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Anti-Corruption Activity Coordination (NG0009)



Action Plan: Nigeria National Action Plan 2017-2019

Action Plan Cycle: 2017

Status: Inactive


Lead Institution: Federal Ministry of Justice

Support Institution(s): Ministry of Information and Culture, National Orientation Agency, Economic and Financial Crimes Commission, Code of Conduct Bureau, Independent Corrupt Practices and other Related Offences Commission, Ministry of Youth and Sports Development, Ministry of Communication, Ministry of Science and Technology, Nigeria Football Federation. Public What You Pay, African Centre for Leadership, Strategy & Development, Digital Forensics, PGL, African Network for Economic and Environmental Justice, Freedom of Information Coalition, Global Network for Cyber Solutions, Sports Lawyers Association, Nigerian Bar Association, WANGONeT, Nigerian Labour Congress, Council for the Regulation of Engineering in Nigeria, MSME-ASI, Association of National Accountants of Nigeria, Open Judiciary Institute, Ethics and Compliance Institute, Inter-Religious Bodies/Council, The Christian Association of Nigeria, Council of Ulamahs, other Sports Associations

Policy Areas

Anti-Corruption, Anti-Corruption Institutions, Education, Extractive Industries, Health, Infrastructure & Transport, Legislation & Regulation, Private Sector, Public Participation, Public Service Delivery, Whistleblower Protections

IRM Review

IRM Report: Nigeria Implementation Report 2017-2019, Nigeria Design Report 2017-2019

Starred: No

Early Results: Marginal

Design i

Verifiable: Yes

Relevant to OGP Values: Access to Information , Civic Participation , Public Accountability , Technology

Potential Impact:

Implementation i



This commitment is to take a wide range of actions that will change the culture of corruption and create the enabling environment for building institutional integrity in Nigeria

IRM Midterm Status Summary

9: Commit to taking appropriate action to co-ordinate anti-corruption activities; improve integrity, transparency and accountability

Language of the commitment as it appears in the action plan:

“This commitment is to take a wide range of actions that will change the culture of corruption and create the enabling environment for building institutional integrity in Nigeria.”


9.1. To set up a cabinet to co-ordinate anti-corruption efforts of government and provide national accountability on the implementation of anti-corruption strategy.

9.2. To join the International Sports Integrity Partnership.

9.3. To launch a Practitioner Partnership on Institutional Integrity in the Public and Private Sector with special emphasis on the extractives, health, education, professional bodies, anti-corruption institutions and infrastructure development.

9.4. To adopt the National Anti-Corruption Strategy (NACS), working closely with CSOs.

9.5. To create an innovation hub that will facilitate the update of new approaches and technologies to tackle corruption and improve access to information.

9.6. Introduction and passage of the Whistleblower Act.

Start Date: January 2017 End Date: June 2019

Action plan is available here:

Context and Objectives

This commitment brings together a wide-ranging set of milestones that address corruption, which remains widespread in Nigeria.

The country has consistently ranked poorly on Transparency International’s Corruption Perceptions Index—ranking 136 out of 176 countries in 2016, and 148 in 2017. [105] A 2017 Afrobarometer survey found that although many Nigerians believe the government is doing “fairly well” or “very well” in fighting corruption, public perception of corruption is still high for police officers, National Assembly members, and local government councilors. [106] Between 2015 and 2016, almost a third of Nigerian adults paid bribes when in contact with public officials, almost one bribe was paid by every adult Nigerian per year, and roughly 400 billion Nigerian Naira was spent on bribes each year. [107] There is little or no transparency or accountability in sports, leading to allegations of corruption. [108] For example, in 2016, the Super Falcons (the female national football team) staged open protests against the Nigerian Football Federation (NFF) for denying them their allowances after they won the Nations Cup in Cameroon. [109] In December 2016, the International Football Federation suspended its development grant to the NFF claiming that the organization could not account for an earlier grant of $1.1 million. [110]

A variety of actions under Commitment 9 were initiated prior to the commitment period. For example, regarding Milestones 9.1. and 9.4, there have been various efforts over a decade to develop a Nigerian national anticorruption plan. Between 2009 and 2016, no less than three draft national anticorruption plans or strategies were formulated. [111] Launching a Practitioner Partnership on Institutional Integrity (Milestone 9.3) derives from commitments made by Nigeria and the United Kingdom during the 2016 Anti-Corruption Conference. [112]

