Conflicts of interest pose significant ethical and legal threats to governance, undermining public trust, accountability, and institutional integrity.

The recent appointment of Anthony Sarpong, Senior Partner at KPMG Ghana, as Acting Commissioner-General (C-G) of the Ghana Revenue Authority (GRA) has raised profound concerns.

Given his entrenched professional and financial ties to KPMG, Mr. Sarpong’s appointment creates a situation rife with potential conflicts of interest that challenge the impartiality
and credibility of GRA’s operations.

This article examines these concerns in the context of relevant Ghanaian statutes and ethical guidelines, while presenting a compelling case for the revocation of Mr. Sarpong’s appointment.

Ethical and Legal Concerns

1. Dual Allegiance: Financial Stake in KPMG As a Senior Partner at KPMG Ghana, Mr. Sarpong likely retains a financial interest in the firm. According to Ghana’s Public Procurement Act, 2003 (Act 663) and the Public Financial Management Act, 2016 (Act 921), public officials are required to avoid conflicts of interest that may impair their impartiality or fiduciary responsibilities. KPMG’s long standing contractual relationship with GRA—including managing recruitment and providing audit services—directly conflicts with Mr. Sarpong’s fiduciary duties as Acting C-G. His dual role inherently compromises the objectivity required to safeguard GRA’s financial and operational integrity.

2. Conflict in Recruitment Contracts: KPMG’s role in managing GRA’s recruitment despite GRA’s own Human Resources Department has sparked staff dissatisfaction. This outsourcing
   arrangement raises legitimate concerns about transparency and fairness. As Acting C-G, Mr. Sarpong’s ability to impartially assess the continuation of KPMG’s recruitment contract is
   compromised, as terminating such contracts could affect his financial interests at KPMG. Such a scenario undermines both Article 286 of the 1992 Constitution, which addresses
   conflicts of interest, and GRA’s obligation to uphold meritocracy in public sector employment.
3. Audit of Strategic Mobilization Ghana Ltd (SML): In 2024, KPMG conducted an audit of SML on behalf of the government, recommending the termination of SML’s contract with GRA due
   to procedural irregularities. With Mr. Sarpong now at the helm of GRA, his ability to oversee or implement further audits of SML is fraught with potential bias. His prior involvement through KPMG creates a scenario in which his decisions may be perceived as self-serving, thereby violating Section 175 of the Companies Act, 2019 (Act 992), which emphasizes the duty to
   avoid conflicts in positions of fiduciary responsibility.
4. KPMG’s Tax Advisory Services: KPMG’s provision of tax advisory services to clients :some of whom may be in disputes with GRA—creates a fundamental conflict with GRA’s mandate to
   enforce tax laws impartially. Under Section 9 of the Revenue Administration Act, 2016 (Act 915), the Commissioner-General is responsible for enforcing tax compliance without favoritism. Mr. Sarpong’s dual role risks compromising public confidence in GRA’s ability to act without undue influence.
5. Erosion of Staff Morale and Public Confidence: The dominance of KPMG in GRA’s operations has already diminished staff morale. Mr. Sarpong’s appointment exacerbates these tensions,
   signaling further entrenchment of KPMG’s influence within the organization. Such developments threaten to erode public trust in GRA, a critical institution tasked with ensuring
   equitable revenue collection for national development.
6. Implications of Hypothetical Resignation from KPMG: Even if Mr. Sarpong were to resign from his position as Senior Partner at KPMG, the conflicts of interest would persist. His prior association with KPMG and potential residual financial benefits, such as profit-sharing or retirement entitlements, would continue to compromise his impartiality.

Additionally, his recent leadership role at KPMG raises concerns about undue influence over decisions involving the firm, especially given its extensive contractual engagements with GRA. These lingering ties undermine the appearance and reality of unbiased governance, reinforcing the need for his appointment to be revoked.

KPMG’s Internal Policies on Conflict of Interest

KPMG International’s Code of Conduct explicitly prohibits senior partners from accepting roles that could compromise the firm’s integrity or create conflicts of interest. This policy is aligned with global best practices for maintaining professional independence and mitigating reputational risks. Mr. Sarpong’s appointment potentially contravenes these internal guidelines, as his dual roles blur the boundaries between public service and private interests.

Existing Contracts Between KPMG and GRA

Public records and disclosures indicate that KPMG has provided a range of services to GRA,
including:

● Recruitment management contracts.

● Auditing services for third-party contractors such as SML.

● Advisory services related to financial operations and tax compliance.

The continuation of these contracts under Mr. Sarpong’s leadership represents a clear conflict of interest, necessitating a thorough review by independent authorities.

1. Immediate Revocation of Appointment: To uphold the integrity of GRA and reinforce public trust, Mr. Sarpong’s appointment should be revoked immediately. This aligns with Article 296 of the Constitution, which mandates fairness and impartiality in public appointments.

2. Independent Audit of GRA-KPMG Contracts: An independent audit should be conducted to evaluate the necessity and impact of KPMG’s involvement in GRA operations. This would
   ensure compliance with the Public Financial Management Act, 2016 (Act 921), and promote accountability.

3.Appointment of Independent Leadership: The government must prioritize appointing individuals without financial or professional ties to entities contracting with GRA. This will restore impartiality and reinforce GRA’s credibility.

Conclusion

The appointment of Anthony Sarpong as Acting Commissioner-General of GRA exemplifies a conflict of interest that undermines the institution’s credibility and operational integrity.

His dual role violates ethical principles, statutory provisions, and professional guidelines. Even in the event of his resignation from KPMG, lingering conflicts of interest and perceptions of undue influence would remain.

For the sake of transparency, accountability, and public confidence, the revocation of his appointment is not only justified but necessary to safeguard the interests of Ghana’s revenue
authority and the public it serves.