Companies Must Submit Succession and Training Plans by February 28

The situation

The Petroleum Commission’s Localisation Directorate in Ghana now requires all companies in the oil and gas sector to submit a succession and training plan to the Petroleum Commission by February 28, 2019 – or face a fine.

A closer look

As part of their required duties, employers must submit the below template forms, which they can obtain through their immigration provider:

• Succession form. The succession plan form requires information such as the foreign worker’s job description and the name of the local employee that will be succeeding that role.
• Training plan. The training plan form requires a description of the training sessions the local employee will undergo so that their skills match those of the foreign national when the handover takes place.
• Successor or intern assessment form. This form assesses the progress in training a successor to take over for a foreign worker.
• Recruitment and employment plan. This form outlines the organization’s recruitment plans.

 

Impact

Employers that fail to submit their succession, training and other relevant forms by February 28, 2019 are liable for a fine until they comply with the requirement.

Background

• Continued focus on local workers. Prior to 2018, Ghana did not enforce strict rules on the hiring of foreign nationals. However, in 2018, the Localisation Directorate set out requirements for companies in the oil and gas sector that shifted the climate to focus on the protection and development of local workers' skills.
• How the plans work. A succession plan is a document outlining how the skills and duties performed by each foreign national will be transferred to a local employee. There is one plan per employee per position. Employers use this with a training plan to teach the local employee during the period that the foreign national performs the work.
• Trend in Africa. Succession plans are a growing requirement in sub-Saharan African countries; currently, in addition to Ghana, they are required in Nigeria, where the government frequently conducts audits to ensure that companies are complying with the requirements.

Looking ahead

Fragomen anticipates that the Localisation Directorate will continue to develop more policies to protect local workers. Companies should expect workplace audits as the Localisation Directorate monitors the implementation of the localization rules in the oil and gas sector. Fragomen will report on announced audits and other relevant developments.

This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].