The_NCOM_reacts_to_the_Presidents_CSO_Meeting_October_20251.pdf

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National Coalition on Mining (NCOM) – Ghana
C/O Third World Network – Africa Post Office Box AN19452 9 Asmara Street, East Legon,
Accra Tel: 0302 511189/503816/500419 Email: environment@twnafrica.org
NCOM on Galamsey and the Meeting between President Mahama and CSOs
On Friday 3rd
October 2025, over 50 civil society organizations were invited to the Jubilee House
to engage with the President on the problem of illegal mining. The encounter was billed as an
opportunity to “provide a platform for frank and constructive dialogue between the Government
and civil society on the menace of illegal mining, with a view to harnessing collective expertise,
perspectives and solutions to address the national challenge”.
Even though the National Coalition Mining (NCOM) was not invited, we keenly followed the
interaction between the President and the government team with the representatives of civil
society organisations and religious bodies.
The commitment expressed by the President to intensify the campaign against the menace of
illegal mining describing the ongoing efforts as a “process” that he is determined to win was a
very important statement and has been welcomed by all.
No matter the good intentions of government however, galamsey is hydra-headed and must be
tackled comprehensively if it is to be overcome. In this regard we welcome President Mahama’s
caution about the declaration of a state of emergency. We have been treading the futile road of
blunt militarized repression of galamsey for 20 years, under both NDC and NPP regimes. Starting
with “Operation Flush Out” in 2005, we have since had the Inter Ministerial Taskforce (2013),
Operation Vanguard (2017- 2020), Galamstop (2018 -2021) and Operation Halt (2021 -2024). In
the process lives have been lost, the human rights of scores of citizens have been violated and
legally established small-scale mining and allied businesses damaged.
Galamsey is not simply a law-and-order issue
From a law-and-order perspective all unlicensed mining is illegal. However, the public anger over
the legal opening up of forest reserves for mining by politicians shows that the popular measure
of what is galamsey includes abuse of legality. Section 18(1) of TheMinerals and Mining Act,2006,
(Act 703) generally permits mining in forests, provided the license holder acquires the relevant
permits from the Forestry Commission and Environmental Protection Authority (EPA). It has
become apparent that this provision in the law has been ﬂagrantly abused by successive
governments that have gone ahead and granted licenses to their cronies to mine in forests. Either
way the actors in galamsey are multiple, varied and driven by different factors. Their success has
been aided by political, policy and institutional failures and weaknesses of public institutions. A
cross-cutting dimension of these is the pervasive corrupt complicity in and facilitation of the
galamsey economy by politicians and public officials. In addition to bolstering galamsey it is also
contributing to weakening the legitimacy and authority of the state and public institutions.
Dealing effectively and successfully with the galamsey problem starts with the recognition of this
complexity and therefore the diverse responses which must be applied.
Those at the top of the galamsey chain are equivalent to Latin American drug lords and their
enablers. These include businessmen (local and foreign), politicians, state officials (including in
the security services), prominent chiefs, sports and entertainment celebrities, etc. Who sells the
excavators used in galamsey? Who buys, rents and uses them in galamsey? Who allows access

