Conflicting interests and the localisation of international migration governance norms in Ghana

Jaji, Rose Research Report Conflicting interests and the localisation of international migration governance norms in Ghana IDOS Policy Brief, No. 21/2024 Provided in Cooperation with: German Institute of Development and Sustainability (IDOS), Bonn Suggested Citation: Jaji, Rose (2024) : Conflicting interests and the localisation of international migration governance norms in Ghana, IDOS Policy Brief, No. 21/2024, German Institute of Development and Sustainability (IDOS), Bonn, https://doi.org/10.23661/ipb21.2024 This Version is available at: https://hdl.handle.net/10419/299534 Standard-Nutzungsbedingungen: Die Dokumente auf EconStor dürfen zu eigenen wissenschaftlichen Zwecken und zum Privatgebrauch gespeichert und kopiert werden. Sie dürfen die Dokumente nicht für öffentliche oder kommerzielle Zwecke vervielfältigen, öffentlich ausstellen, öffentlich zugänglich machen, vertreiben oder anderweitig nutzen. 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If the documents have been made available under an Open Content Licence (especially Creative Commons Licences), you may exercise further usage rights as specified in the indicated licence. https://creativecommons.org/licenses/by/4.0/ Conflicting Interests and the Localisation of International Migration Governance Norms in Ghana Rose Jaji Summary This Policy Brief addresses the challenges that Ghana faces in implementing governance norms on international migration. Although Ghana has committed to the goals of the Global Compact for Safe, Orderly and Regular Migration (GCM) and the African Union (AU) and Economic Community of West African States (ECOWAS) Protocols on Free Movement, along with complementing them with comprehensive domestic migration policies, there are obstacles to holistic implementation of these goals as well as those in the country’s National Migration Policy (NMP). This Policy Brief specifically addresses conflicting interests and priorities among the various actors; reliance on external funding; and lack of coordination and synchronisation between policies as well as between policy and experience at the local level. Ghana participated in the development of the GCM as well as in the Global Compact on Refugees (GCR). It was also actively involved in the Global Forum on Migration and Development (GFMD), a platform for UN Member States to discuss the opportunities and challenges of migration. Moreover, Ghana committed to submitting a voluntary review of its implementation of the GCM. Accordingly, its National Development Planning Commission (NDPC) held a meeting to begin the National Consultation on the GCM on 30 November 2020. Ghana followed up on this by launching the National Coordination Mechanism (NCM) on migration on 28 November 2023, which was set up to strengthen the coordination and coherence of the government’s implementation of the GCM in relation to domestic policies and activities related to migration. Ghana also committed to the AU Free Movement Protocol and the ECOWAS Protocol on Free Movement. At domestic level, it passed a comprehensive National Migration Policy (NMP) in 2016 and unveiled other policies addressing specific aspects of migration such as the Labour Migration Policy (2019) and the Diaspora Engagement Policy (2020). In view of the implementation challenges for these international pacts and domestic policies, this Policy Brief recommends that the government of Ghana: • Implement international and (sub-)regional frameworks as well as domestic migration policies in Ghana in a holistic manner. • Match the ambition for (sub-)regional integration with concrete actions that align domestic policies with the ECOWAS and AU Protocols on Free Movement. • Earmark funds for policy implementation instead of relying on external funders. The government needs a clear strategy on how it will achieve the goals of its policies in terms of the source and amount of resources needed. This would reduce the counter-productive tension between internal priorities and external funders’ interests and narrow the gap between policy and action. • Develop and implement policies that complement the NMP and, in the process, dissuade young people from unsafe and “irregular” migration. This includes harmonisation of migration policies with policies that address factors that influence the decision to migrate. • Enforce compliance with migration policies by actors such as migrant recruitment agencies that continued to recruit migrants for domestic work in the Gulf States even when the government had halted this migration corridor in order to reach bilateral agreements with the Gulf States, meant to ensure that Ghanaian domestic workers in this region would be safe and treated with dignity. IDOS POLICY BRIEF 21/2024 IDOS Policy Brief 21/2024 2 Migration as a development strategy Ghana’s NMP is comprehensive. However, the government prioritises categories of migrants that are relevant to its development agenda. The NMP (Government of Ghana, Ministry of the Interior, 2016, p. 12) presents as its purpose the need to “maximise the gains and minimise the costs associated with migration”. Ghana’s National Labour Migration Policy (NLMP) (Government of Ghana, Ministry of the Interior, 2016, p. xi) complements the NMP by seeking to promote “an improved labour migration governance that harnesses the benefits of labour migration for socioeconomic development in Ghana”. The goal to maximise the benefits and reduce the costs of migration – for example, by harnessing and channelling the diaspora’s resources towards development – is as much a strength as it is a weakness