Report on Ghana EITI Oil & Gas Commodity Trading Pilot

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This report encompasses the findings and recommendations of Ghana’s Commodity Trading Pilot Programme. Ghana is one of five countries involved in the EITI pilot project on commodity trading.

• It is possible to produce a commodity trading report for oil sales in Ghana that contains reconciled data from both GNPC as the seller and the buyers for the period 1 January 2015 to 31 December 2017.
• There is a high level of correlation between the data received from GNPC, the buyers, GRA, and Bank of Ghana. We identified seven discrepancies in the data as originally submitted, all minor and none material to the overall accuracy of the data. Only three discrepancies remain where the supplier of the inconsistent data has not provided a correction or explanation. From the high level of correlation of the data, we conclude there are no systematic issues with the collection and reporting of data on GNPC oil sales.
• The governance arrangements concerning GNPC’s oil sales are good but there is scope for improvement to anticipate future growth in production volumes. There is a clear legal basis for GNPC’s activities and for the roles of other institutions in the process. There is also a clear legal framework for governing the flow of revenues received.
• GNPC has a clear buyer selection process with pre-qualification criteria for scoring each potential buyer to ensure only high-quality buyers participate in the sales process.
• We recommend that GHEITI produce a plan as soon as practicable for regular reporting of reconciled oil and gas sales data for Ghana’s in-kind share. The report should occur at least annually and should commence with reporting 2018 data before mid-2019. This plan should set out a realistic timetable for collecting the data, the reconciliation process and report production along with clear responsibilities. The plan should also set out the resources and budget required to implement this level of reporting.
• GHEITI should find an existing reporting process that can incorporate data on the sale of Ghana’s in-kind share of oil and gas production.
• Any expansion of the scope of commodity trading reporting should be carefully planned before implementation. Also, any expansion should be conducted in stages so that lessons can be learned and appropriate amendments made at each stage.