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to the forest reserves, river bodies? Who protects such activities? Who facilitates the entry and
employment of illegal Chinese operators? Who is buying and exporting gold illegally? Which
public/security officials and politicians enable these, and related activities? Many of them have
been named and directly associated with the biggest galamsey operations with the most
destructive effect on forests and water bodies. For this lot galamsey income increases their
wealth, power and influence. Their power and influence have corrupted public institutions, and
political parties and paralyzed political action. They are the head of the galamsey snake and the
pillars of its political economy and must be the central focus of the criminal justice drive against
galamsey. Tangible progress against this power bloc will be a strategic shift in the anti- galamsey
effort and significantly boost the overall legitimacy and credibility of the drive against all
galamsey.
The other galamsey actors include unemployed poverty-stricken youth, most of whom are
persons displaced by large scale gold mining concessions, farmers who see better returns from
collaborating with illegal miners, corrupt traditional rulers and priests who legitimize illegal
mining in their localities, persons frustrated by the defects in the Artisanal Small-scale Mining
(ASM) regulatory regime, and security service personnel running localized protection rackets. For
most of those in this category galamsey provides the means of livelihood and economic security,
with most working in precarity. In this sense galamsey, which has a strong symbiotic relationship
with the legal economy, poses first and foremost a developmental challenge which has raised
law and order issues. Responding to this dimension of galamsey will require:
1) a mix of short-to- long-term public policy and investment measures and actions to create
employment and economic opportunities outside mining, improve social conditions in
rural areas. It will also require among others:
2) a sharp curb on new concessions for large scale gold mines so as to reduce the mass
displacement and livelihood disruptions and social problems created by the industry,
3) reducing the regulatory barriers to entry into legal ASM – including strengthening
(financing, staffing, etc.) the decentralized presence of the State and effectiveness of
regulatory institutions, and
4) curbing the growing challenge of chiefs to the rights of citizens and the institutions of the
Republic.
Many elements of this multidimensional reality and required responses have long been
recognized by regulatory agencies and informed several reforms and anti-galamsey programmes.
Unfortunately, virtually none of these plans/programmes have been fully resourced and
implemented, e.g. the 2017 Multi-sectoral Mining Integrated Project (MMIP) for which the World
Bank provided a $50m grant. The calls for the imposition of a, seemingly cure all, state of
emergency, appear to simplify this multifaceted reality.
A state-society collaboration in needed for success
Over the past few years, the involvement of groups like the Ghana National Association of Small-
Scale Miners (GNASSM) and other groups have aided the drive to end galamsey and the damage
it is causing to rivers and forest reserves. Overall, however, instances of harnessing the resources
and contributions of non-state entities in the fight against galamsey have been patchy and
unsystematic. The “harnessing collective expertise, perspectives and solutions to address” the
galamsey issue should extend beyond policing measures to some of the long term transformative
socio-economicmeasures requiredforbroad basedrural development and creationof economic
opportunities and improved social conditions in the countryside. This will require a purposive
plan and also identification and engagement by the state with civil society organisations and the

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private sector for state-private sector-civil society partnerships. Galamsey is taking place across
all gold endowed parts of the country – in the forest belt as well as the Northen Savannah. -
Addressing it will require appreciation of area specific challenges. This can be aided by public
institutions – from national to local levels district – being better informed about and reaching out
to relevant citizens’ organisations.
The list of participants in the Jubilee House meeting seen by the NCOM was heavily dominated
by Accra based/headquartered organisations. This skewing could have been as a result of factors
that the Coalition is not privy to. It is however striking that quite a number of organisations around
the country, especially in mining areas, who have been working on the issues were not on the list
of those invited. From a more pessimistic point of view, the defects in the invitation could be
another instance of the pervasive absence of a systematized approach by most public agencies
to engagement with CSOs working on issues within their purview. This weakness often results in
these institutions reaching out in an ad hoc and sub-optimal manner to CSOs and other
organisations. Very few public bodies have credible databases of which CSOs are working in their
areas of responsibility.
Article 37 (2) of the 1992 Constitution (Directive Principle of State Policy on Social Objectives)
enjoins the State to facilitate the citizens to form their own association in order to use them to
promote and protect their interest in the development processes, including through access to
public officials and agencies. Useful as the Jubilee House meeting on galamsey may have been,
it also highlighted a glaring shortfall in democratic governance more than 30 years into the life of
the 4th
Republic.
Government must commit the resources needed for the multi-dimensional effort to address
illegal mining
Addressing the challenge of galamsey requires substantial financial and other resources which
must be planned and budgeted for over the short to long term. Unfortunately, the approach of
successive governments to resourcing has been inadequate, short term, ad hoc, lacking in a
recognition of the variety and mix of responses required. We encourage the government to
properly finance and equip the effort founded on an acceptance that change has to be sought on
multiple fronts and differing time horizons. There must be dedicated resources not only at the
national level but also at the district and local levels where many of the activities take place.
We must confront gold’s unhealthy and unsustainable importance in Ghana’s economy
Gold is the most sought-after metal and it is Ghana’s (mis)fortune to have gold deposits on about
a quarter of its land area. (See attached map). Even as we decry galamsey and its devastating
effects we must have an honest conversation about the exaggerated and unsustainable
importance of gold production in Ghana’s economy. We should also soberly evaluate the overall
balance sheet of the socio-economic and environmental effects of gold’s status. The status of
gold is severely distorting the balanced development of the national economy and society.
Last year gold accounted for more than 50% of Ghana’s export earnings. We should be alarmed
about this dependence. From 2021 to 2024 the production of gold went up by almost 90% from
2.77m/oz. to 5.09m/oz with the value of 2024 exports being more than double that of 2021, thanks
to the steady rise in gold prices, which recently breached $4000/oz. In 2024 the shares of ASM
and large-scaleproduction were close, 43% and 57% respectively. Compared to ASM, large scale
gold mining enjoys a privileged status with the Ghanaian state, including security protection by
the military.

