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Bystellarchem

NATIONAL AGENCY FOR FOODS &DRUG ADMINISTRATION AND CONTROL

A TWO-DAY WORKSHOP FOR COSMETICS AND MEDICAL DEVICES MANUFACTURERS IN NIGERIA

TOPIC

CHALLENGES IN THE COSMETICS & MEDICAL DEVICES INDUSTRIES

IKPONG OKON UMOH

CHAIRMAN, TOILETRIES & COSMETICS MANUFACTURERS GROUP OF M.A.N

PROTOCOLS

First, on behalf of Toiletries & Cosmetics Manufacturing Group of MAN(T&C-MAN),I wish to thank the National Agency for Foods and Drug Administration and Control (NAFDAC) for organizing this forum and willingly giving us (T&C) an invite to speak our minds on the challenges facing our industry in the course of exercising their mandate.

For some of you who have been active in this industry for the past 15 years,you will agree with me that we are dealing here with a “New NAFDAC”. In the past NAFDAC operated like an overlord reeling out regulations on a take it or leave it manner.

The regulated, (i.e. cosmetics and medical devices manufacturers and vendors) were likened to the criminals and treated on the basis of always “guilty while manufacturing”.

In those days, there was a slogan among the cosmetics SMEs that the “Fear of NAFDAC was the beginning of Good Manufacturing Practice”

Over the years, a few things have happened which some succor and a more conducive atmosphere for the regulated and the regulator to discuss openly and sincerely on issues of regulation. A typical example is this forum, thanks to the new DG, Dr. Paul Orhi, and we hope that some of the reforms he brought would be sustained long after he has stepped aside.

Let’s begin this discuss with some definitions of key terminologies:

What is cosmetics?

US FDA/NAFDAC define cosmetics as

“articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body…for cleansing, beautifying, promoting attractiveness, or altering the appearance” [FD&C Act, sec. 201(i)]. Among the products included in this definition are skin moisturizers, perfumes, lipsticks, fingernail polishes, eye and facial makeup preparations, cleansing shampoos, permanent waves, hair colors, and deodorants, as well as any substance intended for use as a component of a cosmetic product.

What are medical devices?

The American FDA/NAFDAC defines a Medical Device as “an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including a component part, or accessory which is:

intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease, in man or other animals, or
intended to affect the structure or any function of the body of man or other animals, and which does not achieve its primary intended purposes through chemical action within or on the body of man or other animals and which is not dependent upon being metabolized for the achievement of any of its primary intended purposes.”

In this lecture I am going to limit my focus to the cosmetics industry where majority of participants here operate. Most Medical devices are imported into this country with very few being manufactured here if any and therefore may have a regulatory framework that applies to all imports.

Generally speaking, industries in Nigeria are faced with very big challenges which have been documented by the Manufacturers Association of Nigeria (MAN), and may be listed as follows:-

Poor and deteriorating infrastructural services, compounded by collapsed electricity supply which impacted negatively on capacity utilization;

Deepening weak domestic demand arising from lack of consumer purchasing power;

High and unplanned inventories caused by lack of patronage and distress in aggregate domestic demand;

Smuggling and Unbridled influx of cheap imports of sub-standard, fake and substandard products, including dumping of all manner of finished goods-all in the name of trade liberalization;

High costs of funds arising from depreciation of the Naira against major currencies coupled with high lending rates and extreme difficulties in accessing credit for working capital, particularly by small and medium-scale industries;

Policy inconsistency and anomalies in customs duty while imported finished goods witnessed a corresponding reduction in duty payments.

Continuing harassment of companies by some state and local governments over unauthorized multiple levies,taxes and charges in spite of the clear position of the law on the matter;

Problems of supply of petroleum products, particularly AGO (diesel) LPFO (black oil)

Non completion of the development of core industries particularly the Petro-chemical as well as Iron & Steel Industries;

Dearth of qualified skilled middle level manpower worsened by the decaying educational system;

Slow rate of technology acquisition stemming from low investments in Research and Development and absence of the needed collaboration between the various government research institutes and the Universities on the one hand, and the manufacturing sector on the other;

Cumbersome port administration that hinders the attainment of the 48-hour cargo clearing at the ports; etc. (MAN, 2008, MAN,2010,and Jamodu,2010:47)

A close look at this list of challenges shows a clear omission of regulatory challenges as if they did not exist and this lecture/presentation will try to fit this missing link and suggestions on the way out, through the eyes of cosmetic practitioners and bench-mark practices all over the world.

