Mr. Ebenezer Adjirakor
The Chief Director
Ministry of Trade and Development
91 Starlets Road
Accra – Ghana

7th June, 2018

Dear Mr. Ebenezer Adjirakor,

REQUEST FOR INFORMATION RE. UNI-PASS, GCNet, WEST BLUE

In March 2018, Ghana Link network Services Limited, in collaboration with Customs UNI-PASS International Agency (CUPIA) of Korea Customs Services, were contracted by the Ministry of Trade and Industry to introduce UNI-PASS to the ports system.

IMANI has been studying the port systems, specifically the paperless port process, and would like to understand the implications of adopting UNI-PASS on the turnaround times and the costs. We write to request an interview with your institution regarding the above topic.

Itemised below are sample questions for discussion:

1. According to the Ministry of Trade and Industry (MoTI), the introduction of UNI-PASS is expected to make the GNSW more comprehensive. In addition, the UNI-PASS system will include a clearance management system, a cargo management system, an information management system and an administration system.

2. Are all these functions missing from the existing systems (GCNet and West Blue platforms)? How easily can they be added to the existing system and at what cost?

3. The 2018 World Bank Doing Business index indicates that Ghana ranked 158 out of 190 countries in the trading across borders indicator, a four-point drop from 2017 rankings. How does the UNI-PASS system enhance trade facilitation in terms of the Cargo Dwell Times?

4. How much percentage wise, are revenues likely to increase from the existing situation with the new system? Will this be large enough to offset the potential lost revenue from government shareholding in GCNet?

5. The GCNet contract ends in 2023 while the West Blue contract expires in 2020. This means that there are still about 5 and 2 more years, respectively, for them to operate the single window system.
a.Is the government going to abrogate these contracts and at what cost?
b. If government does not intend to abrogate these contracts, how will all three companies operate on the single window platform? c.What is the implication for trade facilitation?
d.What will the transition look like and what consequences will it have for trade facilitation and revenue mobilisation?

6.What motivated MoTI’s decision to procure a new system instead of strengthening existing systems?

7. Will the introduction of UNI-PASS complete the Ghana National Single Window (GNSW) programme?

8.How essentially different is the Ghana Integrated Cargo Clearance System (GICCS), the Ghana Customs Management System (GCMS) on GCNet platform and the Pre-Arrival Assessment Reporting System (PAARS), the Customs House Agents Management System (CHAMS), the Joint Inspection Management Information System (JIMIS) and the Risk Management System (RMS) on the Westblue Platform on one hand to what has been proposed in the UNIPASS?

9.Separate reports have stated that GCNet charge importers a fee of 0.4% on FOB, while West Blue are alleged to charge between 0.28% and 1% for CIF. What are the current fees of GCNet and WestBlue? How do they compare with that of UNI-PASS?

10.What review processes has the Ministry of Trade carried out recently (can evidence be adduced) to justify the signing of this agreement?

11.Can MoTI share the results of the feasibility studies (2015) on the ports, conducted by CUPIA of Korea Customs Services and Ghana Link Network Services?

12. The Customs (Amendment) Act, 2016 (Act 923) amending the Principal Act clearly points the direction of where the National Single Window is ESTABLISHED, effectively curing all elements of doubt that might have lingered on in the past as to ownership of the project. With this knowledge, why is the Trade Ministry signing agreements on this subject when a sub section of the quoted Act clearly states the Ghana Revenue Authority (GRA) as the one to manage the National Single Window System?

13. What is the nature of the contract between MOTI and Ghana Link Network Services Limited? Who bears the cost of training, change management and integration?

14. In the knowledge of the Trade Facilitation Agreement that Ghana just ratified, specifically to the Article on the Disciplines on Fees and Charges, Ghana has given notification as to the number of years needed to regularize our fees and charges regime to reflect that of the WTO-TFA, why would a leading Ministry in this discussion sign a 10 year contract whose fee structure (advalorem) contravenes the stipulations of The Agreement?

15. Has there been an update on the initial review on the paperless port processes? What are the successes and challenges?

We are grateful for your attention to this matter and look forward to receiving your response within a week from the day of delivery by courier. This will also be sent electronically on June 7, 2018.

Yours sincerely,

Franklin Cudjoe
(Founding President)

H.E. Dr. Mahamudu Bawumia
The Vice President
Office of the Vice President

Mr. Isaac Crentsil
Commissioner – Customs Division
Ghana Revenue Authority
Mrs. Akosua Frema-Opare
Chief of Staff
Office of the President

Mr. Richard Patrick Yawutse
Deputy Commissioner
Policy and Programs Division
Ghana Revenue Authority

Hon. Alan J. K. Kyerematen
The Minister
Ministry of Trade and Industry

Mr. Alan Adjirakor
Executive Chairman
Ghana Community Network
Hon. Carlos Kingsley Ahenkorah
Deputy Minister
Ministry of Trade and Industry

Ms. Valentina Mintah
Chief Executive Officer
West Blue Consulting Ghana

Hon. Robert Ahomka Lindsay
Deputy Minister
Ministry of Trade and Industry

Dr. Yaw Adu-Gyamfi
President
Association of Ghana Industries
Hon. Ken Ofori-Atta
The Minister
Ministry of Finance and Economic Planning

Chief Executive Director
Ghana Link Network Services.
The Economic Management Team
Jubilee House

Mr. Kwabena Ofosu-Appiah
President
Ghana Institute of Freight Forwarders

Hon. Marfo Nana Amaniampong
The Chairman
Trade, Industry and Tourism Committee
Parliament of Ghana.

Mr. Samson Asaki
Executive Secretary
Importers and Exporters Association
Hon. Osei Kyei-Mensa Bonsu
Majority Leader
Parliament of Ghana

Mr. Yofi Grant
Chief Executive Officer
Ghana Investment Promotion Centre
Hon. Haruna Iddrisu
Minority Learder
Parliament of Ghana

Mr. Edward kofi Osei
Director of Port – Tema
Ghana Ports and Harbours Authority.
Also copied in this letter are the following individuals and institutions: