Harnessing Regional Potentials: the Private Sector and the Nigerian Economy -By Alaba Lawson

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Alaba Lawson

The State of the Nigerian Economy

The nation’s economy continues to show slow signs of improvement, as confirmed by several economic indicators and reflected in the growth of our Gross Domestic Product (GDP). The International Monetary Fund (IMF), in its recent forecast report for 2019, predicts a 2.3 per cent GDP growth for Nigeria in 2019, which indicates a positive outlook. Inflation has fallen for sixteen consecutive months, from 18.72 per cent in January 2017 to 11.61 per cent in May 2018. Although this is commendable, it is still double digits inflation and certainly not good enough. This implies the need for more work to be done on the economy.

Monetary Policy Rate of 14 per cent has remained unchanged for 23 months and foreign reserves have risen, to a four year high of $47 billion by May 2018. The naira to USD exchange rate of N360 to $1 has remained stable in the parallel market and N305.8 to $1 at the official CBN rate. While these are encouraging signs, the Nigerian Association of Chambers of Commerce, Industry, Mines and Agriculture (NACCIMA) is of the view that more needs to be done by government to create a more stable and enabling environment for business to thrive. In all of these, we must acknowledge that the Economic Recovery and Growth Plan (ERGP 2017-2020) has proved to be a veritable platform for recovery. The vice president, Professor Yemi Osinbajo, at a Business Summit tagged “Exploring Investment Opportunities in Nigeria and the UAE”, in Dubai just a few days ago, precisely on Saturday July 21 said “the ERGP was conceptualised to place the Nigerian economy on the path of stronger and more sustainable and inclusive growth.” And the ERGP is being implemented to keep the economy on the path of “sustainable economic growth and global competitiveness”. Within the frame work of the ERGP and in close cooperation with the private sector, we have witnessed some achievement in the strategic areas. The private sector is therefore looking forward to closer engagement with government in the forthcoming phases of the ERGP.

The Unemployment Situation

The Nigerian unemployment rate is said to be 18.8 per cent. We all know this is certainly a conservative estimate. Let us be frank with ourselves and lay aside these indicative figures. Millions of our people, especially young people, are unemployed and we must to do something about this. Hardly a day passes when people like you and me will not receive a CV with the request for a job. It’s particularly worse among the youth. This is not acceptable. The implications are too grave for us as a nation, with our growing population now nearing the two million mark. We therefore need to address the situation. And let me, in this context, draw our attention to the Next Generation Nigeria Report of 2010. It was the work of an independent Task Force chaired by former finance minister, Dr. Okonjo Iweala. Others on that Task force were Professor David Bloom; James Gamble, a professor of Economics and Demography at Harvard School of Public Health; Professor Pat Utomi; Mr. Frank Nweke, former minister of Information; Alhaji Lamido Ado Bayero; Mrs. Maryam Uwais; Mr. Donald Duke, a former governor of Cross River State and Lord David Treisman, a prominent British Banker, politician, former minister, and member of England’s Football Association from 2008 to 2010. The task force was supported by the British Council and Harvard, funded through a British Council grant and backed by an array of academic and research teams. The Report, which was released in 2010 can be found online; please check it out. It examined Nigeria through the demographic lens. Let me briefly refer to some of its key findings and recommendations.

The report says that Nigeria stands at the threshold of the greatest transformation in its history. That by 2030 (just about 12 years away), it will be one of the few countries in the world that has young workers in great supply. Youth, not oil, will be the country’s most valuable resource in the twenty-first century. It continues and says that Nigeria stands ready to collect a substantial demographic dividend if it continues with its recent economic growth, it improves health standards and harnesses its growing work force; the average Nigerian income will be as much as three times higher by 2030 and over 30 million people will be lifted out of poverty. If Nigeria fails to collect its demographic dividend, it’s prospects will be bleak and could be catastrophic, in the worse case, Nigeria will see growing numbers of restless young people frustrated by the lack of opportunities, increased competition for jobs, land, natural resources and political patronage, alongside ethnic and religious conflict. In other words, our country could face a demographic disaster. That Report counsels that we must invest in our young people by equipping them for life in a modern economy through good education and healthcare. It also stresses the need to prioritise the acquisition of skills and expansion of vocational training that can lead to employment. And notably the report equally indicates that Nigeria needs to create almost 25 million jobs over the next ten years.

This is a challenge for all of us, and it is why in NACCIMA we have given utmost priority to capacity development and training for the youth, as well as improving the capacity of small and medium enterprises. This is because SMEs have been identified as veritable platforms that can provide jobs for millions of our young people, just like China did and was able to lift about three hundred million people out of poverty within a decade. We should therefore increase the capacities of our SMEs to enable them to thrive, by providing incentives and access to capital to expand their productive capacities, so they can make significant contributions to the provision of employment to our people, especially our youth.

Creating Employment Opportunities Through the NACCIMA Youth Entrepreneurs (NYE)

NACCIMA launched the NACCIMA Youth Entrepreneur initiative not too long ago in order to reorientate young people towards self-employment and the development of their entrepreneurial skills. We are now in partnership with other stakeholders such as Nigeria Export Promotion Council (NEPC), Federal Institute of Industrial Research, Oshodi (FIIRO) to encourage the youth to take advantage of relevant programmes to go into entrepreneurship. Currently, in cooperation with NEPC, a training Programme is on-going in the area of the export of non-oil products. We are very encouraged by the response of our youth and we think this is one of the strategies to address the issue of unemployment.

Also we have just been recently certified as an Approved Training Partner (ATP) of CQI (Chartered Quality Institute of London). This is a project facilitated by United Nations Industrial Development Organisation (UNIDO) under the Nigerian Quality Infrastructure Project sponsored by the European Union (EU). For us this is a major achievement because only two institutions have achieved this status in Nigeria – our association (NACCIMA) and the Standards Organisation of Nigeria (SON). Under this programme at the NACCIMA headquarters, we now train our young people for CQI certified courses. This is a concrete way of equipping them with an internationally recognised certification process for employment in reputable companies, both at home and abroad. And also in helping to provide the missing gap of skilled personnel who are required to turn out quality products and services that are in harmony with international standards.

The Africa Continental Free Trade Area (AfCFTA) Agreement

This is an issue on the top of our national agenda in the field of trade. And we must therefore say a few words about it. The Africa Continental Free Trade Agreement aims to create a market of 1.2 billion people with a GDP of USD$2.5 trillion, with over 40 African countries signing to it. Nigeria was deeply involved in the negotiations leading up to the Agreement and indeed we chaired the the process. We cannot afford to be excluded from a common African market because it a veritable strategy to raise the competitiveness of African economies in the global economy. Clearly, NACCIMA’s position is that our dear country should sign the completed AfCFTA Agreement. We as a nation have been closely and long involved in the vision of an African Free Trade Area right from the establishment of the Organisation of African Unity (OAU). Let me briefly recall the relevant part of what our first prime minister, Sir Abubakar Tafawa Balewa said on the occasion of the creation of the OAU in Addis Ababa, Ethiopia on May 1963: “…if we are to establish an African common market we shall overcome many difficulties and we shall be in a position to stand on our own in relation to other parts of the world. My fears of being colonised will disappear if we are to establish this African common market.” That was our visionary prime minister, the golden voice of Africa, speaking 55 years ago. So we cannot afford to be missing in the AfCFTA Agreement. It is worthy of note that nation-wide stakeholder consultations have been held at the various geopolitical zones and consensus has emerged that Nigeria must be part of the AFCTA for numerous reasons, including the fact that it’s is indeed also a platform for our SMEs to be integrated into the regional economy and for the acceleration of women’s trade and economic empowerment. However, the Association counsels that in order to take full advantage of the AfCFTA, government should intensify current efforts to eradicate non-tariff and regulatory barriers such as border delays, burdensome customs and inspection procedures, as well as multiple licensing processes and taxes. A situation where it is easier to import than to export will defeat the purpose of signing the AfCFTA.

The Association also notes that the immediate impact of the AfCFTA could be the loss of revenue from import duties and taxes which may impede the federal government’s current agenda to invest heavily in infrastructure and affect other spending activities. So NACCIMA counsels that the government should steps up its efforts with policies that will ensure that Nigerian products and services are market ready for the African continent in the shortest possible time. While we continue to address the issues around the AfCFTA, and work on a strategy of implementation to tackle the problems involved. We should SIGN THE AGREEMENT now and set up an all embracing implementation committee in readiness for when it would finally take off.

