Anti-Corruption Activity Coordination (NG0009)
Action Plan: Nigeria National Action Plan 2017-2019
Action Plan Cycle: 2017
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 AreasAnti-Corruption, Anti-Corruption Institutions, Education, Extractive Industries, Health, Infrastructure & Transport, Legislation & Regulation, Private Sector, Public Participation, Public Service Delivery, Whistleblower Protections
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.  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.  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.  There is little or no transparency or accountability in sports, leading to allegations of corruption.  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.  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. 
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.  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. 
Between 2008 and 2009, various whistleblower protection bills (Milestone 9.6) were developed,  but at the time of this report, there is still no law that establishes a comprehensive framework for whistleblower protection in Nigeria.  A Whistle Blower Protection Bill, 2017 [HB. 17.06. 1073] is being processed before the National Assembly.  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. 
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.  Information can be submitted via the FMF-Whistle, a secure online portal,  which also permits the person disclosing the information to check the status of reported matters. 
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. 
Practitioner partnerships for institutional integrity are located within the United Kingdom’s new international program aimed at eliminating corruption and strengthening government integrity.  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)  could prevent corruption in sports, therefore protecting its integrity and encouraging investments in Nigerian sports.  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.  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),  and compensation for victimization of whistleblowers. 
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.
NG0015, 2019, Anti-Corruption
Implement Open Contracting and the Open Contracting Data Standard
NG0016, 2019, Access to Information
Transparent Tax Revenue Reporting
NG0017, 2019, Access to Information
Open Contracting and Licensing in Extractives
NG0018, 2019, Access to Information
Implement EITI Standard
NG0019, 2019, Anti-Corruption
Establish Beneficial Ownership Registry
NG0020, 2019, Access to Information
Strengthen Asset Recovery Legislation
NG0021, 2019, Anti-Corruption
Implement National Anti-Corruption Strategy
NG0022, 2019, Anti-Corruption
Improve Compliance with Freedom of Information Act with Focus on Records Management
NG0023, 2019, Access to Information
Improved Compliance with Mandatory Publication Provisions Requirement (FOIA)
NG0024, 2019, Access to Information
Implement Permanent Dialogue Mechanism
NG0025, 2019, Access to Justice
Aggregate Citizens' Feedback on Programs
NG0026, 2019, E-Government
Freedom of Association, Assembly, and Expression
NG0027, 2019, Civic Space
Enhance Participation of the Vulnerable
NG0028, 2019, Capacity Building
Implement New Computer Program in 6 Government Ministries to Improve Service Delivery
NG0029, 2019, Capacity Building
Legal Instrument to Strengthen SERVICOM
NG0030, 2019, Legislation & Regulation
Citizen Participation in Budget Cycle
NG0001, 2017, Access to Information
NG0002, 2017, Access to Information
Extractive Sector Transparency
NG0003, 2017, Access to Information
Tax Reporting Standards
NG0004, 2017, Fiscal Openness
World Bank Doing Business Index
NG0005, 2017, Fiscal Openness
Beneficial Ownership Register
NG0006, 2017, Anti-Corruption
Anti-Corruption Informationi Sharing
NG0007, 2017, Anti-Corruption
Asset Recovery Legislation
NG0008, 2017, Capacity Building
Anti-Corruption Activity Coordination
NG0009, 2017, Anti-Corruption
FOIA Compliance for Annual Reporting
NG0010, 2017, Access to Information
FOIA Compliance for Disclosure
NG0011, 2017, Access to Information
Permanent Dialogue Mechanism
NG0012, 2017, Fiscal Openness
Joint Governmnet-Civil Society Legislation Review
NG0013, 2017, Fiscal Openness
Technology-Based Citizens' Feedback
NG0014, 2017, E-Government