating that he was on an ‘INTRA Company’ transfer, plus various correspondences, certificates etc to prove
that they had been in employment with the church for years. They showed evidence of the church exercising
powers of transfer, executing plans and modifying operations, all acts which prove that they are an
employer, in accordance with section 8 of Act 651.
Indeed, the church admitted to SSNIT that they were in their employ, (at least at various times), the church
however decided to classify them in a different employment capacity of “volunteers” which is not
recognised by the labour law, and not mentioned in the church’s Human Resource Manual.
In the church’s wrong opinion, by being volunteers, our clients were not entitled to a salary, based on which
social security contributions would mandatorily be payable by them. You should have educated them on
this error but you acquiesced, and thereby you have sent a signal that all employers can get away with not
paying contributions as long as they classify employees as non employees or as they wish.
VARIOUS FACTS MADE AVAILABLE
our clients gave many pieces of information which were legally significant, we find it strange that these
were ignored, and rather you elected to admit weaker inferences to defeat actual facts.

1. We supplied information about how Lighthouse Chapel refused to give employment contracts to staff,
and you agreed with our counsel that the conduct of the parties will be sufficient to infer an employment
contract. How come you didn’t make that inference despite the glaring facts. Indeed the church violated
the law by refusing to provide employment contracts as required by law. We are not sure how you
reacted to that glaring breach of law.

2. We emphatically informed you that our employment(s) was not terminated at any time, (indeed there
was one termination and re-instatement. which we informed you of), and asked that you demand
termination evidence from the church. We have not seen a single evidence of termination, so how did
you conclude that our clients ceased to be employees at various times. That is quite bizarre and throws
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 a lot of confusion around. Are you implying that any staff who is transferred or seconded, could be said
to have lost their employment? SSNIT needs to clarify this.

3. The church submitted that it had changed its operational model and introduced a new (and very
convoluted) system which most members and clergy reportedly do not understand. Our clients
explained that although they did not understand the new system fully, they knew they were employees
of the original Lighthouse Chapel International and that had not changed. They were transferred
between the branches but remained employed by the original establishment.
By law it was the church’s duty to explain these developments and changes and to explain how every
employee stood, noting that it is unlawful to vary an employee’s benefits downwards under any such
changes, more-so cancelling their employment status. No internal reorganisation leads to termination
of employment. If that is contemplated, Redundancy under Law (Act 651) will be triggered and a whole
different issue arises. How did SSNIT skip over all these and make its determination?

4. SSNIT was informed about how our clients were obligated to bank, transfer or utilise funds generated
from their workplaces under the instruction, direction, and strict control from headquarters or a
designated officer.

5. SSNIT was informed of how funds were moved from different locations in the church to other locations
for various projects, and salaries and other purposes. SSNIT was informed of how interdependent the
churches were under the leadership of the Accra Headquarters, and some details showed in emails and
other correspondence.

6. SSNIT was informed of how instructions from the church’s “Central Intelligence Office” was carried
out to the effect that the church’s policy that all missions which were not financially self-sustaining after
2 years of operation and receiving support would be transitioned and consequently the serving full-
time missionary would have to transition to lay ministry? Our clients survived these draconian policies
and remained as full-time ministers, yet SSNIT accepts when the church changes its story and says some
of these persons were volunteers all along.

7. It is surprising that although our clients showed evidence of remuneration including provision of cars
and other allowances, SSNIT refuses to see that these constituted Salaries and emoluments pursuant to
an employment relationship. How did SSNIT understand these emoluments and under what conditions
and basis were they being paid?

8. SSNIT was informed that the church had a habit of withdrawing written documentation, so even
payslips were not given except under special circumstances. SSNIT still ignored these and demanded
payslips. In any case evidence of payment of emoluments can be obtained from other sources, some of
which was made available to SSNIT.
9. SSNIT was told of how in some circumstances the church paid for repatriation expenses to attend
church meetings far and near or for transfers. The church covered travelling and accommodation
expenses for our clients and their spouses and managed them as transferred employees, yet in some
cases others were discriminated against and although they had also been transferred like other
missionaries they were discriminated against and left to struggle. These showed an uneven treatment
of employees and breached the law regarding equal pay for equal work and the principles of equity
and fairness. Why were some treated as employees and others not?