in migration governance in Ghana. As a strength, linking migration to Ghana’s development agenda enables the government to pay more attention to migration issues as it seeks to benefit from the resources and opportunities deriving therefrom. For example, the government has taken concrete measures to implement the Diaspora Engagement Policy, which seeks to harness the diaspora’s human and material capital and channel them towards development. These measures include initiatives such as the Ghana Diaspora Homecoming Summit in 2017, the Year of Return in 2019, and the biennial Ghana Diaspora Celebration and Homecoming Summit. These were occasions to appreciate and celebrate the diaspora’s contributions to nationbuilding (Kandilige et al., 2023). In particular, the Year of Return saw an increase in the number of the African diaspora visiting and/or relocating to Ghana. In 2021, then Minister of Tourism, Arts and Culture, Barbara Oteng-Gyasi, indicated that Ghana had earned USD 3.3 billion from the Year of Return initiative. This success led to the unveiling of a follow-up initiative for the period 2020-2030 under the theme Beyond the Return. Another incentive for the diaspora came in the form of the ruling in April 2024 by the Supreme Court of Ghana that Ghanaians with dual citizenship can become a Chief Justice; Commissioner, Value Added Tax Service; Director-General, Prisons Service; Chief Fire Officer; Chief Director of a Ministry; rank as a Colonel in the army; or hold other security service leadership positions. In its focus on channelling migrant remittances to development, the government has also taken action to facilitate migration by domestic workers to the Gulf States by enacting laws that make this migration corridor safe and orderly. The focus on remittances is in line with the World Bank’s (2023) promotion of remittances as an important poverty reduction strategy. In what appears to be a quid pro quo relationship, the government acknowledged the diaspora’s role in developing the country through financial remittances and skills transfer into sectors such as healthcare and education, by addressing the interests of the diaspora. The World Bank’s portrayal of the migration-development nexus as facilitating a winwin situation for countries of origin and of destination has led to prioritisation of international cooperation partnerships that focus on leveraging regular migration and diaspora resources for sustainable development, exemplified by the programme Shaping Development-Oriented Migration (MEG) implemented by GIZ in Ghana. The shortcoming, however, is that the government tends to neglect migration trajectories that it does not see as contributing to the country’s development agenda. These include climate and ruralurban migration, immigration by low-skilled people, and refugees living in Ghana. For example, although the NMP includes climateinduced migration, the government has so far not channelled funding to rural-urban and climateinduced migration or expanded its engagement with local authorities who directly deal with this migration (Ekoh, 2023). The government also sees forcibly returned migrants as a problem, for example, those deported from EU Member States. Forced returns affect the flow of remittances along with the government’s relationship with migrants IDOS Policy Brief 21/2024 3 and their families in Ghana who receive such remittances (Adam et al., 2020). The deportations also increase the rate of youth unemployment and crime, which portrays the government negatively in public opinion (Mouthaan, 2019). These considerations provide utilitarian justification to non-cooperation with the European Union (EU) on the forced return of “irregular” Ghanaian migrants (Cham & Adam, 2023). The idea of some migrants being unwanted in EU Member States is ironically replayed in Ghana with specific reference to the government’s reaction to immigration from other West African states. The government focuses more on highly skilled immigrants while neglecting those who are low-skilled and are a source of competition to Ghanaians in the informal sector. In this sense, the government selectively implements the ECOWAS Protocol on Free Movement by prioritising highly skilled migrants. This selectiveness is illustrated by the Ghana Investment Promotion Centre (GIPC)’s requirement that every foreign investor in Ghana pay a USD 1 million levy, which effectively excludes many retail traders from other ECOWAS Member States. In effect, the levy reserves activities such as retail trading for Ghanaians, which has led, on numerous occasions, to closure by the authorities of retail shops run mostly by Nigerians and to sporadic confrontations between Ghanaian retail traders and migrants from other ECOWAS Member States, such as Nigeria. External funding and agendas The government of Ghana has invested in initiatives that are relevant to the diaspora, which plays an important role in the government’s economic priorities as indicated above. However, it relies heavily on external funding in the governance of migration in general and this funding prioritises the interests of the funders. Reliance on external funding creates challenges where there are discrepancies between domestic and external interests as is the case in Ghana. Ghana’s domestic interests in migration-related issues are: i) closer engagement with the diaspora; ii) prevention of forced returns; and iii) facilitation of “regular” migration, which improves protection of migrants as they move to their destinations (Adam et al., 2020). In contrast, external interests – especially from the perspective of the EU which funds some of the migrationrelated projects – are