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Sudan –
Country Profile
Contents
1
Background 1.1History
2
2
2Population
2
2.1General
2
2.2
Population figures
2
2.3
Age structure (2011 estimates)
2
2.4
Gender ratios (2011 estimates)
2
2.5
Life expectancy (2012 estimates)
2
3Economy
2
3.1
Latest Economic indicators
3
3.2
Five-year forecasts
3
3.3
Annual trends
4
4
Government and Politics
4
4.1
Political structure
4
5
Transport and Communications
7.6
Protection of property rights
7
7.7
Transparency of the regulatory system
7
7.8
Efficient capital markets and portfolio investment
8
7.9
Competition from state-owned enterprises (SOEs)
8
7.10 Corporate social responsibility
8
7.11 Political violence
8
7.12Corruption
8
7.13 Bilateral investment agreements
8
7.14Labour
8
7.15 Foreign trade zones/free ports
8
7.16 Foreign direct investment statistics
9
7.17 Starting a business in Sudan
9
8
Country Risk Assessment
9
8.1
Sovereign risk
9
8.2
Currency risk 9
6
8.3
Banking sector risk
9
5.1Railways
6
8.4
Political risk
9
5.2Airports
6
8.5
Economic structure risk
9
5.3Railways
6
5.4Roadways
6
9
Country Outlook: 2012 – 2016 10
5.5Communications
6
9.1
Political stability
10
6Energy
6
7
Doing business in Sudan
6
7.1
Conversion and transfer policies
7
7.2
Expropriation and compensation
7
7.3
Dispute settlement
7
7.4
Performance requirements/incentives
7
7.5
Right to private ownership and establishment
7
9.2
Election watch
10
9.3
International relations
10
9.4
Policy trends
10
9.5
Economic growth
10
9.6Inflation
11
9.7
Exchange reates
11
9.8
External sector
11
A.1 Appendix two - sources of information
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
11
1
1Background
2Population
1.1History
Military regimes favouring
Islamic-oriented governments
have dominated national politics
since independence from the UK
in 1956. Sudan was embroiled in
two prolonged civil wars during
most of the remainder of the 20th
century. These conflicts were
rooted in northern economic,
political, and social domination
of largely non-Muslim, nonArab southern Sudanese. The
first civil war ended in 1972 but
broke out again in 1983. The second war and famine-related effects
resulted in more than four million people displaced and, according to
rebel estimates, more than two million deaths over a period of two
decades.
2.1General
Sudan has a population of 34,206,710 (July 2012 est.)
Peace talks gained momentum in 2002-04 with the signing of several
accords. The final North/South Comprehensive Peace Agreement
(CPA), signed in January 2005, granted the southern rebels
autonomy for six years followed by a referendum on independence
for Southern Sudan. The referendum was held in January 2011 and
indicated overwhelming support for independence. South Sudan
became independent on 9 July 2011.
Since southern independence Sudan has been combating rebels
from the Sudan People’s Liberation Movement-North (SPLM-N) in
Southern Kordofan and Blue Nile states. A separate conflict, which
broke out in the western region of Darfur in 2003, has displaced
nearly two million people and caused an estimated 200,000 to
400,000 deaths. The UN took command of the Darfur peacekeeping
operation from the African Union in December 2007.
Peacekeeping troops have struggled to stabilise the situation, which
has become increasingly regional in scope and has brought instability
to eastern Chad. Sudan also has faced large refugee influxes from
neighbouring countries primarily Ethiopia and Chad. Armed conflict,
poor transport infrastructure, and lack of government support have
chronically obstructed the provision of humanitarian assistance to
affected populations.
2.2 Population figures
1.884% (2012 est.)
2.3 Age structure (2011 estimates)
Total percentage
Male
Female
0 – 14 years
42.1%
9,696,726
9,286,894
15 – 64 years
55.2%
12,282,082
12,571,424
65 years and
over
2.7%
613,817
596,559
Source: CIA World Factbook
2.4 Gender ratios (2011 estimates)
Under 15 years
1 male / female
15 – 64 years
1 male / female
65 years and over
1.24 male / female
Total population
1.02 male / female
Source: CIA World Factbook
2.5 Life expectancy (2012 estimates)
Total population
62.57 years
Male
60.58 years
Female
64.67 years
Source: CIA World Factbook
3Economy
Sudan is an extremely poor country that has had to deal with social
conflict, civil war, and the July 2011 secession of South Sudan - the
region of the country that had been responsible for about threefourths of the former Sudan’s total oil production. The oil sector had
driven much of Sudan’s GDP growth since it began exporting oil in
1999. For nearly a decade, the economy boomed on the back of
increases in oil production, high oil prices, and significant inflows of
foreign direct investment.
Following South Sudan’s secession, Sudan has struggled to
maintain economic stability, because oil earnings now provide a far
lower share of the country’s need for hard currency and for budget
revenues. Sudan is attempting to generate new sources of revenues,
such as from gold mining, while carrying out an austerity programme
to reduce expenditures.
Services and utilities have played an increasingly important role in
the economy. Agricultural production continues to employ 80% of
the work force and contributes a third of GDP. Sudan introduced
a new currency, still called the Sudanese pound, following South
Sudan’s secession, but the value of the currency has fallen since
its introduction and shortages of foreign exchange continue. Sudan
also faces rising inflation, which has led to a number of small scale
protests in Khartoum in recent months.
Ongoing conflicts in Southern Kordofan, Darfur, and the Blue Nile
states, lack of basic infrastructure in large areas, and reliance by
much of the population on subsistence agriculture ensure that much
of the population will remain at or below the poverty line for years to
come.
