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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 Ghanas Tourism Industry in general and on behalf of theGhana 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 onthe 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 objectof the Tourism Bill must be to establish the National Tourism Authority as a Public-Private 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 NationalTourism Authority Billand not Tourism Bill;

5. Marketing and Promotion must be a primordial function of the National Tourism authority butnot a subsidiary object of the Authority;

6. Reference to gender balance in Clause 5(1)(c) is discriminatory by referring only to the PrivateSector 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 manipulatethe 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 makesredundant the management of the Authority;

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10.Regional and District Offices of the Authority are in addition a bureaucratic replication of chainsof 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 ofaccountability;

12.GHATOFs recommendation to publish the Annual Report of the Authority to stakeholders forthe purposes of accountability;

13.The Tourism Development Fund must be established by a different Act and not housed underthe NATIONAL TOURISM AUTHORITY Bill;

14.The Tourism Development Fund with a Bank Account under the authority of the AccountantGeneral (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 aFund Committee and another Board appointed by the President;

16.The administration of the Tourism Development Fund is to be vested in the expertise of aFundAdministratoras 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 Managerwith no direct business linkage with theNational Tourism Authority to manage the finances of the Fund;

18.An External Auditorbeing a competent Private Auditing Firm to oversee the accountability ofthe 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.

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 Bill2. Ghana Tourism Authority and Ghana Tourism Fund Final Report of the Joint Policy and Finance

Workgroup