10. SSNIT was told of instances when the church required heads of missions to see to the payment of SSNIT
contributions and even communicated the need for timely fulfilment of statutory payments like SSNIT
and IRS. How does this sit with the same church saying some of these persons who were required to
organise their SSNIT payments were volunteers?

EFFECT OF TRANSFER/SECONDMENT
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In your letter to our clients you made the point inter-alia that the church admitted their employee status at
various times (and paid SSNIT for those times), but you were not able to establish an employment relation
at the other times especially when they had been sent on missions elsewhere.

It is clear that you elected to accept the church’s side of the story without any examination. The first relevant
question would have given you the right answer. It would have been to check if the church terminated the
employment of the employee before the transfer or at any time after.
Even if you forgot, we reminded you in our meeting of 2nd June 2021, that you needed to check because
there was no termination of employment and none of the missions stations our clients were sent to entered
an employment relation with them.

In trying to convince us that each mission station was autonomous, you produced a draft of an employment
letter which was not signed by our client, and suggested to us that it was evidence that the foreign mission
had employed him (after the transfer). We pointed out to you that it was not signed and was not authentic
because the person in question spent more than 5 years at that station and never entered a new contract of
employment. You agreed with our point, yet still went ahead and concluded that the employment
relationship was dissolved between the employee and the Lighthouse Church simply because of the transfer.
We deem it apposite to bring to your notice that Transfers or Secondments from one establishment to another
do not in any way terminate the original employment relationship.

There’s a lot of case law supporting this proposition.

In the case of Kankaadi v B.I.O Ltd. [1975] 2 GLR 452, a driver was held to be the employee of the original
employer, not the persons who hired the employer’s truck, although he has been sent there to work with
them as part of their operation and they controlled many aspects of his work.
The principle is that sending someone to work for another (e.g., secondment or transfer) does not break the
original employment relationship.

In Mersey Docks & Harbour Board v. Coggins & Griffiths (Liverpool) Ltd. [1947], it was held in the Appeal
that "That the crane driver was in general the servant of the appellant board is indisputable. The appellant
board engaged him, paid him, prescribed the jobs he should undertake and alone could dismiss him." The
person hiring the crane had some control, but the real control was with Mersey Docks. The ultimate control
is the right to dismiss. A servant is one who is subject to the orders and control of an employer .... whether
or not the persons are running their own business.

The application of this in our context is to the effect that none of the missions our clients were posted to,
whether local or international could dismiss them, they could only be dismissed by Accra, Headquarters of
Lighthouse Chapel International.

In Performing Rights Society v Mitchell & Booker (Palais de Danse) Ltd. (1924) 1 KB 762 , it was held that
Bandsmen were employees of the establishment they worked for because they were controlled and were
told the nights they had to play, the hours they had to play and what song to play. They had little discretion
to how they did the job because they were employees.

Our clients were controlled in every aspect of their work as Pastors and missionaries indeed the control was
so intense it has been described by some as ’Cult-like’.
This is a church where even Bishops were sometimes instructed to preach from the books of Bishop Dag
and not directly from the Bible, the only church where people were made to practice deep kissing in church,
against all established Bible norms on chastity before marriage, where people were restricted in their
fellowship with other Christians, and were nurtured to imbibe the church’s own extreme doctrines on
‘Loyalty’ and other such things. The control of the church over its clergy including our clients was total. All
these were explained yet you concluded that there was no employment relationship.

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As an employer, Lighthouse over asserted its rights as an employer (to control and organise work) in
accordance with section 8(b) of Act 651 by providing the pastors devices preloaded with the founder’s books
and other materials to preach from.
How is it that after exerting such control, SSNIT allows the church to claim that its clergy were not
employees?