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
2
3.1 Latest Economic indicators
2010
1 Qtr
Prices
Consumer prices (2005=100; av)
Consumer prices (% change, year on year)
Financial indicators
Exchange rate SDG:US$ (av)
Exchange rate SDG:US$ (end-period)
M1 (end-period; SDG m)
M1 (% change, year on year)
M2 (end-period; SDG m)
M2 (% change, year on year)
Sectoral trends
Crude petroleum production ('000 barrels/day)
Balance of payments (US$ m)
Goods: exports fob
Goods: imports fob
Merchandise trade balance fob-fob
Services balance
Income balance
Net transfer payments
Current-account balance
Reserves excl gold (end-period)
2 Qtr
2011
3 Qtr
4 Qtr
1 Qtr
2 Qtr
3 Qtr
4 Qtr
156.7
14.6
163.1
15.3
172.4
10.9
172.9
11.6
183.3
16.9
189.5
16.1
206.5
19.8
206.2
19.3
2.24
2.313
16,608
21.4
30,120
27.2
2.26
2.363
17,918
26.4
32,049
28.3
2.37
2.367
18,268
23.9
33,363
26.8
2.352
2.482
19,908
23.6
35,462
25.4
2.632
2.799
20,660
24.4
37,763
25.4
2.681
2.677
21,996
22.8
38,977
21.6
2.677
2.677
21,544
17.9
38,071
14.1
2.677
2.677
24,850
24.8
41,817
17.9
469.8
n/a
n/a
n/a
n/a
n/a
n/a
n/a
2,903
-2,139
764.8
-544
-585
579
215
1,263
2,718
-2,071
646.9
-534
-554
422
-19
1,291
2,742
-2,226
516.4
-467
-615
536
-29
978
3,041
-2,404
636.9
-524
-718
594
-10
1,036
3,587
-1,897
1,689.9
-233
-637
174
994
1,218
3,925
-1,888
2,037.7
-332
-411
264
1,558
1,081
1,146
-2,285
-1,139.4
-436
-18
373
-1,220
428
769
n/a
769.5
589
0
0
1,358
n/a
Source: Economist Intelligence Unit
3.2 Five-year forecasts
(% unless otherwise indicated)
Real GDP growth
Oil production ('000 b/d)
Crude oil exports (US$ m)
Consumer price inflation (av)
Government balance (% of GDP)
Exports of goods fob (US$ bn)
Imports of goods fob (US$ bn)
Current-account balance (US$ bn)
Current-account balance (% of GDP)
External debt (year-end; US$ bn)
Exchange rate SDG:US$ (av)
Exchange rate SDG:¥100 (av)
Exchange rate SDG:€ (av)
Exchange rate SDG:SDR (av)
2011 (a)
-2.4
295
7,014
18
-4.4
8.8
8.1
0.1
0.2
38.6
2.64
3.31
3.67
4.2
2012 (a)
-9.4
140
1,870
18.6
-6.3
3.4
6.1
-1.8
-2.7
39.6
2.85
3.68
3.63
4.39
2013 (b)
2.7
142
1,761
13.6
-3.5
3.1
6.3
-1.4
-2.2
41
3.41
4.24
4.23
5.19
2014 (b)
2.7
140
1,683
12.1
-2.7
3
6.4
-1.5
-2.3
42.5
3.96
4.89
4.86
6
2015 (b)
4.1
140
1,541
10.4
-2.9
2.9
6.6
-1.8
-2.6
44
4.24
5.18
5.25
6.44
2016 (b)
4.7
140
1,552
11.1
-2.8
2.9
6.9
-1.8
-2.3
45.5
4.3
5.18
5.41
6.55
a) Economist Intelligence Unit estimates; b) Economist Intelligence Unit forecasts
Source: Economist Intelligence Unit
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
3
3.3 Annual trends
Real GDP growth (% change)
4Government and Politics
4.1 Political structure
Official name
Republic of Sudan
Legal system
Sharia (Islamic law) applies in both civil and criminal cases in the north
– although there are some special provisions for non-Muslims.
Consumer Price Inflation (av %)
National legislature
Sudan has a bicameral parliament, consisting of a 450-member
National Assembly (with 60% of seats elected by majority voting in
geographical constituencies and 40% by proportional representation,
including 25% reserved for women) and a Council of States
composed of two representatives elected by each state assembly.
National elections
April 2010 (presidential and parliamentary); next elections due 2015.
Head of State
Omar al-Bashir, who took office following a 1989 coup and was
sworn in as President in October 1993, was most recently re-elected
in April 2010.
Budget balance (% of GDP)
National government
The government is dominated by the National Congress Party (NCP).
Until July 2011 it was in a coalition with its former adversary in the
north-south civil war, the Sudan People’s Liberation Movement
(SPLM), and a few minor parties such as the Eastern Front. In
December 2011 there was a cabinet reshuffle, with the Democratic
Unionist Party (DUP) being brought into government.
Main political parties
The main northern opposition parties include the DUP, the Umma
Party and the Popular Congress Party (PCP). In Darfur the main
political-military groups are the Justice and Equality Movement
(JEM) and the fragmented Sudan Liberation Movement (SLM).
The Presidency
• President: Omar al-Bashir (NCP)
• First Vice-President: Ali Uthman Mohammed Taha (NCP)
• Second Vice-President: Al-Haj Adam Yousif (NCP)
Current account balance (% of GDP)
• Assistants to the president:
– Nafie Ali Nafie (NCP)
– Musa Mohammed Ahmed (EF)
– Al-Sadiq al-Mirghani (DUP)
– Abdel Rahman al-Sadiq al-Mahdi
Key ministers
• Council of Ministers: Ahmed Omer Sa’ad (DUP)
• Commerce: Osman Omer al-Sharif (DUP)
• Defence: Abdel-Rahim Mohammed Hussein (NCP)
Source: Economist Intelligence Unit
• Electricity and Dams: Osama Abdullah
Mohammed al-Hassan (NCP)
• Environment and Forestry: Hassan Hilal (DUP)
• Finance and National Economy: Ali Mahmoud Abdel-Rasool (NCP)
• Foreign Affairs: Ali Ahmed Karti (NCP)
• Human Resources: Abdeen Mohammed (DUP)
• International Co-operation: Ishraqa Sayed (DUP)
• Interior: Ibrahim Mahmoud Hamed (NCP)
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
4
• Justice: Mohammed Bushara Dosa (NCP)
Main political parties
The main opposition party is the SPLM-Democratic Change (SPLMDC), a faction with alleged ties to the north that broke away in 2009.
Other opposition parties have limited influence, including the United
Democratic Party (UDP) and the South Sudan Democratic Forum
(SSDF).
• Mining: Kamal Abdel-Latif (NCP)
• Oil: Awad Ahmed al-Jaz (NCP)
• Social Welfare and Insurance: Amira al-Fadil
Mohammed al-Fadil (NCP)
• Youth and Sports: Al-Fatih Taj al-Sir (DUP)
• Central Bank Governor: Mohammed Khair al-Zubair
International organisation participation
• ABEDA
• ACP
• AfDB
• AFESD
• AMF
• AU
• CAEU
• COMESA
• FAO
• G-77
• IAEA
• IBRD
• ICAO
• ICRM
• IDA
• IDB
• IFAD
• IFC
• IFRCS
• IGAD
• ILO
• IMF
• IMO
• Interpol
• IOC
• IOM
• IPU
• ISO
• ITSO
• ITU
• LAS
• MIGA
• NAM
• OIC
• OPCW
• PCA
• UN
• UNCTAD
• UNESCO
• UNHCR
• UNIDO
• UNWTO
• UPU
• WCO
• WFTU
• WHO
• WIPO
• WMO
• WTO (observer)
SOUTH SUDAN
Official name
The Republic of South Sudan.
Legal system
The south has a non-Islamic legal system.
National legislature
South Sudan has a bicameral parliament. The lower house, the
National Legislative Assembly, is made up of the members of the
Comprehensive Peace Agreement era Southern Sudan Legislative
Assembly and the former southern members of Sudan’s National
Assembly prior to South Sudan’s independence. The upper house,
the Council of States, is made up of the former southern members of
Sudan’s Council of States prior to South Sudan’s independence, plus
20 members appointed by the president. An interim constitution was
passed by parliament days before independence in July 2011 and is
expected to serve for four years before a permanent constitution is
approved at a national conference.
The Presidency
• President: Salva Kiir Mayaardit
• Vice-President: Riek Machar
Key ministers
• Agriculture and Forestry: Betty Achan Ogwaro
• Cabinet Affairs: Deng Alor Kuol
• Commerce, Industry and Investment: Garang Diing Akuong
• Culture, Youth and Sports: Cirino Hiteng Ofuho
• Defence and Veteran Affairs: John Kong Nyuon
• Environment: Alfred Lado Gore
• Finance and Economic Planning: Kosti Manibe Ngai
• Foreign Affairs and International Co-operation: Nhial Deng Nhial
• Gender, Child and Social Welfare: Agnes Kwaje Lasuba
• General Education and Instruction: Ustaz Joseph Ukel Abango
• Health: Michael Milly Hussein
• Housing and Physical Planning: Jemma Nunu Kumba
• Information and Broadcasting: Barnaba Marial Benjamin
• Interior: Alison Manani Magaya
• Justice: John Luk Jok
• Labour and Public Service: Awut Deng Acuil
• National Security: Oyay Deng Ajak
• Parliamentary Affairs: Michael Makwei Lueth
• Petroleum and Mining: Stephen Dhieu Dau
• Roads and Bridges: Gier Chuang Aluong
• Telecommunication and Postal Services: Madut Biar Yel
• Transport: Agnes Poni Lokudu
• Water Resources and Irrigation: Paul Mayom Akec
• Central Bank Governor: Kornelio Koryom Mayiik
National elections
The term of the National Legislative Assembly is four years from
9 July 2011.
Head of State
Salva Kiir Mayaardit
National government
The government is dominated by the Sudan People’s Liberation
Movement (SPLM).
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
5
5Transport and
Communications
5.1Railways
Sudan has 4,578 kilometres of narrow-gauge, single-track railroads
that serve the northern and central portions of the country. The
main line runs from Wadi Halfa on the Egyptian border to Khartoum
and southwest to Al-Ubayyid via Sannar and Kusti, with extensions
to Nyala in Southern Darfur and Wau in Bahr al Ghazal. Other lines
connect Atbarah and Sannar with Port Sudan, and Sannar with
Ad Damazin. A 1,400-kilometre line serves the al Gezira cottongrowing region. A modest effort to upgrade rail transport is currently
underway to reverse decades of neglect and declining efficiency.
Service on some lines may be interrupted during the rainy season.
The main system, Sudan Railways, which was operated by the
government-owned Sudan Railways Corporation (SRC), provided
services to most of the country’s production and consumption
centres. The other line, the Gezira Light Railway, was owned by
the Sudan Gezira Board and served the Gezira Scheme and its
Manaqil Extension. Rail dominated commercial transport, although
competition from the highways has been increasing rapidly.
5.2Airports
Sudan has 72 airports – 15 with paved runways and 57 with unpaved
runways.
Sixteen international airlines provided regular flights to Khartoum.
5.3Railways
Total: 5,978 km
5.4Roadways
Total: 11,900 km
Sudatel exited the mobile market when it sold its GSM network to
Celtel (now Zain) at a record price in 2006, following the arrival of
competition the year before from Bashair Telecom. Sudatel then
re-entered the mobile market independently with its CDMA network
under the brand name Sudani. At the end of 2009 the company
launched a GSM-based network overlay, keeping up with Zain and
MTN in offering third generation services including HSDPA mobile
broadband. Broadband pricing is still high and varies widely between
the different operators.