What are the regulatory challenges faced by the Cosmetics industries in Nigeria?

As key players in this subsector of the economy, we have identified six main challenges due to the regulatory framework we are subjected to and we shall x-ray each of them in turn as follows:-

MULTIPLE REGULATION:

The Toiletries & Cosmetics industry all over the world wide is under the purview of designated Government Agencies, like The Foods &Drug Administration (FDA in the USA); The National Agency for Foods and Drug Administration and Control (NAFDAC in Nigeria)

It’s been observed that in the past 4-5 years, the number of Government Agencies regulating our industry is now on the rise.

We now have in addition to NAFDAC,

Standards organization of Nigeria (SON),

National Environmental Standards and Regulations Enforcement Agency (NESREA),

Lagos state Environmental Protection Agency (LASEPA),

Weights and Measures,

Consumer Protection Council (CPC), etc.

The regulatory framework crafted and used by these agencies are more or less very similar to the regulatory framework of NAFDAC even though they may be called different baptismal names e.g. SON –Mandatory Conformity Assessment Program (MANCAP) and LASEPA -Chemical Storage Permit, to mention a few.

All these overlapping regulations end up in payments of money to these various agencies for the certifications and permits that do not necessarily add value to the product or the company. The process of compliance for each of these agencies process gulps man-hour, management time and un-receipted sums of money, all of which constitute a big drain on the meager resources of the T&C MAN members who are mainly SMES.

SUGGESTED SOLUTIONS:

NAFDAC should enhance the value of GMP certified premises/facilities so that new products development can start and progress to market testing with initial submission of raw materials to be incorporated in the new product for the purpose of screening.
The industry can assist NAFDAC by embarking of self-regulation and engaging the agency in regular discussions on safety and usage of restricted/ controlled Raw materials.

REQUIREMENT FOR A STAND ALONE BUILDING

Beside pre-market registration, there are other requirements for startups which appear very cumbersome and discourages new entrants into the business.

Such guideline include, having a stand-alone factory building, which must have facilities such as laboratories, cloakrooms, air-conditioned storage facilities for raw materials, finished goods and packaging materials, water supply and treatment facilities, high caliber personnel to man production, quality control e.t.c.

This requirement is strictly a requirement for Drugs, Foods and Food supplements, and should not be applied to cosmetics

In today’s Nigeria where unemployment is on the increase and our tertiary institutions are churning out youths in their thousands, this regulatory requirement is too cumbersome and constitutes a disincentive for our fresh Science Graduates who would like to venture into cosmetics manufacturing and therefore needs to be reviewed in line with the realities on the ground, to encourage new entrants.

In T&C Manufacturers Group, we believe that it is possible to manufacture quality cosmetic products under adequate sanitary standards to avoid contamination without necessarily insisting on stand-alone factory building which may gulp the meagre start-up capitals.

Our position is corroborated by the fact that the history of many cosmetics companies around the world including the big multinationals of today indicates very modest beginnings, often times from the garages or backyards of their founders, e.g George Johnson the founder of Ultra sheen, Charles Revson of Revlon, ESTEE LUDER,Z SKIN COSMETICS,TIFFANY, William &James Lever (UNILEVER)

One of our member companies who we interviewed recently for our current edition of “T&C NEWS SPLASH” is said to have started manufacturing a petroleum jelly based product in his kitchen with less than Three Thousand Naira (N3,000) start-up capital about 13 years ago. Today the industry now has over 25 different products and employs over 3,000 workers.

This is a talent and a dream which would have been dead on arrival if the Stand alone requirement was in force.

SUGGESTED SOLUTIONS:

NAFDAC should simplify this requirement to enable new start –ups to use a section of their residence for a period of 3-5 years. This will also encourage some retired NAFDAC staff and civil servants who would like to venture into cosmetics manufacture.

REGISTRATION OF DIFFERENT PACK SIZES:

The cost elements associated with the registration of a cosmetic product in Nigeria ranks among the highest in the world.

It is noteworthy that Cosmetics business everywhere including Nigeria is driven and spiced by variety especially different pack sizes.