i) strengthening of border security and control; ii) supporting reintegration of migrants who have voluntarily returned; and iii) encouraging migration within West Africa as a strategy to reduce migration to Europe (Adam et al., 2020). EU funding thus prioritises deterrence of “irregular” migration to Europe, which explains the EU’s focus on facilitating free movement in the ECOWAS region and promoting the return and reintegration of those forcibly returned from Europe (Kandilige et al., 2023). Recently, the EU focus has embraced the recruitment of skilled workers to countries such as Germany, facilitated by the Ghanaian-European Centre for Jobs, Migration and Development (GEC). Thus, the EU continues to promote curbing “irregular” migration at the same time that some of its Member States are actively recruiting highly skilled people overseas. The EU also prioritises capacity-building with the aim of establishing strong and stable institutions that facilitate effective collaboration with Ghana on migration governance. It directs its funding to securing the borders in order to curb “irregular” migration. The 10th European Development Fund financed the Ghana Integrated Migration Management Approach (GIMMA) (Kandilige et al., 2023). The EU is consistent in its priorities: it has taken the same approach in its cooperation with Senegal on migration governance (Dimé & Jaji, 2023). Although the government of Ghana wants secure borders, its reasons are different from those of the EU. The EU sees secure borders as a deterrent to “irregular” migration. The government of Ghana, on the other hand, wants secure borders primarily to prevent the instability in the Sahel region from spreading into Ghana. Accepting EU funding means prioritising projects that seek to deter “irregular” migration. Cooperating with the EU on deportations is politically risky as it portrays the government as standing in IDOS Policy Brief 21/2024 4 the way of citizens’ aspirations in addition to contradicting its policies on diaspora remittances. The deportations also swell the number of young people who are unemployed. Cooperating with the EU on the deportation of Ghanaians without first putting in place policies that address forcibly returned migrants’ needs in a comprehensive manner and in the long term can lead to political backlash, increasingly evident in young people’s voting patterns. This is salient in a sub-region where the young are playing a growing role in shaping the political landscape, the latest example being the election of the 44-year-old Bassirou Diomaye Faye in Senegal. Like Ghana, Senegal faces the challenge of “irregular” migration especially by young people to the EU, and both countries are in partnerships with the EU on migration governance. Cooperation with the EU on deportations can thus turn public opinion against the party in power (Mouthaan, 2019). There is an inherent dilemma in the EU’s interventions in West Africa, namely securing borders and simultaneously supporting sub-regional migration. The EU sees migration in West Africa as reducing “irregular” migration to Europe, yet its support for border controls in the sub-region potentially undermines the ability of some migrants to move even within the region, especially those who find the “regular” route cumbersome, expensive, and exclusionary where the destination country’s government prefers highly skilled migrants – a criterion they may not meet. These contradictions leave the government of Ghana in an untenable situation where it has to balance the interests of domestic actors and those of the external funders of its migration policies and activities (Adam et al., 2020). This is happening in a context where the government of Ghana also has to consider subregional interests. The government’s incapacity or failure to earmark funds for policy and implementation has resulted in it ceding space on some migration issues such as “irregular” migration to civil society and faith-based organisations that similarly rely on external funding and comply with the needs and interests of their funders. Promotion of safe and orderly migration according to the GCM raises the challenge of how to deal with migrants who engage in “irregular” migration, especially to EU Member States. In addition, free movement in West Africa cannot work when governments are wary of the economic and political impact of migrants. This places the government of Ghana in a difficult position because of the contradiction between encouraging subregional integration involving Ghanaians’ migration within West Africa and the reluctance to receive immigrants especially those who are lowskilled and would create competition with Ghanaians in the informal sector. International and (sub-)regional frameworks versus domestic interests Migration governance in Ghana shows contradictions between international and (sub-)regional migration governance frameworks on the one hand and domestic interests on the other. In addition to its commitment to the GCM, Ghana is guided by the AU Free Movement Protocol (adopted in 2018) which urges domestication of free movement protocols, waiver of visa requirements (still not fully implemented on the continent), freedom of movement in sub-regional blocks for both citizens and non-citizens of these blocks, and the laying down of legal frameworks to facilitate the issuance of a common African passport (which missed the 2023 deadline) (Kandilige et al., 2023). The AU Free Movement Protocol grants the rights of entry, residence, and establishment for citizens of the continent. At subregional level, the ECOWAS Protocol on Free Movement grants the same rights to citizens of Member States. There are