6Energy
Sudan’s electricity-generating capacity – at just 4,520 gwh in 2006, or
about 115 kwh per head – is inadequate for its needs. The electricity
grid is unreliable and only covers a tiny portion of the country around
Khartoum and south to Blue Nile state, areas that contain about 30%
of the population. The remainder of the population rely on production
from small and expensive diesel generators.
Hydroelectric power provided around 41% of electricity in 2006,
and so power fluctuates according to the flow of the Nile. A major
programme to increase output is under way, the centrepiece of
which is a US$1.2bn hydroelectric dam at Merowe, which should
generate an average load of 625 mw, more than doubling Sudan’s
generation capacity. Other projects include a doubling of capacity at
the oil-fired Khartoum North power plant to 380 mw, the construction
of a 500-mw oil-fired power station in Kosti in White Nile state and
the enlargement of the Roseires Dam. At present, the south or west
of Sudan has no significant power-generating capacity, although
there are plans for hydroelectric schemes and the electrification of
20 southern towns with local diesel-powered grids, as well as for the
extension of the national grid in the north to Darfur and Kordofan.
Paved: 4,320 km
Unpaved: 7,580 km
5.5Communications
Following a referendum, oil-rich South Sudan became the world’s
youngest independent state in mid-2011. Having been beyond the
central government’s control and deprived of development, it is
establishing its own independent telecommunications regime,
creating new opportunities for service providers and equipment
suppliers.
Three quarters of the population are in the North where mobile
market penetration is much higher, but the average revenue per
user (APRU) is higher in the South. The North has a large, relatively
well-equipped telecommunications system by regional standards,
including a national fibre optic backbone and international fibre
connections.
The national telco, Sudatel has been privatised more than a decade
ago, with major shares and management control now held by Etisalat
of the UAE and Qatar Telecom. It is also listed on several regional
stock exchanges. The company presided over the world’s fastest
growing fixed-line market until it started substituting traditional
copper lines with CDMA2000 fixed-wireless access in 2005.
Competition in the fixed-line market comes from Canartel which,
interestingly, is also majority-owned by Etisalat. It too opted for
CDMA2000 technology to cost effectively roll out fixed services and,
like Sudatel, is offering wireless broadband services through this
network following an upgrade to the EV-DO standard. The company is
lobbying for a licence to offer mobile services as well but is meeting
resistance from the other operators.
7Doing business in Sudan
By all independent measurements available, Sudan presents one
of the most challenging business environments in the world to the
would-be investor. The country’s rank of 135th out of 183 in the 2012
World Bank Doing Business report is unchanged from the previous
year, but Sudan recorded lower scores in seven of the ten indicators
in 2012. Sudan is ranked 177th out of 182 nations in Transparency
International’s Corruptions Perception Index. The nation’s political
risk rating is 137 out of 140 according to the PRS Group; the Country
Credit rating is 174 out of 178 according to Institutional Investor.
Measure
Year
Index/Ranking
TI Corruption Index
2011
177
Heritage Economic Freedom
N/A
Not Graded Since
2000
World Bank Doing Business
2012
135
MCC Government
Effectiveness
FY12
-0.51 (20%)
MCC Rule of Law
FY12
-0.39 (17%)
MCC Control of Corruption
FY12
-0.55 (10%)
MCC Fiscal Policy
FY12
-3.2 (40%)
MCC Trade Policy
FY12
N/A
MCC Regulatory Quality
FY12
-0.63 (15%)
MCC Business Start Up
FY12
0.946 (59%)
MCC Land Rights Access
FY12
0.685 (65%)
MCC Natural Resource
Management
FY12
49.40 (24%)
* Mauritius is not eligible for MCC
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
6
The July 2011 secession of South Sudan fundamentally altered
Sudan’s economy. Southern oil production accounted for over
75% of the country’s total, an amount that represented almost 36
percent of the government of Sudan’s revenues. In response to the
loss, Sudanese government officials announced their intention to
replace the revenue by expanding existing oil and gas production,
increasing mining operations, particularly gold mining, and reviving
the agricultural sector, the mainstay of the Sudanese economy prior
to the advent of crude oil exports in 2000.
7.4 Performance requirements/incentives
Investors must begin their projects within six months of receiving
a license, submit reports every six months during the period in
which the project receives special privileges, keep regular books
and maintain records on the assets of the project exempted from
customs duties, and exempted imported materials, and present,
to the Minister, the Competent Minister and the State Minister,
annually, during the period of validity of the privileges, a copy of the
annual report of the project, approved by a certified auditor.
To succeed in its plans for diversification of the economy, the
government of Sudan has repeatedly stressed the need for foreign
direct investment. Its actions have not matched its rhetoric, however.
According to the World Bank, Sudan has not introduced any
significant investment reforms in the last two years and only one – a
lowering of the corporate income tax rate – in the last four years. The
government eliminated the Ministry of Investment in December 2011
and replaced it with a High Council on Investment.
Sudanese investment law specifies certain sectors as strategic for
the purpose of providing additional or special incentives:
Trade missions visit Khartoum on a regular basis, often accompanied
by public announcements of signed agreements and purported
deals. In many cases, the projects never come to fruition. Most
foreign investment to date has been resource seeking, particularly
in petroleum and gas exploration and extraction, and agriculture.
China, Malaysia, and India have made major investments in the oil
sector; other countries including the Gulf States, Indonesia, Turkey,
and South Africa have also shown interest in expanding existing
commercial relations with Sudan.
3 Agriculture and industrial production
7.1 Conversion and transfer policies
Since the global financial crisis of 2008 and the collapse of crude oil
prices, Sudan has faced a severe foreign exchange reserves shortfall.