Offering the same product in different pack sizes is a market strategy to reach out to try to satisfy all spectrum of consumers with varying purchasing powers. For example, you can put into the market a Hair& Scalp conditioner product in 500g pack, 250g, 150g and even 100g to target Professional salons, home users, students in the campus and secondary school pupils with low cuts. The more variants you have spread along demographic lines the bigger your market is likely to become.

In recent times NAFDAC has introduced charges for different pack sizes of the same product filled from the same vessel and packed in similar plastics materials.

What obtains in other clime is worth mentioning here.

Unilever (Uk, Europe& America) has close to 50 variants of impulse spray fragrance. These variants of impulse are being sold everywhere all over the world. The purpose is to satisfy customers’ choice preferences in selecting which variant suits their passion.

Why is Unilever not offering these products in Nigeria? Is there any company in Nigeria that can offer such a broad band of single product selection?

The answer is NO. To manufacture and sell 50 variants of Impulse in Nigeria, Unilever, would pay so much in time and cash to register each variant and would rather concentrate effort and funds on areas of comparative advantage.

It is also common knowledge that any local manufacturer of cosmetics that attempts to adopt this robust brand strategy cannot survive the rigour of registration and its financial implications. If any company tries it, that company may have to file for Bankruptcy protection after paying all prescribed NAFDAC fees? It is as bad as that!

The T&C Group of M.A.N has made several representations on the negative impact of this exercise to NAFDAC, we have gotten some verbal promises of “better days” but the reality on the ground is that nothing has changed.

SUGGESTED SOLUTIONS:

We want to renew our appeal to NAFDAC to remove this requirement for different pack size registration and payments so that manufacturers can satisfy the different yearning in our market without being straddled in multiple registration and charges.

ADULTURATION &FAKING:

This used to be a nightmare for many local manufacturers of cosmetics. We can say here that this has reduced drastically in the past three years. This may be attributed to the improved corporation between the NAFDAC, the industry and the law enforcement agents. There is need to keep the flag flying and watch and pray that this crime does not return in full force.

FREQUENT CHANGES IN REGULATORY REQUIREMENTS AND CHARGES:

While fully aware that change is the only thing that is constant, the cosmetic industry is constantly facing the challenge of frequent changes in regulatory requirements.

The list of requirements for inspection, registration and renewals gets longer every year and so are the charges in geometrical ratios.

With our NAFDAC, Every time there is breaking news and the manufacturer is caught by surprise on some of these changes.

As stakeholders, we deserve to be carried along and our opinions sought on very sensitive changes especially those that can affect our lead time and budgetary allocations

SUGGESTED SOLUTIONS:

There is need for improved collaboration and communication between the NAFDAC and the Toiletries &Cosmetics industry on one hand and the various sections of the agency on the other. This can streamline the requirements, and foster understanding and easy of compliance.

CONCLUSION:

Personal Care Products is one of the fastest growing businesses in the world. It is estimated that by the year 2017,the Global personal care market would have grown to about USD 630 (Eur 487) billion (N126 trillion) in value (Lucintel,2012)

In Africa, countries like South Africa and Nigeria, the two biggest economies, have shown very strong growth in the last 10 years and each holds out a promise to achieve stable and continuous growth in the years to come.

In South Africa, the indigenous cosmetic companies have made significant contribution to this growth. In Nigeria, the major beneficiaries of this growth are the foreign- made cosmetics. These products occupy almost all the major shelves in the open markets and supermarkets and are estimated to have a market dominance of about 90%.

If the local cosmetics products in Nigeria must partake in the current and future boom, things have to change for the better. The speed of reaching the market with new products will continue dictate and define competition and success in the market place.

Between the local cosmetics manufacturers and the Market, NAFDAC holds the Ace. The Agency has already initiated that change by willingly inviting us to make known the challenges the manufacturers face

By so doing they have demonstrated that they are ready to “walk the talk” and leverage its long term performance indices on collaboration and cooperation with the stakeholders.

We, in the cosmetics industry request that NAFDAC should embrace and adopt international best practices in the exercise of its mandate for the cosmetics and Medical Devices industries. Make deliberate effort to simplify the requirements and adopt Post Market Surveillances (PMS) instead of Pre-Market registration so that our products can be competitive and every stakeholder can achieve a win –win situation for our industry and for our country Nigeria.