different economic and political interest groups that influence the government of Ghana’s reactions to migration issues. Adam et al. (2020) identify three such internal groups namely: • Political actors who must address domestic interests that are salient for winning elections. • Administrative actors who are interested in bureaucratic expansion and play along with EU IDOS Policy Brief 21/2024 5 priorities because of the funding opportunities this entails. • Societal actors whose views range from a total rejection of the EU’s agenda to the welcoming of the new opportunities cooperation with the EU creates. The EU – which provides much of the funding – and the diaspora – who send remittances – are other powerful and influential actors. With specific reference to the diaspora, the government is responsive to the interests of this group as discussed above. In contrast to the all-inclusive provisions of the ECOWAS Protocol, Ghana’s implementation of the Protocol is influenced by domestic considerations and interests. For example, it focuses on highly skilled workers and only grants work permits to ECOWAS citizens if the job cannot be done by Ghanaians (Kandilige et al., 2023). This means that the very migrants that the EU would prefer to remain in West Africa are not welcome in Ghana. In response to domestic economic and political pressure, the government of Ghana is protective of the informal sector and reserves petty trading and operation of small-scale businesses for citizens of Ghana (Kandilige et al., 2023). Although Ghana has relaxed its visa requirement for some African countries, it remains wary of competition for jobs between Ghanaians and immigrants, and this is a major obstacle to full implementation of the AU and ECOWAS Protocols on Free Movement (Kandilige et al., 2023). This means that ECOWAS citizens’ freedom of movement is influenced by their desirability, or lack thereof, in the Ghanaian labour market. The government of Ghana engages in a selective approach to localisation of international and (sub-) regional migration governance norms and frameworks: it shows commitment to ECOWAS but is inward-looking on issues such as immigration that threaten Ghana’s domestic interests. The country has been slow to domesticate international protocols through acts of parliament and to establish structures that facilitate implementation of its own NMP. It is also important to note that refugees are treated differently from other migrants, even if they come from ECOWAS Member States. Refugee affairs are regulated by the Ghana Refugee Board while migration falls under the purview of the Ghana Immigration Service. This means that the “special” circumstances under which refugees are hosted, as provided for in the Geneva and African Union Refugee Conventions, result in them being subjected to refugee status determination. This places in a tenuous position people who are denied refugee status and those who are granted the status but end up residing in camps where the right to establishment is curtailed by restriction of movement – notwithstanding the fact that the ECOWAS Protocol on Free Movement extends the right to free movement, residence, and establishment to all citizens of Member States. There is thus a disconnect between policy and practice because of the discrepancy between domestic interests and commitment to (sub-) regional integration. This calls for a delicate balancing act in which the government responds to the needs and interests of domestic actors such as voters and, at the same time, fulfils its obligations as a Member State of both the AU and ECOWAS. Turning a blind eye to the presence of non-Ghanaians in sectors reserved for Ghanaians does not always work, as citizens in these sectors speak out, which puts political actors under pressure because they need citizens’ votes during elections. In this sense, political interests influence political actors’ reaction to migration issues (Cham & Adam, 2023). Political interests influence reactions to both low-skilled ECOWAS immigrants and Ghanaians forcibly returned from Europe. The government of Ghana needs to address the inherent contradiction and incoherence in its wanting to champion (sub-)regional integration without being impacted by such integration in the sense of receiving immigrants. Contradicting interests explain the focus on governance rather than the humanitarian aspects of migration that are protected by the AU and ECOWAS Protocols on Free Movement’s emphasis on the right to entry, residence, and establishment. In short, the IDOS Policy Brief 21/2024 6 government of Ghana prioritises migrants based on their relevance to its development agenda, rather than their needs. Lack of policy complementarity, synchronisation, and institutional capacity Nana Akufo Addo, the current president of Ghana, has lamented the deaths of young Africans on the perilous trans-Sahara and trans-Mediterranean route to Europe. Lamentation alone cannot stop young Africans from risking their lives attempting to migrate to Europe. There is a need for a combination of the commitment to make migration safe and orderly with domestic policies that address the reasons that force young Africans to migrate. In Ghana, a holistic implementation of the NMP requires complementary policies and programmes that address youth unemployment, poverty, and inequality in an effective manner. These are the main reasons why young people risk their lives and migrate as “irregular” migrants. The fact that they take this risk points to the inefficacy of the country’s youth employment programmes. Awareness campaigns highlighting the dangers of “irregular” migration are inadequate if the country