As a result of the shortage of foreign currency, the government of
Sudan has significantly tightened conversion and transfer policies.
Domestic businesses have no assurance of obtaining needed levels
of foreign currency for international transactions. Foreign companies
operating in Sudan must have the permission of the Central Bank of
Sudan to repatriate profits and foreign currency.
• Investments that assist in the development of export capabilities
While Sudanese and foreigners are permitted to hold foreign
currency accounts in commercial banks, access to the currency
can be delayed and/or limited without prior notification. Individuals
and businesses often resort to obtaining hard currency on the black
market. The government of Sudan periodically cracks down on
dealers involved in unlicensed foreign exchange.
Changes to policies governing currency access and conversion
are introduced without warning and generally become effective
immediately upon announcement.
7.2 Expropriation and compensation
Sudanese investment law states that “just compensation” must
be offered in the case of nationalization or confiscation of all or
part of any investment for “the public interest.” No mechanism
for determining compensation is specified; no definition of public
interest is provided.
7.3 Dispute settlement
According to the World Bank’s publication Doing Business 2012,
enforcement of a commercial contract in Sudan takes an average
of 53 procedures and 810 days at a cost of almost 20 percent of the
claim. These figures are unchanged for the last five years. The World
Bank reports that it takes 25 weeks to enforce an arbitration award
rendered in Sudan (assuming no appeal) and 19 weeks for a foreign
award.
The investment law does provide for international arbitration, and
Sudan is a party to the Convention on the Settlement of Investment
Disputes between States and Nationals of Other States (ICSID
Convention). Sudan has not signed the 1958 New York Convention.
1 Infrastructure, including roads, ports, electricity, dams,
communications, energy, transport, contracting business,
education, health and tourist and information technology services
and water projects
2Natural resource extraction and exploitation
Investments in strategic sectors are exempt from tax on profits for a
period of ten years. The High Council on Investment may grant nonstrategic investments an exemption of five years. The government
may also extend benefits including free land and exemptions from
other taxes and fees to strategic and non-strategic investments. Such
projects may include, but are not limited to:
• Investment in the least developed areas of the country
• Investments that contribute to rural development;
• Investments that increase employment
• Investments that are charitable in nature
• Investments that develop scientific and technological research
7.5 Right to private ownership and establishment
A business may be registered as a sole trader, partnership, limited
liability company (private or public), or branch of a foreign registered
company. However, severe restrictions to foreign equity ownership
apply in many sectors, particularly in service industries. Businesses
involved in railway freight transportation, airport operations,
television and radio broadcasting and newspaper publishing are
closed to foreign participation. This restriction was used to shut
down newspapers owned wholly or in part by South Sudanese
businessmen after the secession of South Sudan in July 2011. In
addition, foreign participation is limited in the telecommunications
and financial services sectors.
The law does allow for the purchase of privately or publically held
land in Sudan, but instances of sales are rare. The government has
provided land without transferring ownership to foreign companies
as an investment inducement. Land may be leased in Sudan without
restrictions on the amount or the duration. The lease may not be
transferred without permission.
7.6 Protection of property rights
Securing rights to property takes an average of six procedures over
nine days and costs, on average, three percent of the property value.
However, protecting property rights can be problematic. Military and
civil authorities do not follow due process at times. The judiciary is
unduly influenced by other branches of government, exercises little
or no independence, and is widely perceived as being corrupt.
7.7 Transparency of the regulatory system
Although the Heritage Foundation has not graded Sudan in its annual
Index of Economic Freedom since 2000, an analysis of selected
indicators is provided in the 2012 report. In the category of regulatory
efficiency, the report on Sudan states, “Sudan’s entrepreneurial
environment is not conducive to private sector development.
Inconsistent enforcement of regulations and other institutional
shortcomings, including a dysfunctional court system, often impede
business activity and prevent sustained economic development.”
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
7
7.8 Efficient capital markets and portfolio investment
Sudan’s financial system is relatively small by regional standards. The
banking sector is comprised of 32 banks, including five foreign and
four state-owned banks. Sudan remains under-banked, with banking
and other financial institutions concentrated around Khartoum. The
African Economic Outlook 2011 reports that while private sector
loans and deposits doubled between 2005 and 2009, their ratios to
GDP remain low (16% and 12% respectively). Non-performing loans
have increased in the last two years and are currently over 20%.
7.9 Competition from state-owned enterprises (SOEs)
According to a 2009 World Bank report, “the state indirectly
owns enterprises through government officials and political
parties in addition to direct ownership of enterprises by all levels
of government (National, GoSS, and State). The broad range of
activities in which the state participates as direct or indirect owners
of enterprises distorts competition in those markets, as the presence
of state firms provides a strong disincentive to private entry. This
undermines policies both at the national level and in Southern Sudan
to allow greater entry of the private sector.”
In October 2010, the government of Sudan announced its intent
to conduct mass privatisations in 2011. However, there were no
significant privatisations in 2011. A Kuwaiti fund company sold back its
share of the national airway, Sudan Air, to the government.
Many state-owned enterprises and parastatals are owned in whole
or part by military and security officials. Selling or closing these
establishments would threaten entrenched interests.
7.10Corporate social responsibility
Activist organisations and advocacy groups for corporate social
responsibility routinely target multinational corporations with
economic interests in Sudan for protest and economic boycott. As a
result, many universities, mutual and hedge funds, and philanthropic
organisations have divested their share holdings of companies that
do business in Sudan. The Chinese government and the stateowned China National Petroleum Corporation have come under
severe international criticism for their involvement in the Sudanese
petroleum sector.
7.11Political violence
While the Government of Sudan has taken some steps to limit the
activities of terrorist groups, elements of these groups remain in
Sudan and have threatened to attack Western interests. The terrorist
threat level throughout Sudan and particularly in the Darfur region
remains critical.
