The 2025 Ministerial Code of Conduct was introduced with the promise of restoring integrity to public office. Framed as a bold step toward transparent and ethical leadership, the Code was expected to set a new standard in Ghanaian governance. But a close analysis reveals something less reassuring: a framework that permits influence to flow—legally and quietly—in increments of GH₵20,000 at a time.

According to Section 1.5.12 of the Code, Ministers and political appointees may retain gifts valued up to GH₵20,000 (approximately $1,480) without any obligation to declare them. There is no requirement to disclose the source of the gift, no independent valuation mechanism and no cap on the number of such gifts an official may receive within a given period. In effect, this creates a legal channel for repeated, unregulated material influence.

The Code also fails to prohibit or even restrict gifts from private individuals or politically exposed persons. With no safeguard against orchestrated gifting from multiple actors within the same interest group, the provision enables cumulative influence to be exerted through small but persistent transactions—each technically legal, all cumulatively significant.  

In comparison, similar thresholds in established democracies are significantly lower and subject to stricter controls. In the United Kingdom, ministers must declare and surrender any gift above £140. In the United States, the federal threshold is $50 per gift, with a $100 annual cap per source. Australia enforces a similar standard at A$100. In these countries, declarations are made public and often audited. Ghana’s Code includes none of these safeguards.

The problems do not stop at gifts. Section 1.5(b) defines “Family Members” in relation to conflict of interest narrowly, omitting in-laws, (siblings of a spouse, and spouses of the Minister’s children). These relationships are often used to shield direct involvement in questionable transactions. Their exclusion from the definition fails to reflect how influence networks actually operate in Ghanaian political life.

Section 1.6 exempts jewellery and artworks valued under GHS 5 million (roughly $350,000) from mandatory declaration of assets. That amount is enough to purchase multiple properties in the capital, yet the Code allows public officials to own and conceal such high-value personal assets. While this clause originates from Section 4 of the Public Office Holders (Declaration of Assets and Disqualification) Act, 1998 (Act 550), it urgently requires revision in light of contemporary standards of transparency and asset concealment risks.

Worryingly, enforcement is vested largely in the President. Section 6 of the Code gives the Head of State complete discretion in determining whether an infraction warrants an apology, dismissal, or no action at all. There is no clear role for CHRAJ or an independent ethics committee. This centralization of enforcement undermines impartiality and introduces the risk of selective accountability.

The Code is also silent on electoral ethics. It contains no provisions to regulate the misuse of public resources during campaigns a recurrent issue in Ghana’s political landscape. This omission signals a reluctance to address some of the most persistent integrity challenges in the public sector.

Furthermore, there are no protections for whistleblowers or avenues for anonymous public complaints. No secure portal exists for internal or external reports of misconduct, weakening the culture of accountability the Code seeks to promote. Other countries, including South Africa and Kenya, have integrated whistleblower protections into their ethics regimes. Ghana’s failure to do so places those who seek to report wrongdoing at considerable personal and professional risk.

The Code also makes no mention of hospitality, sponsored travel, or third-party benefits. It does not require appointees to disclose luxury trips, accommodation, or gifts provided to family members or associates. Without regulation, these benefits function as a form of soft influence. Legal but ethically problematic.

To address these gaps, several reforms are urgently needed. First, the gift threshold should be reduced to GHS 2,000, and all retained gifts—regardless of value—should be declared and recorded in a public registry. Second, the conflict of interest definition should be expanded to include extended family and marital relations. Third, an independent ethics body should be established or CHRAJ empowered to investigate and enforce compliance. Fourth, whistleblower protections and an anonymous reporting platform must be created. Fifth, electoral ethics must be incorporated into the Code to ensure accountability during campaign periods. Finally, all high-value personal property, foreign-sponsored travel, and indirect benefits to family members should be subject to full disclosure.   

The 2025 Code of Conduct was intended to rebuild public trust. That trust cannot be achieved through symbolic gestures or partial transparency. It must be grounded in a system that enforces ethical standards without exception, and in which no official is beyond scrutiny—not even the one who signed the Code into force.  

Until then, influence in Ghana will continue to flow—quietly, lawfully, and GHS 20,000 at a time.