Former Auditor-General Daniel Domelevo has expressed strong concerns about the $20,000 gift limit outlined in President John Mahama’s newly introduced Code of Conduct for government appointees, calling the threshold misguided and at odds with principles of ethical governance.
He criticized the decision to allow public officials to accept gifts of such high value, warning that it creates a dangerous precedent and undermines the integrity expected of those in public service.
“Creating these windows and putting a limit of $20,000 on gifts for government appointees can receive, I think, is a no-no. I worked at the World Bank. Our threshold was $50, five zero, not a hundred.”
Daniel Domelevo
To Domelevo, Ghana’s public service appears to harbor a worrying tolerance—perhaps even affection—for personal gifts. “I think we seem to like gifts too much,” he observed.
Domelevo maintained that public office is a salaried position, and those who hold such roles are expected to sustain themselves solely on their official earnings.
He stressed that the culture of accepting gifts undermines the integrity of public service and creates a breeding ground for conflicts of interest.
While Domelevo was sharply critical of certain aspects of the proposed policy, he also recognized that it contains elements that could contribute meaningfully to ethical governance.
He noted that the document is not entirely without merit, as it includes provisions that could strengthen accountability. However, he cautioned that these positive aspects should not be treated as temporary guidelines meant to apply only under a single administration.

Instead, he urged that the valuable components be integrated into the existing draft Code of Conduct Bill and passed into law.
For Domelevo, making these ethical standards legally binding is the only way to ensure continuity, enforceability, and credibility across successive governments.
According to Domelevo, ethical standards must transcend political cycles and individual leaders. “So that it is not something which is going to guide public office holders only during the Mahama administration.”
Push for Legal Backing Amid Controversial Gift Limit
Furthermore, Daniel Domelevo expressed serious concern about the section of the proposed code that deals with asset declaration, highlighting a clear inconsistency with the existing Asset Declaration law.
He drew attention to a specific clause on page 30 of the document, which stipulates that only jewelry valued at $5 million or more must be declared—a threshold he believes is excessively high and legally questionable.

“$5 million, I say, this is too high. And it is not consistent with the law because Act 550 does not say anything like that. So, I think they may have to review that and maybe make it to align it with the law. It’s a lot. I don’t know if the housing some of them stay in is even up to $5 million.”
Daniel Domelevo
For Domelevo, the $5 million threshold is unrealistic and potentially misleading. Moreover, he warned against a political approach to ethics.
Reinforcing Domelevo’s position, Dr. Kojo Asante, Director of Policy Engagement and Partnership at the Centre for Democratic Development (CDD-Ghana), also expressed deep skepticism about the gift threshold.

He questioned the vagueness of the $20,000 limit. “And the other thing that is obviously not clear is that, is this $20,000 threshold for the year?” Dr. Asante asked. Without explicit clarification, he warned, the policy could be easily manipulated.
According to him, the current wording leaves too much room for abuse.
“Because I can basically be giving you $20,000 every month for 12 months. And every time I receive it, it’s under $20,000. And therefore, it’s within the rules.”
Dr. Kojo Asante
This loophole, he suggested, could institutionalize corruption under the guise of regulated gifting.
Dr. Asante maintained that the true purpose of such a policy should be to prevent, rather than permit, scenarios that could lead to conflicts of interest.
In his view, the focus should be on eliminating opportunities for undue influence, not crafting rules that could be exploited under the guise of regulation.
He emphasized how difficult it is to monitor and assess the intent behind gifts in the public sector, suggesting a zero-tolerance policy may be the best route. “So you try to just avoid it. Don’t create a situation for people at all,” he concluded.
Both Domelevo and Asante are united in their call for a comprehensive, legally enforceable framework for public ethics—one that isn’t subject to the whims of a particular administration.
Their criticisms highlight a broader concern: that Ghana must move beyond piecemeal ethical codes and embrace lasting, bipartisan reforms grounded in law, not temporary political goodwill.
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