The threat of violent crime, including kidnappings, armed robberies,
home invasions, and car-jackings, is particularly high in the Darfur
region of Sudan, as the Government of Sudan has limited capacity to
deter crime in that region. In addition, Janjaweed militia and heavily
armed Darfuri rebel groups are known to have carried out criminal
attacks against foreigners.
Violent flare ups break out between various armed militia groups and
Sudanese military forces with little notice, particularly in the Darfur
region, along the border between Chad and Sudan, and in areas on
the border with South Sudan. Hostilities between Sudanese forces
and armed opposition groups in Blue Nile and Southern Kordofan
States, including the disputed area of Abyei, present real and
immediate dangers to travellers.
7.12Corruption
Sudan is regarded as one of the most corrupt countries in the world,
ranking 177 out of 182 nations in the 2011 Transparency International
Corruption Perceptions Index.
Sudanese law does not provide criminal penalties for official
corruption, and officials frequently engage in corrupt practices. The
government does not investigate officials suspected of corruption,
and government officials are not subject to financial disclosure laws.
There are no laws ensuring public access to government information.
Sudan signed the UN Anticorruption Convention in 2005 and the
African Union Convention on Preventing and Combating Corruption,
but has yet to ratify either agreement.
7.13Bilateral investment agreements
Sudan has bilateral investment agreements with Germany,
Netherlands, Switzerland, Egypt, France, Romania, China, Indonesia,
Malaysia, Qatar, Iran, Morocco, Oman, Turkey, Yemen, Bahrain,
Ethiopia, Jordan, Syrian Arab Republic, United Arab Emirates,
Switzerland, Egypt, Libya, Tunisia, Algeria, Kuwait, United Arab
Emirates, Lebanon, Chad, Djibouti, India, Vietnam, Netherland,
Bulgaria, and Italy. Sudan has bilateral taxation treaties with Egypt,
United Kingdom, Malaysia, South Africa, Turkey and Syria.
7.14Labour
Complete statistics reflecting the demographic situation in Sudan
after the July 2011 secession of the South are not yet available.
Sudan’s labour force was estimated at 12.2 million in 2010 with a
participation rate of 51.4% for those aged 15-64. The government
of Sudan claimed that the unemployment rate was 13% after the
secession of South Sudan. Most observers believe it to be closer
to 20%. Underemployment is also a significant social problem as
the economy is not creating sufficient jobs for graduating university
students.
The legal minimum wage is 200 Sudanese pounds per month
(approximately US$67). The work week extends from Sunday to
Thursday and is 8 hours per day and 40 hours per week.
Foreign workers must have valid residency and work permits or f
ace imprisonment and deportation. In practice, the majority of
unskilled labour positions are filled by day workers, who are not
reported or taxed.
The absence of a procedure for documenting South Sudanese who
wish to remain in Sudan may be negatively impacting the availability
of labour in certain sectors of the economy, including construction.
The adult literacy rate in Sudan is 69 percent. Gross enrolment rate
in North Sudan in 2009 was 71%. However, only one if five children
completed primary school in 2010.
Sudan has signed and ratified all major ILO conventions protecting
workers rights, but falls short in practice of international standards.
7.15Foreign trade zones/free ports
Sudan has established two free trade zones: Suakin on the Red Sea
near Port Sudan and Aljaily near Khartoum. According to the Free
Zones and Free Markets Law of 1994, industrial, commercial or
service investments which are licensed in the free zones enjoy the
following advantages:
• Exemption of the projects from tax on profits for 15 years,
renewable for an extra period dependant on the decision made by
the concerned minister
• Salaries of expatriates working in projects within the free zones
are exempted from personal income tax
• Products imported into the free zone or exported abroad are
exempted from all customs fees and taxes except service fees
and any other fee imposed by the board of the Sudan Free Zones
Company
• Real estate inside the free zones area is exempted from all taxes
and fees
• Invested capital and profits are transferable from Sudan to abroad
through any bank licensed to operate in the free zone
• Money invested in the free zones may not be frozen or
confiscated
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
8
7.16Foreign direct investment statistics
Inward
2006
2007
2008
2009 2010
3534
2426
2601
2682 1600
7
11
98
Outward
Time to
complete
Sovereign Currency Banking Political Economic Country
risk
risk
sector
risk
structure risk
risk
risk
45 51
7.17Starting a business in Sudan
The table below outlines the steps involved in opening a business in
Sudan. It also details the time involved and the associated costs.
No Procedure
8Country Risk Assessment
Associated costs
1.
Submit application
for preliminary
approval to Registrar
and reserve
company name
3 days
SDG 200
2.
Notarise
2 days
memorandum and
articles of association
SDG 350
3.
Notify taxation
chambers
1 day
4.
Register with
commercial registry
4 days
5.
Conduct site
inspection
2 days
6.
Apply for tax
1 – 2 days
identification number
7.
Register for VAT
2 days
(simultaneous
with previous
procedure)
8.
Register with labour
authorities
14 days
SDG 192
9.
Enrol employees for
social security
3 – 7 days
SDG .25
10.
Make a company
seal
2 days
SDG 40
SDG 55
No charge
SDG 5
No charge
Aug
2012
C
C
C
C
CC
C
(AAA=least risky, D=most risky)
8.1 Sovereign risk
Stable. Sudan’s external debt stock, which we estimate reached
US$38.6bn at end-2011, is mostly in arrears, and the secession in
July 2011 of South Sudan, which has most of the oil, has diminished
its ability to pay further. Despite initial hopes to the contrary, debt
relief after secession is unlikely.
