The Kokoda Campaign Tours website does little to unscramble what seems to be an organizational omelette in PNG – this is usually a sign that owners are not upfront and prefer to operate from the shadows.

This perception is reinforced by the fact there are no profiles of the company owners on either their website or their Facebook Page which they seem to use as a vehicle for making snide remarks about other Kokoda tour companies.

Official PNG records need to be treated with caution due to the lack of governance in the PNG Government sector where front office staff have been known to ‘facilitate‘ transactions ‘over the counter‘ in return for cash. This is made easier by a lack of enforcement of their rules and regulations by Government agencies when breaches are brought to their attention.

One would hope that a pilgrimage tourism industry based on the values of the Kokoda campaign would act as a moral beacon for those involved in leading treks across the Kokoda Trail.

Unfortunately, this is not always the case – rather than try to make the system work some try to ‘work the system‘!

Official Company Records – Australia and PNG

Grafton based Kokoda Campaign Tours P/L (ACN 151 673 004) was registered with the Australian Securities and Investment Commission (ASIC) on 23 June 2011.

Grafton based Australian and PNG Tours P/L (ACN 615 838 376) was registered by ASIC on 10 November 2016. The company is not registered with the PNG Investment Promotion Authority (IPA) as either a ‘Foreign Enterprise’ or as an ‘Overseas Company’ as required by the IPA Act – or with the Kokoda Track Authority (KTA) as a licensed Kokoda tour operator`.

According to IPA records, Australian and PNG Tours P/L registered Kokoda Campaign Tours P/L as an ‘Overseas Company’ on 3 February 2012 – their ‘Business Activity’ is registered as ‘Other Community, Social and Personal Service Activities’ – there is no mention of Kokoda tourism. On 24 July 2022 they registered a ‘Change of Directors for Overseas Company’ and on 25 January they lodged an ‘Application for Re-Registration of Overseas Comany’.

On 2 February 2023 Kokoda Campaign Tours applied for a ‘Foreign Enterprise Certification’ for an ‘Overseas Company’ – it was approved a month later on 6 March 2023.

The approval process, according to the IPA Information Guide, advises:

The Authority is required to make a decision on a complete and correct application within 35 working days. The application, if complete and correct, must first be considered at a Management Certification Committee, which are held every two weeks. After consideration, the Management makes appropriate recommendations on each application to the Board for approval. Board Members must then endorse the recommendations. Upon board approval, a formal IPA Certificate will be issued displaying the name of the foreign Enterprise, the nature of business activity, the principle location of business, other terms and conditions of Certification.

The approval process for Kokoda Campaign Tours seems to have been fast-tracked.  It certainly differed from Adventure Kokoda P/L who engaged LLLS Lawyers, to ensure compliance in obtaining Foreign Enterprise Certification and to establishing a PNG company (Adventure Kokoda (PNG) Ltd-1:118228) in accordance with their IPA Act.

Adventure Kokoda P/L was required to provide proof of our previous agreement our PNG logistics provider, Sogeri Enterprises Pty Ltd, from 2002-2019 along with details of their operating location before the certification was approved. The process took three (3) months after the company lodged the required amount of K100,000.

The IPA Information Guide also advises:

‘A company has an obligation to report its activities annually. It does this by submitting an Annual Return to the Office of the Registrar of
Companies . . .

‘It is an offence under Section 41 of the Act for a foreign enterprise to operate without an IPA certificate, carry on business in a Reserved activity, or fail to comply with a Term or Condition of Certificate as is- sued. A penalty of up to K100,000.00 may be imposed or a default penalty fine not exceeding K10, 000.00.

There is no indication of any penalty being imposed for their failure to lodge Annual Returns as required by the IPA Act in 2012, 2013, 2014, 2015, 2016, 2017, 2018, 2019, 2020, 2021 or 2022. 

According to the IPA Information Guide for Foreign Enterprise Certification:

‘A foreign enterprise is a business entity which is wholly owned or that is 50 percent or more owned or controlled and managed by non-citizens . . .‘

There are no listings of PNG shareholders on the IPA documentation approving the registration of Australian Kokoda Tours as an ‘Overseas Company.

It is also worth noting that the Kokoda Track Authority (KTA) continued to issue trek permits to Kokoda Campaign Tours in breach of their own ‘Commercial Operations Licence Conditions 2012’ from 2012-2022.