THANK YOU.

Bydavidking

NEW EXECUTIVE ORDER ON EASE OF DOING BUSINESS

NEW EXECUTIVE ORDER ON EASE OF DOING BUSINESS-MEASURES FOR COMPLIANCE TO ENHANCE GROWTH OF SMEs IN NIGERIA

IKPONG UMOH

Chairman /Managing Director, Stellarchem Nigeria Limited

Chairman, Toiletries & Cosmetics Manufacturers Group of M.A.N

Date: August15,2017

PROTOCOLS:

On Thursday 18 May 2017, the Acting President Prof Yemi Osinbajo signed an executive order on ease of doing business in Nigeria. In principle, the order sought to address certain shortcomings in Government circles and position Nigeria as the preferred investment destinations. The order can be broken down and treated under the following heading:

Transparency in MDAs

The Order seeks to promotes transparency in the dealings of Ministries, Departments and Agencies (MDAs) by directing them to publish a complete list of all requirements for obtaining permits, licences and approvals, including fees and timelines, in their premises and on their websites within the next 21 days.

Default Approvals

To further deal with lack of openness and backhand deals MDAs must communicate with applicants by at least two methods, and any approvals for applications not received within the specified period will be assumed to have been granted to the applicant by default. Similarly, any rejections must be communicated immediately to the applicant with valid reasons.

One Government Directive

The Order promotes a “One Government” policy. No private applicant will be asked to produce or submit a document issued to it by the FGN as part of an application process if an original of the document is in the possession of another FGN MDA. A photocopy will be sufficient. Instead, FGN MDAs are now required to bear the responsibility of seeking verification or certification directly from the issuing MDA.

Entry Experience of Visitors and Travellers

Visas request for persons travelling to Nigeria from other countries will be issues within 48 hours and the processing of issuance of visas on arrival shall be carried out in a transparent manner. Our airports and sea ports are not excluded. There will now be only one centrally located interface for agencies and touting has been strictly prohibited.

Any official caught soliciting or receiving bribes from passengers or other port users shall be subject to immediate removal from post and disciplinary as well as criminal proceedings commenced in line with extant laws and regulations.

Ports Operations

All agencies currently physically present in Nigerian Ports have been directed to harmonise their operations into one single interface station in one location in the port and implement as a single joint task force at all times.

The Apapa Port shall resume 24-hour operations within 30 days from today and each Port in Nigeria shall assign an existing export terminal to be dedicated to the exportation of agriculture produce within 30 days of this Order in order to jumpstart our international trade and economic activity.

DRIVING FACTORS FOR THE EXECUTIVE ORDER.

1.Our economy slipped into recession in Q1,2016 at -0.36% and has not recovered fast enough as was predicted and trumpeted by Government. Its currently standing at -0.56% as at Q1,2017

2.Macroeconomic indicators point to disequilibrium. Inflation figure in December, 2016 was 18.6%, decreasing to 17.2% in May 2017. Inflation from a layman’s point is the general increase in prices and the fall in the purchasing power of the Naira (money). this translates into the fact that the higher the inflation in the economy the less goods and services the money you have at hand can purchase and vice versa. The ideal would be a single digit inflation hovering between 4-8%

3.increasing Poverty Level and unemployment in Nigeria is alarming. The recent UN reports says “Nigeria, with a population of about 185 million, is the most populous nation in Africa and the seventh most populous in the world. Her population will be approximately 200 million by 2019 and over 400 million by 2050, becoming one of the top five populous countries in the world.

“Nigeria is one of the poorest and most unequal countries in the world, with over 80 million or 64% of her population living below poverty line. The situation has not changed over the decades, but is increasing. Poverty and hunger have remained high in rural areas, remote communities and among female-headed households and these cut across the six geo-political zones, with prevalence ranging from approximately 46.9 percent in the South West to 74.3 percent in North West and North East.

The Federal Bureau of statistics(FBS) confirmed that about 4.85 million jobs were lost between 2015 and 2016.The Manufacturers association of Nigeria has determined from its current survey that about 226 companies have either closed shops or downsized within the same period.