Let us have base studies and start to train those who will be involved in the nitty gritty of the implementation. Luck enough, we now have a National Office on Trade Negotiations. Let us develop the capacity of this office and its staff in readiness for the next phase of the AfCTA. Currently, AfCFTA is entering critical stages and negotiations are going on and priority sectors for trade in services, transport tourism, financial communication and business services have been selected. Meanwhile, Nigeria is dithering and still ruminating on what to do. Discussions are also going on for the AfCFTA secretariat, an issue which should have been an ease take for us. The world will not wait for us, so let us sign the Agreement promptly, so that we can also be part of the negotiations and influence. NACCIMA as a major and prominent member of the organised private sector (OPS) is ready to work with government to achieve the various purposes of the AfCFTA at the national and continental levels.

The 2018 Budget

In our last briefing, we decried the late passage of the 2018 budget. When it was finally passed we also reacted to the removal of certain key capital projects and supported the stand of Mr. President to represent these projects in a supplementary budget. It’s the seventh month of the year and that budget has now been submitted to the National Assembly as promised. While we urge the implementation of the projects and programmes under the 2018 budget, we also urge that the National Assembly should swiftly review and pass the N228 billion supplementary budget that President Muhammadu Buhari sent to it on July 17, 2018 to enable the funding of critical projects removed from the 2018 budget when this supplementary budget is passed. NACCIMA once again reiterates its stance that funds borrowed to fund the budget should be applied to capital projects and not concurrent expenses or to the ongoing electioneering process.

The National Carrier: “Nigeria Air”

The aviation sector plays a very critical role in the economic and social life of any nation. Today, it is the backbone of global movement. The Nigerian aviation sector is therefore of great interest to our Association because it plays a critical role in the economy of any nation. It was therefore with considerable interest that we received the news on July 18, even though from the far away Farnborough International Air Show, of the establishment of a new national carrier, Nigeria Air. The Airline is expected to commence operations by December 24, 2018. All said and done, this is a welcome development for several reasons.

With an estimated population of about 198 million, and an upwardly mobile class known for traveling all over the world, our current air market, which ironically is dominated by foreign national carriers, is not being optimally served. Yet, opportunities exist in the aviation sector. Observers say our current air traffic market is just around 15 million, and it is projected to grow significantly. There are over 80 Bilateral Air Services Agreement (BASA) that are not being utilised or are under-utilised. New opportunities are also opening up under the Yamasukoro Agreement and the Africa Single Air Transport Market (SAATM). As such, all efforts must be made to have a strong aviation sector to take advantage of this scenario. We therefore welcome the courage of the government in kickstarting the establishment of the national carrier to be part of those to benefit from the market.

Against the background of our past experience with the defunct Nigeria Airways and Virgin Nigeria, which still leaves sad memories and a bitter taste in our mouths, the issue of the ownership structure and management of the new national carrier are of significance. Indications are that under the new ownership arrangement, government will have only a 5 per cent share and the rest will belong to strategic partners who will manage, operate and invest in the new national carrier. Implicitly, the airline will operate on the principle of a private public partnership (PPP) arrangement for its take off and management. We therefore welcome the goal of a strategic partner to invest in develop and operate and manage the new national carrier to the status of a world class airline in its domestic andinternational operations.

As we await the next stages in the process of formation of the carrier, we wish to make our stand clear on the following:

● There must be transparency in the process of the choice of those being considered for strategic partnership;

● The bidding process of the search for strategic partners must be open and competitive;

● Due consideration should be given to the Nigerian private sector in the offer of equity and the controlling share;

● The new airline must be protected from government intervention, so that it does not suffer the same fate like the defunct Nigeria Airways.

But overall, as we gear up for the operations of the new national carrier, we must also work to create a conducive environment that would ensure that private sector airlines also survive. The situation in which we have more individually owned private jets than airlines is not encouraging and a situation in which the private airlines collapse regularly is not good. Something is wrong with such a trend. We must create the environment for private airlines to thrive. Attention must therefore be given to the improvement of the aviation value chain, the infrastructure concession arrangements in the running of our airports, the security provisioning, maintenance culture, etc.

The Nigerian population and air market is indeed large enough for several birds to fly comfortably in the skies without colliding and, I should add, safely to their destinations and profitably so. As the “The Voice of Nigerian Business”, we will continue to advocate and support mutually beneficial partnerships, especially between government and the private sector in the promotion of Nigerian aviation and the participation of private airlines, as a new national carrier emerges.

