Engaging staff unions to promote integrity in Customs administrations: the experience of Ghana
22 June 2025
By the Ghana Revenue AuthorityThe workforce of the Ghana Revenue Authority (GRA) is highly unionized, with 69.24% of the staff having joined the GRA Workers’ Union (GRAWU), which was formed in 2012. Membership of the Union cuts across all three divisions of the GRA, namely the Customs Division, Domestic Tax Revenue Division and Support Services Division.
Over the years, the GRA management team and GRAWU have established a good working relationship based on mutual trust and respect, as well as an honest and constructive mindset. They have collaborated on numerous projects, including initiatives in the fight against corruption and the promotion of integrity within the organization. In this article, the GRA highlights the advantages brought by such a partnership and its challenges as well as the requirements to make it a success.
About GRAWU
Ghana’s Labour Act of 2003 (Act 651) contains provisions on collective bargaining, including the issuance of collective bargaining certificates that give trade unions the right to enter into negotiations with employers. The certificate held by GRAWU assigns it the leading role in all labour matters on behalf of both unionized and non-unionized staff of the GRA, numbering over 7,000 individuals.
Fourteen national executives are elected every four years to lead the Union, while eight permanent workers run the daily affairs of the Union’s National Secretariat under their guidance. They include an administrator, an accounts officer, a welfare officer, a janitor and two security officers. There are also local, regional and zonal executives who are stationed in its offices across the country.
GRAWU consults GRA staff mainly through meetings and communicates with them by means of circulars sent via corporate email and published on notice boards at the various offices as well as on the Union’s website. GRA employees can contact the union representatives via email, through GRAWU social media accounts, by phone and even by visiting the GRAWU Secretariat’s headquarters in person, located in the capital city of Accra.
Involvement in integrity matters
The GRA management team and the Internal Affairs Unit involve the Workers’ Union in a number of activities.
Development and update of the Code of Ethics and Conduct
The Workers’ Union has been involved in the development of the Code of Ethics and Conduct (CoEC) since the inception of the initiative in 2009. It also joined the committee set up to update it in 2018. One of the key changes it argued for was the alignment of the sanctions section of the CoEC with the Disciplinary Provision of the Collective Agreement (CA), which is the binding agreement between staff and management.
Disciplinary committees
When a staff member is under investigation by the Internal Affairs Unit of the Ethics and Good Governance Department, a report is issued and submitted to the management team. Based on the findings and/or recommendations of the report, the Human Resource Department may set up a disciplinary committee. A representative of the Workers’ Union must be present during the hearings of the disciplinary committee in order to ensure that the procedures have been respected during the investigation, that the employee is given a fair hearing and that sanctions, if they are to be applied, are reasonable and commensurate with the offence committed.
Performance measurement and management
In 2022, the GRA launched a 360-degree performance management system (PMS) to assess staff performance and productivity while providing them with coaching, counselling and feedback opportunities. In addition, supervisors were requested to communicate with their employees in a more open and transparent way, and staff who have demonstrated a commitment to integrity and ethics were recognized through awards or acknowledgement at public events.
GRAWU works with the GRA management team to ensure fairness, transparency and consistency in the way performance is assessed via the PMS. It also assists employees in understanding and complying with the performance policies, while taking part in the resolution of grievances related to the PMS.
FIT for Integrity team
The GRA is developing an integrity strategy that will provide the framework for its integrity action plan. A team named the “FIT for Integrity Team” has been formed to take on this project and includes among its members GRAWU representatives. In view of their experience working with staff, they are well placed to suggest or support measures they believe are workable and oppose those they believe are not
For example, when it was suggested that lifestyle audits should be incorporated into the strategy, the union representatives argued that there were other measures which would be easier to implement and that it may be prudent to focus on those types of solutions first. After much deliberation, the team agreed to put lifestyle audits on the back burner for the time being.
Confidential reporting mechanism
The Customs Division of the GRA has been working with the Ghana Integrity Initiative, the local chapter of Transparency International, on setting up a confidential reporting mechanism which will enable individuals to report incidents of bribery and corruption. The Workers’ Union should be involved in the project once it is fully established.
In 2020, the GRA introduced a whistleblower programme with reward incentives for individuals who help expose tax defaulters. The Fit for Integrity Team has been advocating for the development of a whistleblower implementation policy for the GRA, and the Workers’ Union will be involved in this work once approved.