cannot meet young people’s needs. The absence of complementary policies that address the causes of “irregular” migration, or the ineffectiveness of those that exist, is an obstacle to the government of Ghana’s capacity to ensure that migration is safe and orderly as the GCM seeks to achieve. A representative of a government department in Ghana whom I interviewed in October 2022 indicated that Ghanaian migrants often travelled to neighbouring countries, such as Togo, in order to evade the government’s stringent measures at the international airport in Accra to deter migration to the Gulf States. The stringent measures are in line with the government’s mandate to protect Ghanaians by curbing unsafe migration. However, without corresponding policies that address youth unemployment and poverty in a comprehensive manner and in the long term, these stringent measures are likely to be ineffective because people who are determined to migrate find loopholes in the system or devise alternative strategies to migrate. After the ban in 2017, many Ghanaians continued to migrate to the Gulf States (Teye et al., 2019). There is also a need for adequate welfare services and social safety nets for children so that women as mothers do not migrate through “irregular” and unsafe routes, sometimes to equally unsafe destinations. This entails reviewing the existing cash transfer under the Livelihood Empowerment Against Poverty (LEAP) programme so that it also addresses children’s needs in a comprehensive manner and also that it includes people with productive capacity but lacking opportunities who see “irregular” migration as a strategy to meet their own needs and those of other family members. Migration also involves middle-class people, the so-called “burgers”, who sometimes leave their white-collar jobs to work in blue-collar jobs mostly in high-income countries so that they can earn more and acquire status symbols back in Ghana (Nieswand, 2014). Some of the “burgers” find the “regular” route expensive and this calls for bilateral labour agreements that would facilitate safe and orderly migration. The other area that the government of Ghana needs to address is the lack of coordination and synchronisation of national policy with experiences at the local level. There is urgent need for action in the communities where the migrants live, beyond awareness campaigns on the dangers of “irregular” migration. Consideration of the circumstances in the communities and involvement of citizens at this level are pertinent to the success of migration policies because the impact of migration is experienced at this level whether in terms of competition for jobs or the impact of remittances on families. This is the reason why civil society organisations in Ghana raise the important point that successful reintegration of returnees requires the cooperation of communities (Adam et al., 2020). Currently, there is poor coordination for migrations that are not at the top of the government’s agenda. For instance, the national IDOS Policy Brief 21/2024 7 government leaves the governance of everyday migration issues to cities that have limited capacity, competency, and resources instead of treating migration into cities as a national priority deserving funding and coordination with local authorities (Ekoh, 2023). In addition to policies that complement the agenda to make migration safe and orderly and synchronisation of policies, there is a need to put in place institutions that facilitate migration policy implementation in a timely manner. Implementation has stalled because relevant processes have been slow. Kandilige et al. (2023) note that, after the passing of the NMP in 2016, the Ghana National Commission on Migration (GNCM), which would have facilitated implementation of the NMP, was not immediately established and Ghana continues to use migration governance frameworks that existed before the NMP. It has been a long route to 28 November 2023 when the Government of Ghana finally launched the National Coordination Mechanism on Migration, which aims to strengthen the coordination and coherence of the government’s addressing of migration issues. It remains to be seen whether the launch of the NCM signals impending establishment of a migration commission as provided for by the NMP. The absence of adequate resources and institutional structures tasked with implementing migration policies in a coherent manner leads to diffusion of responsibility in the event of policy non-implementation and failure. For example, political actors can easily pass on the blame to relevant government departments such as the immigration services department and bureaucrats. The establishment of such structures needs to be reinforced by coordination among the various government agencies that are relevant to migration governance. In addition, fuzziness in who deals with what creates loopholes that can lead to non-compliance by other actors involved in migration issues. For example, only a few migrant labour recruitment agencies comply with the NLMP (Kandilige et al., 2023). Ghanaians who are determined to leave the country can avoid official exit points, for example, evading the governmentimposed ban on migration to the Gulf States by travelling to neighbouring countries from which they proceed on their onward journeys to work as domestic workers in the Gulf States. Political change: different administrations and incongruous priorities Effective governance of migration requires consistency and responsiveness to unanticipated issues that may arise in the course of time. Ghana has held free and fair successive elections and enjoyed peaceful transfer of power since 1992. While this