As counseled by the International Civil Aviation Organisation (ICAO), let us ensure the development of an economically viable civil aviation system, comprising of airlines, airports, air navigation services, while facilitating access to funding for aviation infrastructure and other investment needs in the sector.

Promoting Tourism and Hospitality

Nigeria is not only rich in human and natural resources but it also has a wide array of tourist attractions, exciting landmarks, cultural festivals etc. Yet, it is a well-known fact that the potentials of our tourism and hospitality sector have not been fully harnessed. There are tourist sites across the country, from Osun Osogbo Groove in Osun State to Obudu Cattle Ranch in Cross River State, Oguta Lake in Imo State, Ogbunike Caves in Anambra State, Yankari Games Reserve in Bauchi State, Olumo Rock in Ogun State, the Badagry and then Gurara Waterfalls in Niger State, just to mention a few. Our cultural festivals are also goldmines waiting to be tapped: Argungun fishing festival, Oshun Oshogbo, new yam festivals, Ojude Oba in Ijebu Ode, Eyo in Lagos, etc. However, despite the potentials in the tourism and hospitality sector, its contribution to the nation’s GDP has been between 1.5 per cent and 1.8 per cent in the last 10 years. We need to work harder to harness our potentials in this area, which is also obvious going by the appearance in the country of major international hotel brands such as Hilton, Radisson Blue, Marriott, etc.

The challenges in the sector include infrastructure, insecurity, inadequate data and information, the poor management of tourist destinations, and poor services in our hotel and tourist destinations. Despite all of these, the Nigerian Tourism Development Corporation (NTDC) is only struggling to promote tourism. We hope it would be ultimately given the support required to effectively carry out its responsibilities.

Still on the issue of the appropriate policy environment that will be supportive of tourism, it is necessary to address the present gaps, especially in the area of the provision of internationally accepted services and standards. We are, therefore, delighted at the passage, in June 2018, of the National Institute for Hospitality and Tourism (NIHOTOUR) Bill in the National Assembly. Hopefully this will help in the area of training, capacity building, research and development registration, certification and registration of personnel in the hospitality and tourism sector. We urge prompt presidential assent to the Bill so that NIHOTOUR can commence operation in accordance with the Bill setting it up. When NIHOTOUR is fully established and operational it is also expected to operate and work to help establish global standards, taking note of our cultural nuances. We, of course, are ready to work with NIHOTOUR in the fulfillment of its mandate, and we shall look into the possibility of entering into an memorandum of understanding (MoU) in this regard, taking into consideration our recent certification as an ATP of the CQI under Nigeria’s NPQI project.

In the final analysis, we wish to say that the private sector is best placed to drive the tourism and hospitality sector. Government should only provide the policy and enabling environment. We therefore also want to encourage respective states to look inward and develop their own Strategic Tourism Road Maps. A good example is Ogun State, which is developing its cultural tourism. The Drum Festival is a good example in thia regard. The third in the series of this festival was held recently to international acclaim. Other states should follow this example to upscale the development of tourism to contribute to employment and increase its contribution to the GDP.

The Creative and Entertainment Industry

Our creativity industry has grown in leaps and bounds. It was reported that it contributed 2.3 per cent (N239 billion) to Nigeria’s gross domestic product (GDP) in 2016 and has become a veritable avenue through which Nigerian culture and history is exported to the world. Our Nollywood is reputed to be the third largest by volume in the world, after Hollywood and Bollywood. We now have movies that gross N50 million and above at the opening overnight and making profit of over N100 million (one hundred million naira). Musical such as Saro the Musical and Wakaa sold out at their opening nights in London two years ago. Both musicals have played to international audiences in high profile theatre districts abroad. Similarly works of young Nigerian musicians dominate the air waves across Africa and are well known, also making the producers celebrities, across the world. This sector has tremendous economic potentials, and also generates a lot of employment, especially for our young people. It certainly deserves more attention. We therefore call for policies and incentives to address issues of financing, taxation, capacity building, infrastructure, copyright and intellectual property rights piracy etc. to enable the continuous growth of the sector. We hope the recent visit of the vice president to Hollywood will also spin a wave of various initiatives to advance the growth of the sector.