Challenges
Staff of the GRA Customs Division have their own association called the Customs Staff Association (CSA) whose mission is to foster continuous forums for building capacity, discipline and esprit-de-corps, address challenges concerning members, bridge the gap between junior, senior and managerial staff, and promote networking and collaboration among members through social activities. Although the Association does not have a collective bargaining certificate, it is represented on the “FIT for Integrity Team”.
The relationship between the GRA Workers’ Union and the CSA is strained. The latter argues that Customs is a para-military arm of the Authority and, therefore, the law does not support their unionization. A few years ago, they asked the country’s High Court of Justice to rule that all Customs officers who are GRAWU members should withdraw from it. The Court has still to return its verdict.
Despite the ongoing feud between the two parties, they both meet to discuss measures that would impact the welfare of Customs officers and of GRA staff in general. Views and decisions reached by consensus are then put forward by the GRA Workers’ Union to the relevant authority.
Lessons learned
Engaging staff unions in the fight against corruption and in the promotion of integrity is rewarding for all stakeholders. It enables the GRA management team to ensure a better understanding and acceptability of reforms among staff; opens opportunities for the Workers’ Union to strengthen its role and credibility; provides employees with guarantees in terms of transparency and fairness, as well as the provision of support and protection; and helps trade operators to prevent or reduce the occurrence of unlawful practices, and to offer a better quality of service.
Below are some of the lessons that have been learned in the process.
Expect disagreements and stalemates
Teamwork is one of the five core values of the GRA, together with fairness, integrity, responsiveness and service. As the African proverb tells us, “If you want to go fast, go alone. If you want to go far, go together” – this resonates deeply across the Authority. Discussions between representatives of the Workers’ Union and the GRA management team may be difficult, but they are worth every effort put in, as they have led to more innovative solutions and fairer decisions.
Start with what you have and improve gradually
The Code of Ethics and Conduct, which entered into force in 2009, was a first for the GRA, and each party involved in its development and review was requested to identify any shortcomings and areas for improvement. Nine years on, a first update has been published and a new review cycle is in progress.
Timely engagement is critical
There is always a risk that union representatives will reject changes to existing practices or new policies if they perceive them as a threat to the interests of the staff. Given the clout they have, they may influence others and convince them to resist positive changes as well. Management teams must therefore engage their unions at an early stage in a project so as to ensure their active participation and ownership, while helping build credibility and momentum for change among staff.
Balancing interests while remaining credible can be difficult
Balancing interests refers to the process of determining which conflicting interests should prevail when both or all interests cannot be fully satisfied. The GRA management team and GRAWU have, over the years, built a good working relationship, and the Workers’ Union is, for the most part, supportive of the management’s initiatives. However, this alignment can be perceived negatively by staff who may accuse union staff of being in cahoots with management. The union staff may then harbour a fear of retaliation, harassment and/or intimidation. These fears would have to be dealt with and allayed through assurances by both parties that they have each other’s (staff and management) interests at heart, as agreed in the CA, and that no one would condone any acts of reprisal, in whatever form. Everyone must also be reminded of the fact that the law is on their side as long as they follow the right path in promoting integrity and fighting corruption.
Having a strong relationship helps secure external support
The GRA and GRAWU have limited resources to dedicate to their anti-corruption efforts. Having established a good working relationship, both parties are able to work together to obtain support from donors and international organizations. Where there is goodwill, respect and trust, and both the Workers’ Union and management agree on the need to fight corruption and promote integrity, they can work together to secure the help and support they need for the strategies they devise for this purpose.
Conclusion
Ghana’s experience shows that involving staff unions in Customs integrity strategies is not only possible but desirable, provided that a good governance framework can be established. The challenge is to move from a logic of mistrust to constructive cooperation and collaboration around common objectives. Ultimately, engaging staff unions in anti-corruption efforts is not just a moral imperative, but a strategic necessity for Customs administrations. By partnering with staff unions, management teams can leverage their expertise, influence and reach to promote integrity, prevent corruption and build a more transparent and accountable organization.
The GRA encourages Customs administrations to institutionalize this type of social dialogue with employee representatives as a sustainable leverage for strengthening the culture of integrity within their organization. As we strive to build more effective and efficient administrations, engaging staff unions in the process is essential. It is clear that the fight against corruption in Customs administrations requires a collective effort, one that includes the involvement of staff unions. By working together, we can promote a culture of integrity, transparency and accountability, ensuring that Customs administrations serve the public interest and contribute to a fair and efficient trade environment and, ultimately, to a more prosperous and equitable society.