Between 2008 and 2009, various whistleblower protection bills (Milestone 9.6) were developed, [113] but at the time of this report, there is still no law that establishes a comprehensive framework for whistleblower protection in Nigeria. [114] A Whistle Blower Protection Bill, 2017 [HB. 17.06. 1073] is being processed before the National Assembly. [115] At the time of this report, only public officers are protected against civil or criminal proceedings for the disclosure of information in good faith under section 27 of the Freedom of Information Act, 2011. [116]

In 2016, the Federal Ministry of Finance introduced a whistleblowing policy, designed to encourage anyone with information about a violation of financial regulations, mismanagement of public funds and assets, financial malpractice, fraud, or theft to submit such information to the authorities. [117] Information can be submitted via the FMF-Whistle, a secure online portal, [118] which also permits the person disclosing the information to check the status of reported matters. [119]

This commitment is relevant to all three OGP core values. The innovation hub under Milestone 9.5 can improve access to information on Nigeria’s anticorruption efforts, while Milestone 9.4 calls for working closely with civil society in adopting the NACS and thus is relevant to civic participation. Additionally, passing the long-awaited Whistleblower Protection Act is relevant to public accountability. The commitment also addresses the OGP value of technology and innovation for transparency and accountability via Milestone 9.5.

The activities are mostly verifiable. Verifiable milestones included setting up the anticorruption cabinet and joining the ISIP. Milestone 9.4, however, does not explain how civil society will be consulted in developing the NACS, nor how their input will be incorporated and there is little detail provided for the innovation hub (Milestone 9.5).

This commitment has a moderate potential impact on addressing corruption in Nigeria. The mere finalization and adoption of a national anticorruption strategy will be a major step forward, as no previous anticorruption strategy reached this stage. The proposed NACS is also comprehensive and calls for civil society support to cement the Nigerian government’s commitment to tackle corruption and close gaps in existing initiatives. The NACS is based on corruption prevention, enforcement and sanctions, public engagement, a campaign for ethical reorientation, and recovery of stolen assets. [120]

Practitioner partnerships for institutional integrity are located within the United Kingdom’s new international program aimed at eliminating corruption and strengthening government integrity. [121] Based on development economist Paul Collier’s notion of “twinning,” the program seeks countries to share high professional standards and best practices in taxes, budgets, natural resource management and accounting.

If successful, the partnership between Nigeria and the UK will strengthen government capacity in the areas listed in Milestone 9.3.

According to Barbara Maigari, Program Manager of Partners West Africa (PWA), joining the International Sports Integrity Partnership (Milestone 9.2) [122] could prevent corruption in sports, therefore protecting its integrity and encouraging investments in Nigerian sports. [123] ISIP members are required to improve information-sharing between international sports organizations and law enforcement; take legislative or other measures to combat practices such as match-fixing, illegal betting, and doping; and enact whistleblower protection.

Adopting the Whistleblower Act (Milestone 9.6) will make the principles and mechanisms set out in the 2017 bill binding. [124] These include immunity for protected disclosures (extending to immunity from civil or criminal liability alongside protection from disciplinary actions, loss of employment, or termination of services), [125] and compensation for victimization of whistleblowers. [126]

Next Steps

Future commitments in this area should include:

  • Narrowing down the scope of the commitment to the groups that are specifically perceived as corrupt (police officers, National Assembly members, and local government councilors);
  • Tailoring milestones to address corruption in these sectors; and
  • Including civil society in developing the NACS and report how their input influences the final strategy.
[105] Transparency International, “Corruption Perception Index 2017” (21 Feb. 2018),
[106] Oluwole Ojewale and Josephine Appiah-Nyamekye, “In Nigeria, perceived corruption remains high despite praise for president’s anti-graft fight” Dispatch No. 187 (Afrobarometer 8 Feb. 2018),
[107] United Nations Office on Drugs and Crime and Nigerian National Bureau of Statistics, Corruption in Nigeria, Bribery: Public experience and response (Jul. 2017),
[108] Barbara Maigari (program manager, PWA), interview by IRM researcher, 5 Mar. 2019.
[109] Punch, “Taint of Corruption in Nigerian Football” (21 Mar. 2017),
[110] Id.
[111] In 2015, President Buhari prepared a draft National Anti-Corruption Plan (NACP). The NACP was based on an earlier draft National Strategy to Combat Corruption developed between 2009 and 2011 by a public sector Inter-Agency Task Team under the auspices of the United Nations Convention Against Corruption. President Buhari established a Presidential Advisory Committee Against Corruption in August 2015 to finalize the NACP in collaboration with all relevant stakeholders, including CSOs. A consultative NACP was submitted to the Attorney-General in November 2015, but in December 2016, yet another anticorruption document was put forward by the Federal Ministry of Justice. Fatima Waziri-Azi, “An evaluation of the Nigerian national anti-corruption strategy” European Journal of Research in Social Sciences 5 no. 5 (2017) 1, 3 – 4.
[112] The establishment of Practitioner Partnerships on Institutional Integrity with various countries is part of the United Kingdom’s cross-government 2016 Anti-Corruption Strategy. “Anti-Corruption Summit, London, 2016, UK Country Statement,”
[113] Ibrahim Sule, “Whistleblowers’ protection legislation: In search for a model for Nigeria” Nigerian Journal of Law Practice and Procedure of Legislature (2009),; a Whistleblower Protection Bill [SB233] is also available on the website of the Nigerian National Assembly, see
[114] NaijaLegalTalk, “An appraisal of the whistle-blowing policy in Nigeria” (9May 2017),
[116] Freedom of Information (FOA) Act, 2011 §27
[117] Federal Ministry of Finance, Nigeria, “FMF Whistle Blowing – Frequently Asked Questions”, “
[119] Federal Ministry of Finance, Nigeria “FMF Whistle Blowing – Frequently Asked Questions”, “
[120] Omole Temitope Alice, “Highlights of the National Anti-corruption Strategy (NACS) for Nigeria” (Nigerian Institute of Advanced Legal Studies),
[121] UK Government, “UK to lead global partnerships to tackle corruption” (12 May 2016),
[122] The ISIP, launched in 2017, is an initiative to support and strengthen efforts to implement high standards of transparency and good governance to eliminate corruption in sports. See
[123] Maigari, interview.
[124] Id.
[125] Whistleblower Protection Bill, 2017 §23.
[126] Id. §26.


  1. Participatory Budgeting

    NG0015, 2019, Anti-Corruption

  2. Implement Open Contracting and the Open Contracting Data Standard

    NG0016, 2019, Access to Information

  3. Transparent Tax Revenue Reporting

    NG0017, 2019, Access to Information

  4. Open Contracting and Licensing in Extractives

    NG0018, 2019, Access to Information

  5. Implement EITI Standard

    NG0019, 2019, Anti-Corruption

  6. Establish Beneficial Ownership Registry

    NG0020, 2019, Access to Information

  7. Strengthen Asset Recovery Legislation

    NG0021, 2019, Anti-Corruption

  8. Implement National Anti-Corruption Strategy

    NG0022, 2019, Anti-Corruption

  9. Improve Compliance with Freedom of Information Act with Focus on Records Management

    NG0023, 2019, Access to Information

  10. Improved Compliance with Mandatory Publication Provisions Requirement (FOIA)

    NG0024, 2019, Access to Information

  11. Implement Permanent Dialogue Mechanism

    NG0025, 2019, Access to Justice

  12. Aggregate Citizens' Feedback on Programs

    NG0026, 2019, E-Government

  13. Freedom of Association, Assembly, and Expression

    NG0027, 2019, Civic Space

  14. Enhance Participation of the Vulnerable

    NG0028, 2019, Capacity Building

  15. Implement New Computer Program in 6 Government Ministries to Improve Service Delivery

    NG0029, 2019, Capacity Building

  16. Legal Instrument to Strengthen SERVICOM

    NG0030, 2019, Legislation & Regulation

  17. Citizen Participation in Budget Cycle

    NG0001, 2017, Access to Information

  18. Open Contracting

    NG0002, 2017, Access to Information

  19. Extractive Sector Transparency

    NG0003, 2017, Access to Information

  20. Tax Reporting Standards

    NG0004, 2017, Fiscal Openness

  21. World Bank Doing Business Index

    NG0005, 2017, Fiscal Openness

  22. Beneficial Ownership Register

    NG0006, 2017, Anti-Corruption

  23. Anti-Corruption Informationi Sharing

    NG0007, 2017, Anti-Corruption

  24. Asset Recovery Legislation

    NG0008, 2017, Capacity Building

  25. Anti-Corruption Activity Coordination

    NG0009, 2017, Anti-Corruption

  26. FOIA Compliance for Annual Reporting

    NG0010, 2017, Access to Information

  27. FOIA Compliance for Disclosure

    NG0011, 2017, Access to Information

  28. Permanent Dialogue Mechanism

    NG0012, 2017, Fiscal Openness

  29. Joint Governmnet-Civil Society Legislation Review

    NG0013, 2017, Fiscal Openness

  30. Technology-Based Citizens' Feedback

    NG0014, 2017, E-Government

Open Government Partnership