stability is important, especially in a volatile sub-region, regular change in administrations is sometimes detrimental to policy implementation. One administration may leave before fully implementing its policies and the incoming administration may have a different approach to the issue or different priorities altogether. Since migration is an ongoing and open-ended activity, it requires long-sighted policy implementation characterised by consistency across political administrations in Ghana. This does not always happen when a new administration takes over. For example, when the New Patriotic Party (NPP) won the election in 2016 and took over in 2017, the party did not immediately establish the GNCM envisaged by the NMP to facilitate implementation of this policy. Instead, the new administration led by President Nana Akufo-Addo created a Diaspora Affairs Bureau in the office of the president, which prioritised diaspora affairs and interests (Mouthaan, 2019). This excluded migrants who were not central to the government’s focus on harnessing the resources that migration provided towards realisation of its development goals. Inconsistencies are not only between administrations but also among government departments and between government bureaucrats and politicians. Implementation of migration policies may stall because of political reasons that include politicians playing to the interests of the electorate in order to win votes. They often shift the blame for non-implementation to state departments such as the Ghana Immigration Service, a key IDOS Policy Brief 21/2024 8 actor whose capacity to fully implement policies on international migration is hampered by allocation of limited resources. These inconsistencies and a lack of political will often lead to omission of some of the consulting experts’ recommendations, a point which was mentioned in an interview with a Ghanaian expert on migration in September 2022. Change of political actors represented by a new government coming into office can change which policies are prioritised or shelved, as the new administration seeks to distance itself from the policies of its predecessor (Mouthaan, 2019). Ghana’s concrete steps: a good start towards safe and orderly migration By identifying migration as relevant to its development agenda and despite the challenges highlighted in the preceding sections, Ghana has taken concrete steps towards guaranteeing safe and orderly migration in line with the GCM and it can build on these steps. It has formulated migration policies that establish local frames of reference in the governance of both domestic and international migration. Ghana needs to be commended for its comprehensive domestic policies governing the various aspects of migration including internal migration and migration induced by climate change. Its Diaspora Engagement Policy reaches out to not only the Ghanaian diaspora but also to the broader African diaspora, including descendants of enslaved Africans in the United States, the Caribbean and the United Kingdom, among others. When the dangers of migration corridors to the Gulf States became a major issue of concern to countries of origin and human and women’s rights organisations, Ghana was among the countries that responded to the dangers faced by women migrants in the Gulf States by banning migration to these destinations in 2017 for three years. The Ghanaian Ministry of Foreign Affairs and Regional Integration signed bilateral labour agreements with Gulf States such as Qatar, United Arab Emirates, Saudi Arabia, and Kuwait. The government also created a desk at Kotoka International Airport in Accra with the goal to curb Ghanaians from leaving for the Gulf States without guarantees of their safety and humane treatment. Policies function as a reminder to the government of its obligations to migrants and citizens under international and domestic laws. The existence of migration governance policies in Ghana enables civil society actors, migrants, and citizens to prod the government towards protecting migrants and upholding their rights and interests. For example, the Diaspora Engagement Policy addresses not only the role of migrants’ remittances and skills in national development, but also migrants’ right to participate in political processes such as national elections. It also seeks to protect the political rights and participation of Ghanaians who hold dual citizenship (Government of Ghana, Ministry of Foreign Affairs and Regional Integration, 2020, p. 16). Although there are challenges with implementation, Ghana’s decision to formulate these policies is commendable because the policies enable civil society and other actors to remind the country of its commitments to international migration governance norms encapsulated in the GCM, which Ghana has committed itself to. With broad frameworks to govern migration, what remains is a correspondingly comprehensive and holistic implementation that prioritises the rights and interests of all migrants regardless of whether or not they have the resources to contribute to the country’s development goals. These policies also provide the parameters within which other actors in the migration sector are expected to conduct themselves, for example, migrant labour recruitment agencies. Specifically, the agenda to promote safe and orderly migration enables the government to punish unscrupulous actors who are involved in illegal recruitment of migrants. The NMP mentions human trafficking seventy-seven times and clearly states that it seeks to enforce and ensure strict compliance with the Human Trafficking Act of 2005 (Government of Ghana, Ministry of the Interior, 2016, p. 7). The Human