Another anomaly relates to the different addresses:

  • According to IPA the registered address for Kokoda Campaign Tours P/L is listed at ‘Kokoda Block Portion No #172, Kokoda, South Grafton, SOHE, Northern (Oro Province), Papua New Guinea’.
  • According to the registration on the Kokoda Track Authority website the contact details are listed as 0400 273 170, www.kokodacampaigntours.com.au.
  • According to the ‘Kokoda Gold’ website (see below) their address is listed as 370 Fry Street, Grafton NSW 2460 Australia.

Kokoda Gold

A new website ‘Kokoda Gold‘ advises it is an Australian based company formed as an offshoot of Kokoda Campaign Tours. The webiste advises:

‘Kokoda Campaign Tours is owned by Scott Campbell and Stuart Jonklaas and for years has been taking trekkers to Papua New Guinea to experience one of the world’s greatest challenges Trekking the Kokoda Track. This, according to Scott & Stuart, requires a large group of porters to carry all the necessities for a successful crossing including food porters, cooks and personal porters for the trekkers and KCT has an amazing loyal team based in Oro Province. It is this dedication and loyalty given to KCT and their respective trekkers that gave rise to the idea of finding other ways to support these amazing people.’

Reminiscent of the ‘Dodgy brothers‘ beating kundu drums PNG?

According to Scott Campbell and Stuart Jonclaas:

‘When we approached our Trek Masters in Kokoda for an idea of how we could help the communities which provided most of our porters, they suggested that a `Cocoa Export Business’ would suit them, as there were vast untapped resources in the way of cocoa plantations already in the Oro Region which could be brought back into production. They would be able to provide the local farmers with choices as to where to sell their Cocoa Bean and in turn would give their children a future in the Kokoda Region without them needing to travel to Popondetta and Port Moresby for work.

‘From these discussions and an almost impossible dream, due to the rules regarding the granting of Cocoa Export Licences, The Pavau Cocoa Export Company was born. Kokoda Gold was then formed to market the Cacao Bean in Australia with the mission of providing a future for the communities and hopefully a better price for the farmers of Oro Province for their Cacao Bean.’

According to the IPA website ‘Kokoda Gold’ is not registered as a Foreign Enterprise or as an Overseas Company and neither the ‘Pavau Cocoa Company’ nor the ‘Pavau Cocoa Exprt Company’ are registered as a PNG company.

Conclusion

The apparent ‘fast-tracking‘ of the application for Foreign Enterprise Certification by Kokoda Campaign Tours P/L and the lack of any penalty for non-compliance over an 11-year period indicates it may well have been an ‘over the counter‘ arrangement at the IPA front office rather than one that followed due process as per the Act.

It’s difficult to unscramble the relationship between Australian and PNG Tours P/L, which is not registered with the IPA as either a Foreign Enterprise or an Overseas Company, or with the Kokoda Track Authority as a licensed Kokoda tour company. Despite this they were able to register Kokoda Campaign Tours P/L as an Overseas Company in PNG on 2 February 2023.

But Kokoda Campaign Tours P/L had already registered itself as an ‘Overseas Company’ four years earlier on 3 February 2012!

The owners of Kokoda Campaign Tours could help clear the air by:

  • Providing copies of their Annual Returns for 2013, 2014, 2015, 2016, 2017, 2018, 2019, 2020, 2021 and 2022;
  • Posting profiles of the owners-directors of Kokoda Campaign Tours P/L on their website;
  • Providing copies of their bank transfers of K100,000 to each of their PNG bank accounts for the Foreign Enterprise Certification for Australian and PNG Tours P/L and Kokoda Campaign Tours P/L;
  • Providing the Tax Identification Number (TIN) allocated by the Internal Revenue Commission (IRC) for each company;
  • Advising the details of the PNG company directors and their shareholdings in the Overseas Company they have registered in accordance with the IPA Act; and
  • Advising the registration details of ‘Kokoda Gold’ with ASIC in Australia along with the registration of Pavau Cocoa Company or Pabau Cocoa Export Company with the IPA in PNG.

These details can be advised in the ‘Leave a Reply’ box below – until then the principle of ‘Caveat Emptor‘ (i.e. let the buyer beware) should prevail in any dealings with Kokoda Campaign Tours P/L; Australian and PNG Tours P/L; and Kokoda Gold.

Details of ASIC, IPA and KTA records are contained in the following .pdf file: