Monitoring the Nigerian National Action Plan on Business and Human Rights (NG0051)

Thematic Area: Business and Human Rights

Commitment: Review, Ensure, and Monitor the Implementation of the Nigerian National Action Plan on Business and Human Rights.
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Brief Description of Commitment:
This commitment aims to promote responsible business practices that respect human rights across Nigeria's key economic sectors by implementing the National Action Plan on Business and Human Rights (NAPBHR). Through transparent policies, stakeholder engagement, and accountability mechanisms, the commitment will foster corporate respect for human rights, address violations (e.g., labour rights abuses, environmental degradation, and community conflicts), and enhance access to remedies. The NHRC and ACCI will lead a multi-stakeholder process to ensure inclusive policy development, public access to information, and effective grievance mechanisms, aligning with the United Nations Guiding Principles on Business and Human Rights (UNGPs).

General Problem/Challenge Addressed by the Commitment:
Nigeria adopted a National Action Plan on Business and Human Rights but lacks a clear system to track whether government agencies are acting on their commitments. Without regular monitoring, there is no way to know which actions have been completed, which are delayed, and which have stalled entirely. This creates three problems.
1. Government agencies face no pressure to follow through on assigned responsibilities.
2. Citizens and civil society cannot hold duty bearers accountable because progress data is not publicly available.
3. Gaps between policy commitments and actual implementation go undetected and unresolved.
The commitment addresses the absence of a structured, transparent, and inclusive mechanism to review progress, identify bottlenecks, and ensure the NAP delivers real outcomes for affected communities.

Specific OGP Issue(s) in Focus:
Corporate Accountability; Civic Participation; Access to Information. Rights Protection, Transparency

Rationale for the Commitment:
Nigeria's economic sectors, including livestock (a focus of ACCI's activities) and extractives, face human rights challenges, including forced labour, environmental pollution, and land disputes (e.g., farmer-herder conflicts). The absence of a fully implemented NAPBHR, coupled with limited transparency in corporate practices, hinders accountability. This commitment leverages the NHRC's mandate to protect human rights and ACCI's private sector influence to drive policy reforms, stakeholder collaboration, and public participation, aligning with OGP's open government principles and Nigeria's commitments under the UNGPS.

Main Objective:
• Review, Adopt, and Implement a Transparent NAPBHR: Review, improve and operationalise the National Action Plan on Business and Human Rights through inclusive, publicly accessible processes.
• Enhance Corporate Accountability: Establish mechanisms to monitor and report human rights impacts of businesses in the selected sectors with vulnerabilities.
• Strengthen Access to Remedies: Create accessible grievance and redress mechanisms for communities and workers affected by business activities.
• Promote Stakeholder Engagement: Foster multi-stakeholder collaboration involving government, private sector, civil society, and communities to ensure inclusive policy implementation.
• Increase Public Awareness and Participation: Use open data and civic engagement to educate citizens and businesses on human rights responsibilities.

Anticipated Impact:
Short-Term (by Dec 2026): Finalised NAPBHR, established monitoring and grievance mechanisms, and increased awareness among 1 million citizens and 50 businesses. Medium-Term (by Dec 2027): 20% reduction in human rights violations in the livestock, manufacturing, supply chain, and extractive sectors, 100 grievances resolved, and 1,000 stakeholders trained.
Long-Term: Nigeria becomes a regional model for business and human rights, with a scalable NAPBHR framework adopted in other African OGP countries.
Legislative Alignment - Completion of the review of the Labour Act and CAMA to include BHR clauses.
Institutionalisation - Number of BHR Desk Officers trained and active amongst stakeholders like the Ministry of Mines and Steel Development, and NUPRC, etc
• Remedy Access - Number of cases successfully mediated via the National Human Rights Commission without escalating to long-term litigation.

Expected Outcomes | Milestones (Performance Indicators)
1. Stakeholders are well-grounded in the framework
• Trained business representatives report confidence in applying human rights due diligence standards within their organisation.
• Government agencies operationalise business and human rights desk officers with documented handbooks and reporting mechanisms.
• Key stakeholders demonstrate proficiency in UNGPs and NAPBHR implementation as measured by post-training assessments.
2. Establish a Business and Human Rights Action Plan Implementation Monitoring Framework
• Establish a round table for the implementation of the existing NAP-BHR to partner or collaborate with the already established National Working Group (NWG-BHR)
• Encourage the cascading of the same Working Group to the States (Sub-National)
• Baseline and mid-term human rights impact assessment completed with documented findings and sectoral recommendations
3. Establish a National Centre For Business and Human Rights and Create Grievance and Redress Mechanisms
• Grievances and complaints received, mediated and resolved through an accessible mechanism in selected sectors, with increased satisfaction rated among complainants.
• Documented case studies and remedial outcomes published, demonstrating effective grievance redress without escalation to protracted litigation.
• National Centre for Business and Human Rights established with staffing, operational protocols, and linkages to NHRC documented.
• Community satisfaction survey shows confidence in the grievance mechanism accessibility, fairness and timeliness
4. Establish a desk for Business and Human Rights in each state Chamber of Commerce, and Conduct Capacity-Building Programs
• Support desks established with trained personnel and documented operational procedures
• Target SMEs receive targeted capacity building on human rights compliance
• State-level chamber staff demonstrate competency in mentoring and advising member businesses on human rights due diligence and grievance mechanisms
• Target sectors adopt documented human rights policies or grievance-handling procedures, verified through desk-based compliance assessment.
5. Launch Public Awareness Campaign
• Citizens reached through integrated media, social media and community outreach campaigns with demonstrated awareness of corporate human rights responsibilities.
• Pre-and post-campaign awareness surveys show an increase in public knowledge of business human rights violations and the remedy mechanisms
• Community-level dialogues conducted in affected areas, documenting citizens' concerns and remedy pathways
6. Establish a Multi-Stakeholder Oversight Committee
• A multi-stakeholder oversight committee formally constituted with representation from government, the private sector, civil society, and affected communities, with a charter and documented governance procedures.
• Committee convenes monthly with documented attendance, minutes, decisions, and escalation protocols, submitting reports to the OGP NSC.
• Oversight committee reviews and approves selected human rights impact assessments and corresponding remedial action plans

Planned Activities | Start Date | End Date | Expected Output(s) | Output Indicator(s)
1. Conduct multi-stakeholder consultations to finalize the NAPBHR, ensuring transparency and public input. | Jan 2026 | Dec 2027 | • A finalized and validated NAPBHR document that reflects input from all stakeholder groups. • Consultation reports documenting feedback received, issues raised, and how they were addressed. • A stakeholder participation register showing representation across government, civil society, private sector, and affected communities. • A public summary of the consultation process and outcomes, published on a government website or portal. | • Number of multi-stakeholder consultation sessions held (disaggregated by geopolitical zone or sector). Number and diversity of participants across all sessions (disaggregated by government, civil society, private sector, academia, and affected communities). Number of written submissions or recommendations received from stakeholders. Percentage of stakeholder recommendations reflected in the final NAPBHR document. • Number of consultation reports produced and published. Publication date of the finalized NAPBHR document. • Number of platforms or channels used to invite public input (physical meetings, online portals, written submissions).
2. Publish the plan on an open government portal. | Jan 2026 | Jun 2026 | • The finalized NAPBHR document uploaded and accessible on a designated open government portal. A public notification or announcement informing citizens and stakeholders that the plan is available online. The document published in accessible formats (PDF, HTML, and plain language summary). A feedback mechanism linked to the published plan allowing citizens to submit comments or questions | NAPBHR document published on an open government portal. • Number of accessible formats in which the plan is published. Number of public notification channels used to announce publication. Number of downloads or views of the published document within the first 6 months. • Availability of a citizen feedback mechanism on the portal. Number of citizen comments or questions received through the feedback mechanism within 6 months.
3. Establish accessible grievance mechanisms for communities and workers affected by business activities, integrated into NHRC's mandate | Jul 2026 | Jun 2027 | • A formal grievance mechanism framework document approved by NHRC and relevant MDAs. • Designated grievance intake points operational at NHRC offices across all geopolitical zones. A standardized complaint form and process guide available in English and major local languages. • A digital grievance submission portal accessible via web and mobile. Trained NHRC staff and focal officers equipped to receive, process, and escalate business and human rights complaints. Public awareness materials informing communities and workers about how to file grievances. | Number of grievance intake points established and operational across NHRC offices. Number of languages in which the complaint form and process guide are available. Existence of a functional digital grievance submission portal (yes/no). Number of NHRC staff trained on receiving and processing business and human rights grievances. Number of public awareness campaigns conducted to inform affected communities and workers about the grievance mechanism. • Number of grievances received through the mechanism within the first reporting period. Average time taken to acknowledge receipt of a grievance after submission. Number of grievances resolved or escalated within the defined timeline. • Number of geopolitical zones with at least one operational grievance intake point. Number of community and worker groups directly engaged during the rollout of the mechanism.
4. Train businesses, government agencies, and communities on UNGPS and NAPBHR implementation, focusing on selected sectors. | Jan 2026 | Dec 2027 | • Training curriculum and material developed covering UNGP's NAPBHR, human rights due diligence, and remedy mechanism • Training sessions conducted for sectorial stakeholders. Training completion and competency assessment reports documenting participant knowledge gains, application | • Number of training sessions held. • Percentage of participants reporting improved knowledge. • Training materials published online
5. Use media, X, and community outreach to raise awareness of business and human rights responsibilities, targeting 1 million citizens. | Jan 2026 | Dec 2027 | Social media campaign launched • Media features in reputable news outlets documenting business human rights issues and NAPBHR benefits. | Number of awareness campaigns launched. • Number of citizens reached • Number of businesses adopting human rights policies.
6. Form a committee to oversee NAPBHR implementation, monitor progress, and report to the OGP National Steering Committee. | Jan 2026 | Dec 2027 | • Multi-stakeholder oversight committee formally established • Quarterly convening of committee | Committee established and number of oversight reports published Stakeholder satisfaction level of steering committee (target: 70%)

Source(s) of Funding: Federal Government Budget (NHRC allocation), International Development Partners, and Private Sector