8.2 Currency risk
Stable. The Central Bank of Sudan has allowed the commercial
exchange rate to float, while maintaining the official rate at
SDG2.67:US$1 for the time being. The downward pressure on the
Sudanese pound may now ease, especially if planned budget cuts
are implemented swiftly.
8.3 Banking sector risk
Stable. The banking sector continues to be affected negatively by the
high level of non-performing loans and the impact of international
sanctions.
8.4 Political risk
South Sudan has seceded, but tensions remain high over disputed oil
payments and border areas. Austerity measures to offset the loss of
revenue from the south’s oil will increase pressure on the Sudanese
president. The Darfur conflict remains unresolved, and there is
fighting in South Kordofan and Blue Nile.
8.5 Economic structure risk
Following southern secession, Sudan has lost 75% of the oil upon
which its economy relied, putting pressure on the fiscal and external
balances. Planned austerity measures, levies on southern oil passing
through Sudan’s pipelines (if agreed) and attempts to diversify the
economy will not fully offset this loss.
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
9
9Country Outlook: 2012 –
2016
9.1 Political stability
South Sudan came into existence on July 9th 2011 following a
referendum in which 98.8% of southerners voted for “separation”.
The Sudanese president, Omar al-Bashir, accepted the result and
travelled to Juba, the new southern capital, on Independence Day to
endorse the split. However, the north and south have still not reached
agreement on many aspects of the division, notably oil revenue
and debt, and relations have deteriorated substantially in 2012,
following the stoppage by South Sudan of most of its oil production
in retaliation for Sudan’s unilateral seizures of South Sudanese oil
transported by pipeline across Sudanese territory.
Border incidents have become more serious, with South Sudan
temporarily taking control of the oil-producing area of Heglig in April,
and there is a risk that both governments will be tempted to pursue
military confrontation as a means of diverting their populations from
increasing economic difficulties.
The UN Security Council has set a three-month deadline for
resolution of outstanding issues between the two states. Although
this deadline is likely to be missed, concerted international pressure
has at least led to a resumption of talks – with representatives of the
two governments meeting in the Ethiopian capital, Addis Ababa, in
late May.
9.2 Election watch
Sudan may be tempted to hold presidential and parliamentary
elections before the south, which is due to vote in 2015. Although Mr.
Bashir has repeatedly said that he will not stand again, he has kept
a tight grip on his party since taking total control in 1999 and may
well renege on his pledge. In South Sudan, the President, Salva Kiir,
broadened the representation of South Sudan’s ethnic groups when
he reshuffled his cabinet in August 2011.
Preparation for elections in 2015 will raise tensions within the Sudan
People’s Liberation Movement (SPLM), although the party is unlikely
to split. Mr. Kiir, the leader of the SPLM, is likely to run again for
president.
9.3 International relations
Despite Mr. Bashir’s hopes that he would be rewarded for allowing
the south to secede, US sanctions on Sudan were renewed in
November 2011, partly because of US concerns about Sudan’s
aggression in South Kordofan, Blue Nile and Abyei. Relations with EU
countries have been made more difficult by Mr. Bashir’s International
Criminal Court arrest warrant (issued against him on charges of
genocide in Darfur; the EU states are members of the court, unlike
the US).
Western countries are primarily focused on entrenching the peaceful
secession of South Sudan and preventing any return to a north-south
war. However, Sudan and South Sudan will continue the pattern
of mutual destabilisation – with each government supporting each
other’s domestic enemies – and periodically reverting to more overt
violence and direct confrontation. The Gulf Arab and Asian countries,
particularly China, that have invested heavily in Sudan will continue
to support the government, and Sudan will seek to exploit these
relationships to attract much-needed investment, loans and grants;
South Sudan is also seeking to increase ties with and investment
from China, although recent announcements of an US$8bn, two-year
loan are likely to prove over-optimistic.
9.4 Policy trends
Sudan will seek to diversify its economy away from oil, although
tackling corruption—which would improve the business environment
for private business considerably – will remain little more than a
publicly stated policy goal. Although there will be some expansion
in gold mining, as in the past, Sudan will struggle to attract major
new investment in other sectors, especially from the West, and the
privatisation of large state-owned companies will remain off the
agenda as long the economy remains so unstable.
Weakened by years of violence and underinvestment, South Sudan’s
economy is heavily dependent on oil revenue, which accounts
for 98% of government income (excluding aid), according to the
country’s 2010 and 2011 budgets, and 71% of GDP. Trade with
the north will also be essential. The new state will make progress
developing the legal and regulatory frameworks for the economy
and have some limited success in attracting foreign investment, and
some firms will be tempted by the opportunity of gaining a firstmover advantage in Africa’s newest state.
South Sudan may also benefit from new international loans and
grants, as well as development aid (which it already receives).
However, access to funding may be complicated by concerns about
corruption. Improvements in monetary and fiscal policy will depend
heavily on technical assistance from the IMF and the World Bank.
9.5 Economic growth
For Sudan, the full economic cost of secession will be felt this year,
when oil production is forecast to drop to 140,000 barrels/day (b/d),
lower than the ambitious official target of 195,000 b/d. Government
consumption will consequently decline, which will have a knock-on
effect on private consumption, given the size of the public-sector
workforce. Private investment could also be affected by a lack of
financing and concerns over the political risks facing Mr. Bashir’s
regime.
Unless Sudan’s official data are rebased to a year after secession, the
Economist Intelligence Unit forecasts that the economy will contract
by 7.8% in 2012, owing to the knock-on impact on services revenue
and trade from the increasingly lengthy stoppage in South Sudan’s
oil production (which is piped to the northern terminal at Port Sudan).
Their projection of a contraction this year also takes into account the
impact on domestic demand of a loss of 20% of Sudan’s population
but assumes that the two countries do not return to outright conflict.
