In connection with our ongoing study, analysis and commentary on the China Development (CDB) loan facility, we may issue brief alerts on serious matters that come up. This is to ensure that such urgent matters do not get buried under the weight of detail in the upcoming follow-up report to our initial comment on the subject. 1. Sekondi Industrial Estate Policy Confusion This week we are calling the attention of the government to the Sekondi Industrial Estate, one of the anchor projects in the Western Corridor Infrastructure component of the CDB loan facility. In February 2011, the Ghana Free Zones Board issued a license to China Hasan International Holding of Hong Kong to become the main public-private-partnership (PPP) partner on this project. The decision to award the license to China Hasan comes as a bit of a surprise seeing as all the public plans prior to this action pointed to a partnership between government of Ghana, on the one hand, and the China Africa Development Fund (CADF) and the Bosai Minerals Group, on the other hand, to develop the Sekondi Industrial Estate (“SIE” or “Estate” hereinafter) on the back of a proposed $1.2 billion alumina processing plant. Observers are therefore confused that the CADF-Bosai project receives no mention at all in the government’s strategy paper developed for the CDB Master Facility. Months before the Sekondi Industrial Estate project was drafted for inclusion into the CDB’s Master Facility Agreement with Ghana in August 2011, the official position of the Ministry of Trade & Industry was that the Estate was to be anchored on the CADF-Bosai – Government of Ghana (GoG) partnership. It would be good for the Ministry of Trade to clarify if the CADF-Bosai funded alumina plant will be going ahead, if it is on course, and whether it will still serve as the hub of the Sekondi Industrial Estate. And if not, to tell us what is the latest status of the alumina refinery. 2. Did Government Conduct Due Diligence Prior to Contract Award? More important than the seeming policy confusion is the question of whether China Hasan has the capacity to execute what has been announced as a $4 billion or $2 billion project depending on which report you believe. During the signing of the MOU in Beijing, at the China – Ghana Friendship Forum, $2 billion was mentioned. In subsequent announcements and media reports, $4 billion was the quoted figure. Seeing as $100 million of the CDB master facility has been allocated to the infrastructure requirements (common access roads etc.) of the Sekondi Estate (1000 hectares designated as a "free zone"), it is very important for government to come out quickly to reassure Ghanaians that it has conducted thorough due diligence on China Hasan and is thus confident of the Hong Kong – based company’s ability to deliver on its promises should the government spend the $100 million it is borrowing from CDB to develop the basic infrastructure for the estate. Particularly so when questions have been asked by organisations like IMANI about the quality of due diligence being performed by government on projects presented to the CDB for financing. As already discussed in our previous publications on the subject, any failures of due diligence would slow disbursements from the CDB loan facility and undermine the government’s focus on infrastructure in 2012 – 2013. At any rate, due diligence is required to ensure that even disbursed funds are not misapplied. 3. Why this Project can Threaten the CDB Tranche A1 Loan Why is IMANI worried about the capacity of China Hasan to deliver the Sekondi Industrial estate? For the avoidance of doubt, government is borrowing the SIE subsidiary loan from the CDB on the premise that the infrastructure the borrowed money is going to be spent on is needed as the foundational prerequisite of the industrial estate. If it turns out that the PPP partner/lead project financier and developer, in this case China Hasan, has no capacity to deliver on its promises the entire western corridor infrastructure component could be endangered, since the overall Western Corridor infra program is an integrated one. IMANI has developed serious doubts about China Hasan International Holding’s capacity and track record following its own checks and analysis of the company’s background, pedigree and antecedents. 4. Can we Risk the CDB Tranche A1 Loan with Hasan International? According to Hasan International’s website (en.hasan.cc), the group’s focus is on: “the faith of “Creation, Amalgamation and Confidence”, Hasan adheres to the developing idea of seeking break-through in creation, acquiring development in amalgamation and promote cooperation by winning confidence. The abundant cultural background is orienting Hasan’s prospective thinking, compatible motion and international development in a spanning way (DSW), as well as helping Hasan to fit in Africa rapidly.” According to Hasan’s Chairman, Zheng Gang, one of only two members of the company’s management team mentioned in all available public documents referring to the company, his business: “Hasan International has its own distinct cultural characteristics of the so-called "All rivers run into the sea. All soil forms the mountain.” This is the faith I have always adhered to! It looked as if empty, but it is not true. For example, we have come to Africa; we have been accepted by our happy African friends, which are "All rivers run into the sea.” They had accepted the rules of the U.S. and Europe and even the "whip" with no reservations, now they still accommodate the Chinese friends, and accommodate the Hasan International with most charitable spirit and magnanimity. It can be said the culture of Hasan International and Black Africa integrate each other and learn each other on the top domain.” These grand statements notwithstanding, our investigation so far has uncovered scant trace of Hasan’s ability to raise funds from the capital markets, much less accomplish projects of the scale of the Sekondi-Takoradi Industrial Estate. Indeed, we have established that Hasan’s much touted project in Angola, the only one that it claims to have INITIATED so far, has NOT progressed much beyond CONCEPT stage, probably due to lack of financing. This matter is easily confused because the name of the project: “nova vida” bears the same name as an older and ongoing project started in the late 1990s by the Angolan government that has seen several houses built over two phases. True, private companies like Aurecon have been involved, but financing has come primarily from Angolan public funds. Hasan did NOT raise the funds for Nova Vida. The Hasan Angolan housing concept, which dates to 2009, has therefore, from what we have learnt, not yet materialised in Angola. Hasan's existence, in actual fact, does not appear to pre-date 2009. Hasan mentions China Jiangsu International (http://www.zjgj.com/) as its partner in the Luanda Nova Vida project. The problem is that the only verifiable residential housing activity undertaken by Jiangsu International in Luanda took place in 1999 and since then Jiangsu has not been engaged in the Nova Vida development. Jiangsu International, recently awarded a contract in the Palace of Justice project in Luanda (financed by the Angolan government), has no commercial partnership for real estate development with Hasan, nor is the Nova Vida project listed in its portfolio. To all intents and purposes, it is not developing the Nova Vida project with Hasan, contrary to the latter's claims. When a real estate agency in Hong Kong was asked to send us a list of tenants on the 2nd floor of the somewhat rundown Teng Fuh Commercial building (picture on IMANI's website) on Hong Kong’s Queen’s Road (the address supplied on Hasan’s websites and other documents we have sighted), the agency sent a catalogue of SME export-import businesses dealing in items such as jewellery and textiles but curiously did not include Hasan. The only conclusion to be drawn is that Hasan is so small that its office in the commercial building has evaded the attention of even a leading real estate research firm. 5. What Exactly do you want Government to do? We have two humble requests to make of government: A. To reassure the people of Ghana that it has conducted thorough due diligence on Hasan International and is satisfied with what it has learnt; B. Or quickly bring in a third, more credit-worthy, partner to bolster the Sekondi Industrial Estate elements of the Western Corridor Infrastructure transaction documents being used to secure the relevant tranche A1 loans from the CDB. Everyone knows the CDB has loads of money and are interested in doing business with Ghana; we shouldn’t ruin our chances by poor feasibility planning or, indeed, poor negotiation. We will keep the good people of Ghana updated if any other urgent matters concerning the CDB facility crop up, even as we continue to examine the various transaction documents and monitor ongoing developments.