Nigeria’s loss in Global competitiveness is a source of worry. The Global Competitiveness Index (GCI) 2016-2017 measures and ranks competitiveness of 138 economies. In the recently released report, Nigeria, the giant of Africa dropped three notches from 124th in 2015-2016 to 127th in 2016-2017.on the other hand, other countries in Sub-Saharan Africa, like Mauritius (ranking 45th) and South Africa (47th) remain the region’s most competitive economies, climbing two places and one place, respectively. Rwanda (52nd) comes third in the region.

5.Closely related to Global competitiveness is the ease of doing business (EODB).Based on the latest ranking released by the World Bank, Nigeria is ranked 169 among 190 countries. Some analyst see this rank as being an improvement on the previous position of 170 out of 189.When compared with other countries in the sub-region like Ghana (108),Mali (141) and Togo (154),there is nothing to cheer about.

SCORE CARD OF COMPLIANCE BY MDAs

Barely three months after signing the EODB into law, what has changed for all to see that we are moving forward or not.

Some agencies of the government have convened stakeholders meeting and activities in a bid to carry out the executive order and to try to prove their readiness to help achieve the EODB.

I have had the opportunity to participate in two workshops, one organized by the Nigeria customs service (NCS ) and another by Standards organization of Nigeria (SON)

NCS acknowledged that Nigeria’s low ranking of 14th out of 15 Economic Community of West African States (ECOWAS) economies and 182nd out of 190 economies worldwide in the ‘Trade Across Borders’ indicator must be changed .To this end they have introduced some reforms to achieve 24-hour cargo clearing like a shift system for its officers and men in order to achieve a round the clock operation and scheduling and coordinating the Mandatory Joint Examinations and Sign-off Form to ensure that there is only one point of contact between importers and officials.

They were quick to admit that they had some problems like inadequate power supply, bad roads, gridlock and faulty scanners might truncate the shift system.

Some port users alluded to the fact that the low ranking is caused by avoidable delays occasioned by cumbersome documentations, Nigeria customs required about 14 documents to clear goods while in Rwanda you require only 5. NCS however denied any wrong doing, opining that no delay whatsoever is caused by Customs. Most of the delays are actually caused by importers’ false declaration and lack of integrity. When your declarations are correct, within six hours, your goods are released.

Our experience as importers of chemical raw material is that not much has changed. There are still cases of being cleared at one point and by a group of officers only to move to the gate and an order comes from above that you have to come back for reexamination. The point here is that custom has three major functions namely, trade facilitation, anti-smuggling and revenue generation. Of these three, revenue generation remains the most attractive. Given a Revenue target of about 1.1Trillion Naira for 2017, their other mandate of trade facilitation, which would help SMEs do business with ease has to wait while the men and officers make money for the government and for themselves.

In the case of SON,the stakeholders were intimated with the repealed act now called Standards Organisation Of Nigeria Act, 2015 ,Act No. 14.

This act now empowers them to become a full-fledged regulatory agency and enforce the following regulatory requirements :

The mandatory SONCAP PROGRAMME (Offshore Conformity Assessment Programme) for imported goods.
The mandatory MANCAP Programme (Mandatory Conformity Assessment Programme) for locally manufactured products.
The Mandatory Products Registration Programme etc.

In addition, they are empowered to charge fees as they deem fit and appropriate.

It would appear that every Agency of Government interprets ease of doing business as they understand it. From the few seminar and fora, I have attended, the common denominator of ease of doing business translates into ease of making money for the government agencies and some don’t mince words telling the participants as such.

On the issue of compliance with the executive order, some agencies are said to be defaulting by providing telephone lines and emails that are not working. The Vanguard Newspaper investigation listed NCS, the Nigerian Immigration Service, Nigerian National Petroleum Corporation among others as some Government agencies with dysfunctional contact telephone lines. I recently had an encounter with an agency that gave me 10 lines to contact them if I experience any problems on their website. None of the lines is working ,so how have they complied with EODB These agencies should come clean and rectify those avenues of communication.

HOW WILL SMEs FARE IN THE EXECUTIVE ORDER?

According to the world Bank Group, EODB sheds light on how easy or difficult it is for a local entrepreneur to open and run a small to medium-size business when complying with relevant regulations.

This index measures and tracks changes in regulations affecting 11 areas in the life cycle of a business: starting a business, dealing with construction permits, getting electricity, registering property, getting credit, protecting minority investors, paying taxes, trading across borders, enforcing contracts, resolving insolvency and labour market regulation.