After absorbing the shock of the loss of oil and population, the
economy is expected to grow by a modest 2.7% in 2013 and
2.8% in 2014, before picking up to an average of 4.4% in 2015-16,
as the disruption of southern succession fades and government
consumption and investment spending return following the end of
the three-year austerity programme.
In South Sudan the economy will remain oil-dependent. We thus
expect the oil shutdown to be reversed at some point, since if it were
sustained, its impact would be devastating. The exact value of South
Sudanese GDP will be difficult to ascertain until an agreement is
reached with the north regarding oil, and production restarts, but it is
likely to slump this year, before rebounding in 2013.
The economy will be boosted by increased grants and foreign
investment, although donors’ ongoing concerns about corruption
could act as a constraint, and any return to outright conflict would
lead to a sharp fall in such flows. Regional companies, mostly from
Kenya, Uganda and Ethiopia, will lead investment in construction,
manufacturing, consumer goods, power and telecommunications,
centred almost entirely on Juba, far from any conflict areas.
China could, however, play an important role in mediating between
the two states. Southern independence could lead to a weakening
of Sudan’s ties with African states and a strengthening of those with
Arab and Islamic countries.
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
10
9.6Inflation
Inflation pressures in Sudan remain strong, in part reflecting the
impact of a weakening pound on the import bill and high energy
costs – which will be exacerbated if the planned reduction in fuel
subsidies goes ahead. Food price inflation has tended to spike in
response to concerns about political risk, suggesting that the recent
increase in tensions could see price growth accelerate again in the
second half of 2012. Average inflation is expected to rise in 2012, to
22.7%, as the market exchange rate continues to weaken, exceeding
by a significant margin the Central Bank of Sudan’s target of 17% for
this year. Inflation will remain elevated but should decline gradually
in 2013-16, as the exchange rate stabilises at a lower level, averaging
around 12% a year.
South Sudan’s consumer price index has only recently been
established, and the government released its first figures in October.
They showed a surge in inflation in October, probably caused by the
informal blockade imposed on the south by Sudan, its key trading
partner, limiting supplies and raising prices. In addition, relatively high
regional annual average inflation rates also pushed up prices in 2011.
Price rises moderated to 42.2% year on year in February but have
subsequently accelerated again, reaching a reported 80% in May. The
upsurge in inflation is being partly driven by exchange-rate weakness
– reflecting, in turn, the ongoing stoppage of oil production as well as
concerns about increased political risk. Assuming that the oil supply
issue is resolved later this year, we expect inflation to average 50%
in 2012, declining further to 25% in 2013 as global commodity prices
soften.
9.7 Exchange reates
The Central Bank of Sudan operates a managed float of the
Sudanese pound through foreign-currency purchases and daily limits
on the trading band. This is intended to smooth volatility related to
oil exports and foreign direct investment flows. The official exchange
rate depreciated to an annual average of SDG2.68:US$1 in 2011, an
increasingly unrealistic premium on the black-market rate, and we
forecast that it will weaken to an average of SDG3.50:US$1 in 201214, before depreciating more slowly in 2015-16.
The Bank of South Sudan also operates a managed float of its
currency, the South Sudanese pound, which was initially intended
to have parity to the Sudanese pound. The Bank of South Sudan’s
ability to defend the currency is questionable, and “options” for
harmonising the official and parallel-market exchange rates are to be
discussed, according to the austerity budget announced in April. If
followed through, this is likely to involve some form of devaluation.
The shutdown of oil production is having a negative effect, resulting
in a sharp depreciation of the market rate of the South Sudanese
pound to around SSP5:US$1, although the official rate remains
unchanged at SSP2.95:US$1.
9.8 External sector
In Sudan, demand for imports is expected to drop in 2012 owing to
the post-secession fall in population and declines in government
spending and private consumption. With a weaker currency also
depressing demand for imports, we expect the import bill to dip from
an estimated US$8.2bn in 2011 to just US$6.6bn this year, before
rising gradually to US$7.5bn in 2016 as the strengthening economy
draws in increased capital inputs and consumer goods. Meanwhile,
with the loss of southern oilfields pushing exports down dramatically,
the trade balance is expected to move from an estimated surplus of
US$1.5bn in 2011 to a deficit of US$3.1bn in 2016. After an estimated
surplus of US$208m in 2011, the current account is expected to
register a shortfall of US$3.2bn (4.3% of GDP) in 2012. However,
the current account will benefit from lower repatriation of profits
by foreign oil companies, as well as a reduction in services debits.
Assuming that agreement is reached between north and south on
transit fees for southern oil, providing a boost to services credits,
the current-account deficit is expected to narrow to US$2.3bn (3.3%
of GDP) in 2013. Despite a steady pick up in imports, the deficit will
remain broadly stable, at around 3.4% of GDP, in 2014-16.
Although South Sudan’s domestic demand for oil is modest
(providing more for export abroad), the shutdown of oil production
will have a dramatic effect on the trade surplus, which we forecast
will narrow markedly to US$1.6bn in 2012. This is likely to be
insufficient to offset the non-merchandise deficit, reflecting the
country’s dependence on foreign skills and profit repatriation by
foreign oil companies, and thus we expect the current account to
return a deficit this year of around US$5m. However, in 2013, with
oil exports recovering, current transfer credits rising (on the back of
higher aid inflows) and the agricultural sector beginning to realise its
potential (which will lower dependence on food imports), we expect
the current account to move back into surplus.
A.1Appendix two - sources
of information
• Economist Intelligence Unit
• CIA World Factbook
• Bloomberg
• World Bank
• Wikipedia
• US Department of State
© 2012 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity. All rights reserved. MC7204 KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity. The foregoing information is for general use only. NKC does
not guarantee its accuracy or completeness nor does NKC assume any liability for any loss which may result from the reliance by any person upon such information or opinions.
11