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The flipside of the alarming expansion of galamsey is the open-ended readiness of successive
governments to promote and license large scale gold mines across the country. The expansion of
galamsey and legal gold mining are both driven by the market with licensed mining. Both create
negative externalities. Unregulated, unremedied and uncompensated in the case of galamsey
and regulated, partially remedied and partially compensated with a veneer of public
accountability in the case of legal mining.
In recent years the large-scale gold mining frontier has extended into the Upper East and West
Regions. The fragile ecological conditions and higher levels of poverty in these areas mean that
the negative effects of mining are more profound than in the forest zone. No lessons seem to have
been learned from the history of conflict around large scale mining in the south. In the Upper East
and West, just like in the forest gold belt, alliances of state (administrative and security) officials
and traditional rulers help to enforce the interests of mining companies in the face of
dissatisfaction and protests from citizens whose lives and livelihoods have been disrupted by the
mines.
Beyond the designation of forest reserves, water bodies and riparian zones as areas protected
frommining thelawalsogives governmentpowers to designateareas tobeexcludedfrommining.
Experience however shows that public policy gives mining, especially for gold, priority over other
types of land use – economic, settlement, ecological or cultural. Losses and disruption caused
by mining are presumed to be worthwhile consequences “in the public interest” to be privately
mitigated or compensated for by the mining firm. The revenue to the state and the economic
trickle down of the projects are presumed to be acceptable public benefit. We are not aware of a
national land use policy setting criteria and priorities and developmental cost benefit analysis
which informs the priority given to gold mining. Such a policy could clearly prohibit granting
concessions in heavily populated areas, culturally sensitive sites, and ecological fragile areas
such as theUpper East and West regions. There is no evidenceof a publicframework and practice
for comprehensively and periodically evaluating the transformative (positive or negative) effects
of the expansion of legal gold mining beyond the claims made by the companies.
From local to national levels, there is no serious accountability from public institutions to the
citizenry for the management of what are legally publicly owned non-renewable mineral
resources.
Looking forward
The NCOM looks forward to a government anti-galamsey programme which recognizes the
complex nature of the challenge, lays out a strategy resourcing the programme, and a clear
approach to state-society cooperation from the national to local levels. The key political question
remains:Will PresidentMahama havethepoliticalcourageto act againstthosein his government
and the NDC who are known or rumoured to be galamsey kingpins and facilitators? That
ultimately will be the touchstone for the success or failure of any anti-galamsey programme.
____________________________________________________________________________
*The National Coalition on Mining (NCOM), is a grouping of civil society organisations and
individuals that seeks see that the exploitation of Ghana’s mineral resources is done in a manner
that respects human rights is environmentally sensitive and optimizes development benefits for
citizens while contributing to the structural transformation of Ghana’s economy
*For further information, kindly contact NCOM Secretariat 0262251618

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Map of the distribution of gold rocks in Ghana

The_NCOM_reacts_to_the_Presidents_CSO_Meeting_October_20251.pdf

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