In this definition, the SME is the focus not the multinationals or the foreign investors. while the Executive order can ease the registration of a new business name ,the other areas that disadvantage the SMEs are not addressed.

These areas with particular reference to Cosmetic SMEs are

MULTIPLICITY OF REGULATORY AGENCIES

Incidence of multiplicity of regulatory agencies has always resulted in high cost and difficulty of doing business. The cosmetic industries in all over the world is statutorily regulated by a Food and Drug Agency as FDA in the United states and by The National Agency for Food and Drugs Administration (NAFDAC) in Nigeria. The recent empowerment of Standards organization to regulate industries already regulated by NAFDAC is a double regulation and needs to be addressed by the executive order. We have the impression that the repeal of the recent SON act 14 ,2015 did not have wide consultation and implementing as is definitely will wipe out our fragile SMEs.

UNFAIR COMPETITION TACTICS/MANUPULATED TARIFF

Some basic and bulk Raw Materials for manufacturing quality cosmetic products not sourced locally and classed under HS Code 3402 are currently levied 20% +5%VAT as if they were finished products, in gross violation of CET rules, which stipulates 0% for Essential Social goods;5% for Raw Materials;10% for Intermediate goods;20% for Final consumption goods & 35% for Specific goods for Economic Development. This high duty was a conspiracy between some multinationals among us who advised government through MAN to impose that duty in order to protect their investment as they suspect that some unscrupulous people hid under that tariff heading to bring in finished soaps.

With the duty regime in effect, there is acute scarcity of the basic materials and the wheels of T&C industries slowly grounding to a halt. The executive order on ease of doing business should look into this anomaly and save our members business from eventual collapse

LACK OF GOVERNMENT PROTECTION.

The imports prohibition list was introduced by the Federal Government before the advent of CET and aimed at preventing the importation and dumping of products which can be manufactured in Nigeria.

In Government’s thinking all the companies will be able to increase their capacity utilization and achieve good market share.

T&C companies in Nigeria have the capacity to produce finished cosmetics products sufficiently for local consumption and for export just as they did in the 90s. We need government protection by prohibiting the importation of all kinds of cosmetic products into Nigeria, other bilateral agreement entered into notwithstanding.

d). HIGH COST OF FUNDS/ACCESS TO LOANS

Interest rates in Nigeria is hovering between 18% to 25% and yet it’s not easy to raise capital for investment in agriculture or in industry. SMEs need capital to fund their operations. Existing institutions like the BOI and the Commercial Banks, have short-changed the SMEs in their funding needs by insisting on overbearing collaterals and life-threatening conditions before granting them loans. BOI insist on 250% collateral, while commercial banks prefer to lend to government by investing in government bonds. Nigeria being a country in dire need of development cannot overlook the important role interest rate could play in invigorating SMEs. This is probably the reason The Collateral Registry Act ,2017 was made However the idea is good, but implementation is going to pose a big challenge for the banks.

The ease of business ranking as put together by the world bank group has the SME as its focus not for the fun of it, but because SMEs have the potential to grow a country’s GDP out of recession in a more sustainable way than Foreign Direct Investment (FDI) According to word bank data the percentage contribution of SMES to GDP is as flows.

High income countries :50%-55% GDP (UAE, Singapore, Qatar, Denmark, Germany France,many of the EU countries)

Middle income countries: 35%-40% GDP (china, India, Brazil, Malaysia ,Angola, Thailand ,Ghana)

Low Income countries : about 15% GDP (Cambodia, Kenya, sub Saharan African countries)

CONCLUSION:The executive order, looks and sounds very good but it appears to have missed the focus on SMEs and concentrated 90% on the convenience of foreign investors. The Presidential Enabling Business Environment Council (PEBEC) need to do wider consultations and involve the genuine SME stakeholders in the council. If our economy is to recover very fast and in a sustainable way then we need an Executive Orders that will take a cue from the World Bank Group and favour the local SMEs 100%.

THANK YOU!!!

NATIONAL AGENCY FOR FOODS &DRUG ADMINISTRATION AND CONTROL

NEW EXECUTIVE ORDER ON EASE OF DOING BUSINESS

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