The Chamber of Licensed Gold Buyers (CLGB) has thrown its support behind Bawa Rock Limited’s exclusive gold aggregation mandate under the GoldBod framework, rejecting criticisms raised by the Minority in Parliament.

In a detailed statement, the Chamber said industry data and monitoring show that Bawa Rock Ltd has met all licensing requirements and delivered measurable improvements in the Artisanal and Small-Scale Mining (ASM) gold sector, including nationwide aggregation infrastructure, transparent pricing, full traceability, reduced smuggling and improved foreign exchange capture.

According to the Chamber, maintaining a single, exclusive aggregator is a deliberate governance tool rather than a commercial concession, arguing that centralised control is essential for market discipline, compliance, revenue protection and accountability.

Drawing comparisons with Ghana’s COCOBOD model and regional gold aggregation systems, the CLGB warned that weakening Bawa Rock Ltd’s mandate would undermine formalisation gains and reopen avenues for leakages, investor uncertainty and regulatory fragmentation.

The Chamber therefore reaffirmed its institutional protection and support for Bawa Rock Ltd as central to Ghana’s ongoing gold sector reforms.

Below is the full statement by the Chamber.

STATEMENT OF PROVEN EVIDENCE OF PERFORMANCE AND POSITION OF THE CHAMBER OF LICENSED GOLD BUYERS (CLGB)

In Support of the Exclusive Aggregator Mandate Issued to Bawa Rock Limited.

1. Introduction

The Chamber of Licensed Gold Buyers (GLGB) issues this statement in response to the Minority in Parliament's assessment of the issuance of an exclusive gold aggregation license to Bawa Rock Limited under the GoldBod Aggregation Model.

The Chamber affirms, based on industry data, field experience, and institutional performance benchmarks, that Bawa Rock Ltd has demonstrably delivered on the objectives of the GoldBod framework and that maintaining its exclusive mandate is strategically necessary for the continued formalisation, stabilisation, and regulation of Ghana's Artisanal and Small-Scale Mining (ASM) gold supply chain.

This statement also records the Chamber's formal position of protection and institutional support for its member, Bawa Rock Ltd.

2. Proven Evidence of Performance: Bawa Rock Ltd

Since the commencement of the GoldBod aggregation system, Bawa Rock Ltd has:

• Built and operationalized a nationwide purchasing and aggregation network linking licensed miners, buying agents, assayers, and transport operators.
• Enforced uniform pricing transparency and compliance standards across participating ASM operators.
• Introduced full traceabilitv and documentation controls, replacing informal and undocumented trade

flows.

• Significantly reduced smuggling, leakages, and parallel market activity by centralizing gold offtake.
• Improved foreign exchange capture, export predictability, and revenue reporting.
• Successfully and legitimately satisfying all the licensing requirements of the Aggregator category of Goldbod.

The Chamber's internal monitoring confirms that ASM gold that previously exited the country through informal routes is now being captured within the formal national framework, directly attributable to the centralized aggregation mechanism executed by Bawa Rock Ltd.

3. Strategic Logic of Maintaining an Exclusive Aggregation Mandate

The exclusive mandate is not a concession; it is a structural instrument of reform. Its logic is grounded in five core policy outcomes:

1. Market Discipline & Order

Fragmented aggregation introduces price arbitrage, quality dilution, regulatory evasion, and enforcement paralysis. A single aggregator eliminates these distortions.

• Traceability & Compliance

A unified chain of custody is only achievable under centralised control. Multiple competing aggregators fracture traceability and weaken compliance.

• Formalisation of ASM

The ASM sector's transition from informal survival activity into a regulated industrial contributor requires one accountable institutional anchor.

• Revenue Protection & FX Stability

Centralised aggregation ensures accurate declarations, export proceeds repatriation, and macroeconomic stability.

• Policy Accountability

With one mandated aggregator, the State has a single accountable operator, eliminating diffusion of responsibility.

Therefore, the exclusive mandate is a governance tool, not a commercial favour.

4. Comparative Policy Frameworks

a) COCOBOD Model - Ghana

Ghana's cocoa sector offers a successful precedent:

COCOBOD operates a centralized commodity governance system that ensures:

• Price stability
• Quality control
• Producer protection
• Export market credibility

GoldBod's model mirrors this architecture. In both cases, centralised authority is the mechanism through which national value is secured.

b) Tanzania and Rwanda Gold Aggregation Models

Tanzania and Rwanda, though at different stages of implementation, pursue state-directed aggregation and formalisation of ASM gold through:

• Licensed buying centers
• Central reporting systems
• Regulated export pipelines

However, the absence of a single dominant aggregator in those systems has led to persistent challenges with leakage, enforcement fragmentation, and informal trading.

Ghana's GoldBod model—anchored by Bawa Rock Ltd—goes further by locking the entire ASM supply chain into one coherent institutional structure, producing superior outcomes in traceability and revenue capture.

5. Protection of the Chamber's Member: Bawa Rock Ltd

The CLGB formally records that:

• Bawa Rock Ltd has acted in good faith, in compliance with national policy and regulatory directives.
• The company has made significant capital, infrastructure, and operational investments in reliance on the exclusivity of its mandate.
• Any destabilisation of this mandate introduces legal uncertainty, investor risk, and systemic regression of the ASM reform agenda.

Accordingly, the Chamber shall defend the continued operation and mandate of Bawa Rock Ltd as a matter of institutional integrity, fit and proper assessment, market stability, and national economic interest.

6. Conclusion

The Bank of Ghana (BoG) has the exclusive legal mandate to regulate the entry of new banks into Ghana's financial system and financial centres. This mandate is grounded mainly in statute and exercised through licensing, supervision, and prudential regulation. Like the Bank of Ghana, Goldbod is empowered by GHANA-GOLDBOD-ACT- 2025 (ACT 1140) to determine the market entry conditions of applicant licensee.

The exclusive aggregation mandate issued to Bawa Rock Ltd is therefore not an anomaly.

It is the logical outcome of global commodity governance best practice, adapted to Ghana's specific ASM challenges.

Weakening this structure would reverse formalisation gains, reopen smuggling channels, destabilise revenues, and fracture regulatory control.

The Chamber therefore strongly endorses the maintenance of Bawa Rock Ltd's exclusive aggregator mandate as the cornerstone of Ghana's gold sector reform under the GoldBod framework until a strategic time the Goldbod will accommodate the entry of licensees into the category.

Signed; Secretariat, the Chamber of Licensed Gold Buyers - CLGB.