When President John Dramani Mahama launched the Code of Conduct and Ethics for all Political Appointees in May 2025, many welcomed it as a step towards addressing longstanding concerns about discipline, integrity and accountability in public office.
The document addressed several concerns that had long troubled public office in Ghana, from conflicts of interest and the misuse of public resources to questions of professionalism, accountability and the proper conduct of public officials.
Concerns emerged, however, about its legal foundation. Would a document introduced by the President provide sufficient and lasting accountability, or was a more comprehensive statutory framework needed to make ethical standards binding beyond the tenure of one administration? The Ghana Anti-Corruption Coalition and the Ghana Integrity Initiative were among the organisations that drew attention to the need for the Conduct of Public Officers Bill to be enacted into law.
More than a year after its launch, that question deserves renewed attention. Recent developments at the Ghana Tourism Authority (GTA), involving its Chief Executive Officer, Maame Efua Houadjeto, and Deputy Chief Executive Officer in charge of Marketing and Special Duties, Gilbert Abeiku Aggrey, present an opportunity to examine the Code against the realities of public administration.
A Communication Gap at the GTA
On 22 October 2026, Mr Aggrey wrote to the Minister for Tourism, Culture and Creative Arts, Abla Dzifa Gomashie, seeking her intervention over what he described as difficulties in securing timely access to the GTA’s Chief Executive Officer for official consultations.
According to the Deputy CEO, repeated attempts to arrange meetings through the CEO’s secretary or personal assistant had been unsuccessful, with his requests met with indications that she was unavailable. He said these difficulties had affected his ability to obtain timely guidance, approvals and decisions on urgent operational matters.
The consequences, he maintained, extended to delays in operations, stakeholder engagements and the implementation of assignments under his responsibility, including domestic tourism, special events and marketing. He therefore asked the Minister, with the knowledge of the GTA Board Chairperson, to establish a more effective arrangement for communication and consultations between the two offices.
Two days later, the CEO responded in a letter addressed to the Chairperson of the GTA Board of Directors. She expressed surprise and disappointment at the Deputy CEO’s account, maintaining that her office operated an open-door policy, particularly for executive and senior management officers. She acknowledged the importance of effective communication and timely decision-making but disputed the suggestion that her availability to the Deputy CEO had been inadequate.
Her response proposed practical measures to improve coordination. These included scheduled executive consultations, a procedure for escalating urgent matters, better coordination of meeting requests, clearer delegation of responsibilities and approval processes, and regular management meetings. She expressed the hope that an early meeting between the two offices would produce workable arrangements and allow management to continue pursuing the Authority’s objectives collaboratively.
Both officials recognise the importance of communication and coordination to the effective functioning of the GTA. Their disagreement concerns whether the existing arrangements have been adequate and what needs to be done to improve them. Although the correspondence does not establish wrongdoing by either official, it raises legitimate questions about the Authority’s internal coordination and the standards expected of those entrusted with public office.
What Does the Code Require?
The Code expressly brings Chief Executive Officers and Deputy Chief Executive Officers of state and para-statal institutions within its scope. The ethical standards it establishes therefore apply to officials occupying positions such as those held by the two GTA executives.
The Code expects political appointees to demonstrate integrity, respect, accountability and professionalism in their official dealings. It also emphasises honesty, constructive criticism, courtesy and the treatment of colleagues with dignity and fairness. Public officials are expected to act in the public interest, perform their duties diligently and make themselves as accessible as possible to those who need to consult them.
These expectations are relevant to the dispute. If an official responsible for important operational functions repeatedly cannot obtain timely decisions or guidance from the chief executive, and this causes delays in official work, questions arise about whether the institution’s leadership arrangements reflect the Code’s emphasis on accessibility, diligence and productivity.
But the distinction between a concern and a breach is important. The Code cannot reasonably be read as requiring a chief executive to be available at every moment or to grant every meeting request immediately. Availability must be assessed in context, taking account of the demands of the office, the urgency of the matter and the arrangements for handling requests that cannot be accommodated immediately.
Equally, the CEO’s assertion that her office operates an open-door policy does not, by itself, resolve the Deputy CEO’s complaint. The relevant question is whether the arrangements in practice permit the timely handling of official matters.
The Code should not become an instrument for assigning blame simply because two officials disagree. Its value lies in providing standards against which their actual conduct can be fairly assessed. The facts must be established before any conclusion is reached about whether either official has fallen short of those standards.
The Question of Enforcement
The concern about enforcement was present from the beginning. At the launch of the Code, President Mahama described it as a living and enforceable framework rather than a ceremonial document. The Code also contains a mechanism for dealing with suspected breaches.
Under its enforcement provisions, where a Minister engages in conduct that prima facie constitutes a breach of the Code, the President determines, at his discretion, the appropriate course of action. Possible measures include requiring an apology, which may be public, issuing a formal reprimand, requesting the official’s resignation, suspending the official or terminating the appointment.
There remains, however, a broader legal question. A presidential code of conduct is not the same as a comprehensive statute enacted by Parliament. Although the Code provides for executive action, a statutory framework could establish more enduring obligations, procedures and accountability arrangements that are less dependent on the approach of an individual administration.
In the GTA matter, the existence of the correspondence alone does not justify a finding of misconduct or a demand for sanctions. The appropriate first step is to establish what occurred and assess the conduct of the officials against the standards the Code sets out. If the facts disclose conduct that prima facie breaches the Code, the question of enforcement should not be avoided simply because the officials involved occupy senior positions. Equally, the Code should not be used to punish an official merely for raising a genuine administrative concern through appropriate channels.
Will the whip be cracked? That question can only be answered after the facts have been properly examined. What should not be in doubt is that the standards set out in the Code must mean something when they are tested in practice.
Beyond a Beautiful Promise on Paper
The disagreement at the Ghana Tourism Authority may be resolved through the measures proposed by its CEO. The two offices may establish a workable arrangement for consultations, clarify their respective responsibilities and move forward without further difficulty. That would be a welcome outcome, but the wider questions raised by the episode should not be lost in the search for an immediate resolution.
The Code of Conduct was introduced in response to concerns about discipline, integrity and accountability in public office. Its significance will ultimately depend on whether its standards shape the conduct of public officials and whether established breaches attract an appropriate response.
This does not mean that every administrative disagreement should become a disciplinary case. It means that complaints must be taken seriously, facts must be established fairly and any breach that is demonstrated must be addressed through the appropriate process.
The government must also continue to address the broader question of a durable legal framework for public officers, so that ethical standards and accountability do not depend entirely on the resolve of one President or the lifespan of one administration.