NACCIMA recognises the creative industry as a new frontier worth exploring in view of its potential to make significant contributions to the economy, and create jobs, especially for young people who are mostly affected by unemployment. And We commend the Bank of Industry (BoI) for its Nollywood initiative. There is need for more intervention funds in this area. A Culture Fund, which has been long under consideration, should be made a reality to serve as a catalyst for the creative industry. We will, in due course, embark on a collaborative progamme with operators and other stakeholders in the creativity industry for growth and development of the sector.

The Vice President’s Visit To the Silicon Valley and Hollywood

We commend the VP for his recent visit to Silicon Valley and Hollywood. This is a reflection of the administration’s determination to scale up efforts to ensure harnessing of the potentials of the information and communications technology (ICT) sector and the creative industry. The top five leading companies in world today are information technology (IT) companies, with young people at the driving seats. Nigeria’s ICT industry is also growing at a fast pace and attracting global IT giants to the country. Nigerians have proved their ingenuity in the area of the development of software and computing and we can recall the visit of Facebook CEO, Mark Zuckerberg to Nigeria a short while back.

We look forward to the follow up arrangement on the visit of the VP to Silicon Valley. NACCIMA is interested in being part of the expected initiative, to walk the talk in the ICT sector, so to say.

Towards the 2019 Electioneering Process

The elections are here again and the first thing to say is to advice all eligible voters to please pick up their voting cards in readiness for the 2019 elections. Recently the chairman of the Independent National Electoral Commission (INEC) visited Lagos for deliberations with the organised private sector at an event tagged the “Private Sector Forum” put together by one of our Chambers members, the Lagos Chamber of Commerce and Industry (LCCI). According to the INEC chairman, this was in recognition of the fact that the business community is a beneficiary of a stable political environment and business thrives on peace. We should also add that a stable polity is fundamental to the attraction of foreign direct investments (FDIs). He also spoke of the success of an unbroken 20 years of civil rule and the fact that elections are getting better in the country. We therefore look forward to a peaceful and credible election devoid of violence and rancour, going into 2019. We call on all stakeholders, including INEC, the security forces and politicians, to ensure that the forthcoming elections at all levels are peaceful, transparent and credible. This is to enable the required peaceful atmosphere post-election for business to thrive, economic growth and development, and the well being of the people.

As a major stakeholder in the nation’s economy, NACCIMA hereby calls for more efficiency, alertness and responsiveness on the part of all government agencies involved in the electoral process. To the politicians, we urge for caution and implore them to apply the spirit of sportsmanship during the election process.

Developments In the Mining Sector

Nigeria’s mining sector is one with huge untapped potentials. This is especially so because Nigeria is blessed with abundant solid mineral deposits across the states of the federation. But we must move from being a nation with vast mineral deposits to become a mining nation. Figures indicate that the mining sector contributed a mere 0.033 per cent to real GDP in the first quarter of 2018. Through the Road Map for the Growth and Development of the Nigerian Mining and Steel Sector, the goal is to scale up the contribution of mining to 4 per cent of the GDP by 2025. We had done it in the past but then we struck oil and abandoned our solid minerals sector. We are however delighted that the mining sector is now receiving the right attention as part of the determination of government to diversify the economy.

Mining is a priority sector, which is why NACCIMA has been supportive of the “Road Map for the Growth and Development of the Nigerian Mining Industry” adopted in 2016. The Roadmap is a comprehensive strategy designed to achieve “shared mining prosperity” across Nigeria and it has received a lot of attention from our members, especially in states with vast mineral deposits. It’s in this connection that NACCIMA, in cooperation with our High Commission in Australia, is embarking on a Mining Road Show in Australia, a well known mining nation, this month. This will take us to Melbourne and Perth, two well known Australian mining states. The objective is to market Nigeria’s vast mineral deposits and through business to business meetings attract high end Australian mining investors. This is certainly a practical action by NACCIMA to support the implementation of the 2016 Mining Road Map and the vision of improving the contribution of mining to the economy.

I wish to use this opportunity to appeal to states across the federation endowed with solid minerals to take advantage of the opportunities available under the 2016 Mining Road Map. They can set up Special Purpose Vehicles (SPVs) under PPP arrangements with foreign investors to harness these these deposits. It’s a veritable way to improve their internally generated revenues as the SPVs set up can go into partnership with foreign mining investors for the development of their states, the provision of jobs and development of their states.