MODERN STRETCHES OF PRINCIPLES ESTABLISHING EMPLOYEE STATUS

In recent times these time tested principles have been stretched to cover even persons who work at their
own time with their own resources such as Uber drivers.

in Uber BV v Aslam [2021] UKSC 5,

“the Supreme Court held unanimously that the Employment Tribunal had been correct, and that the
drivers for Uber were "workers", entitled at least to the minimum wage and paid holidays, calculated from
the time that they log onto the Uber app.
This is a strained application of the established laws, but it shows clearly how far these principles can be
stretched. It therefore is not mildly surprising that where the facts were so stark and fitted the principles,
SSNIT will arrive at the conclusion that our clients were not employees, in total variance with the established
rules.

CONDUCT ESTABLISHES CONTRACT

The points made above are to establish the fact that there was an employment relationship between the
parties no matter how strenuously anyone tries to erase it.
All good lawyers know that a contract can be established impliedly from the conduct of parties and/or
expressly, the same could be oral or written. It is the existence of certain facts or elements that confirms the
existence of a contract of employment, in this case between the church and its pastors.

IMPLIED UNDUE INFLUENCE

The only aspect of this implied, unwritten contract of employment which needs scrutiny is whether the
principle of ‘Implied Undue Influence’ is applicable. This principle serves to save people who enter contracts
against their self-interest as a result of the undue influence of their Bishops and Spiritual influencers. This is
a pertinent matter which will be dealt with in court not at SSNIT. Its determination will not erase or annul
the employment contract if it has already been concluded, but will ascertain if one party was cheated or has
benefitted from the lopsided contract at the expense of another and Order compensation to be paid to the
weaker or cheated party. So even if this contract was illegally or immorally entered, it will be upheld in all
its valid aspects.

BREACH OF RULES ON DOCUMENTATION

There is a duty imposed on SSNIT as the “examiner” under section 184 (1) of Act 766, by which SSNIT
should have informed the church that failure to give written contracts and ensure proper record keeping as
required by law constitute gross dereliction of duty and violations of law, and that organisations which
deliberately seek to avoid record keeping are seen as potentially unlawful entities involved in illegal activity
and seeking to avoid liability? Somehow SSNIT. Fails in this duty also and goes further to accept the narration
of the erring entity without any supporting evidence.

THE MATTERS DON’T END AT SSNIT

The importance of this matter goes beyond this specific case. The full determination of all issues in this
matter will help solve many other issues raging in many other churches and workplaces.
We are therefore glad that these issues are already before a court, and we will be re-presenting these
evidence in court.
If it becomes necessary, we will subpoena the church’s bank records to prove our case in court. We are
assured that when all the facts are considered and the law is applied, our clients status as employees will
be upheld.

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If SSNIT was not sure of its position, maybe you should have waited for the court to rule before making
your conclusions. We did not have that option because we are obliged to report infractions of the Pensions
Act and bring the matter to SSNITs notice for quick treatment.
SSNIT DEFEATED ITS OWN MANDATE
We would like to submit to your good selves that failure to conduct an exhaustive investigation constitutes
a breach of Section 184 of the Pensions Act 2008 (Act 766).
This decision by SSNIT has thrown out a lot of confusion and in our view SSNIT has defeated its own
mandate and cast doubt on its purpose.
By agreeing with the Lighthouse church under such circumstances, SSNIT looks like an institution Aiding
and abetting lighthouse to flout the Pensions and related laws.
The confusion thrown out will cause many Pastors and church workers especially those in Lighthouse to
wonder what their statuses are.
If SSNIT fails refuses or neglects to correct the error inherent in this decision, it will weakened its own moral
standing, legal mandate and operational effectiveness going forward.
By your decision, You have opened a door for employers to dodge the payment of SSNIT contributions by
not giving employment contracts. You have also sent the signal that when employers are challenged you
will ask the employees to produce copious evidence, failing which you will not assert the laws made to
defend them.
SSNIT has also sent a signal that secondments and transfers could constitute a termination of employment.

We are quite sure not all these effects were intended, but by that one decision, SSNIT has put many issues
in play. We hope by the time the dust settles, we will all be clear which way to go regarding SSNIT
contributions and the real meaning of the applicable laws.

Regards

Kofi Bentil
For an on behalf of
Larry Odonkor
Edward Laryea
Faith Fiakojo
Edem Amankwah
Emmanuel Oko Mensah
Seth Duncan.