Agriculture

Agriculture is another priority sector for NACCIMA as it has long held the position of a major contributor to the GDP and also being an important employer of labour. NACCIMA is therefore delighted at the renewed interest and attention to Nigeria’s agriculture sector, with its increased contribution of 21.65 per cent to the nation’s real GDP in the first quarter of 2018. The rice revolution is an indication of the possibilities in the sector, if we put our minds to it. We should pay more attention to research, soft loans and financing for farmers; infrastructure, technology, logistics, and development of the agriculture value chain. After a concise review of the sector and strategising on how best the gaps can be addressed, NACCIMA is currently working on a partnership with the Nigeria Incentive-Based Risk Sharing System for Agricultural Lending (NIRSAL) to better de-risk lending to farmers and enable them gain access to the required finance for agribusiness.

NACCIMA has also registered and established the NACCIMA Ventures and Certifications Limited (NVCL), a training centre approved by the Chartered Quality Institute (CQI) London to offer the International Organisation for Standardisation (ISO) approved courses. We are also equally involved in and currently on the National Technical Working Group of the Global Good Agriculture Practices (GAP), which is expected to facilitate the entry of our agricultural products into the international market.

We should also pursue the Agripreneur Initiative designed to attract young people to go into agriculture as a business.

Security

The problem of insecurity currently plaguing many parts of the country remains a major source of deep concern to NACCIMA. This is an indication that the nation’s security apparatus requires a more innovative and radical approach to addressing the increasing insecurity challenges we are facing today, ranging from acts of terrorism, to kidnapping, robbery, vandalisation and other vices. NACCIMA hereby calls on the relevant ministries, departments and agencies (MDAs) of government assigned the responsibility of protecting lives and property to come up with the necessary strategies to ensure safety, especially with the up-coming elections.

The Power Sector

The nation’s power sector is, as we all know, central to the performance and productivity of the economy. Its of major interest to the private sector, especially to manufacturers who require power for production. Although the power sector is witnessing an increase in electricity production by the generation companies (GENCOs), yet we are facing the problems of transmission and distribution due to obsolete and inadequate transmission and distribution infrastructure and equipment. Consequently, we now speak of stranded power, energy which is available but cannot be transmitted nor distributed due to inadequate equipment, transformers etc. NACCIMA hereby calls for more urgent steps to resolve these challenges, especially in the areas including metering, estimated billing, and others pertaining to the DisCos.

Infrastructure

While we continue to commend the increased allocations to capital projects in the 2017 and 2018 budgets, especially for infrastructure projects, we are not oblivious of the fact that many of these projects remain uncompleted or are yet to be implemented. The Apapa gridlock, the Lagos Ibadan expressway and others in all other parts of the country require quick completion.

Good road and rail networks can significantly improve the business environment and generally have positive affects on the economy, and the standards of living of our people. Efforts should therefore be made to complete the road and rail projects as promised by government. And, of course, good infrastructure will support the activitues of 37 million micro, small and medium enterprises (MSMEs) who employ over 60 million people in Nigeria. Hence the need for stringent implementation of these infrastructure projects.

Local Content Development

President Buhari in February this year signed Executive Order 5 to Improve Local Content in Science, Engineering and Technology Procurement. NACCIMA commends this act, which is expected to promote the application of science, technology and innovation towards achieving the nation’s development goals across all sectors of the economy. Recently the minister of science and technology addressed the world press to underscore the government’s commitment to the implementation of this Order. The goal is to ensure that science and technology and innovation drive all areas of development and increases Nigerian content. NACCIMA is ready to work with the ministry for the successful implementation of this Order.

Conclusion

Once again, NACCIMA reiterates its support for the African Continental Free Trade Agreement (AfCFTA) and emphasises that Nigeria cannot afford to lose out in the opportunities inherent in a common African market. This also underscores the saying that you can only score a goal as a member of a football team when on the pitch. As such, we applaud ongoing engagements by government with all stakeholders, including the private sector, to have everyone on board, as it gets ready to sign the Agreement and prepare for the subsequent stages of negotiation and implementation.

Alaba Lawson is national president of Nigerian Association of Chambers of Commerce, Industry, Mines and Agriculture (NACCIMA).

 

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