The Board agreed that Cameroon has made meaningful progress overall with implementing the 2016 EITI Standard.

The government is fully, actively and effectively engaged in the EITI process and there are regular high-level statements of support for EITI. The government has appointed a lead with authority to coordinate actions across ministries, mobilize resources, and has the confidence of all EITI stakeholders.

There is an enabling environment for company participation in the EITI process, despite logistical challenges linked to oil and gas companies’ base in Douala. Companies play their role in providing data, and contributing to the preparation and dissemination of EITI reports. The departure of Total in 2010 and Geovic (the only industrial mining company present in Cameroon) in 2014 had a direct impact in reducing company participation on the MSG, particularly for mining.

There is no evidence of any legal, regulatory or practical barriers to civil society’s ability to engage in EITI nor to their ability to freely operate, communicate and cooperate with the broader constituency in relation to extractives or public finance issues. The existence of press articles critical of the government’s management of the oil and gas sector help illustrate that self-censorship is not major concern. However, concerns over conflict of interest linked to per diems (see Requirement 1.4) appear to hamper the broader constituency’s full, active and effective engagement in EITI implementation. There is limited evidence of civil society actors directly represented in EITI Cameroon (the MSG and Technical Secretariat) liaising with their broader constituency. Some stakeholders also consider that capacity constraints have hindered civil society’s ability to effectively use the EITI as an instrument to support public debate and reform in these critical sectors.

The statutory rules for the MSG’s structure and membership are not clear and the lack of codification of nominations procedures and coordination mechanism for each constituency are a concern (see Requirements 1.2 and 1.3). There is little evidence that MSG members from civil society and industry seek to represent the views of their broader constituencies. There appears to be a split within the civil society constituency, with certain CSOs not directly involved in EITI Cameroon considering that civil society represented on the MSG and the Technical Secretariat have been co-opted by the government (see Requirement 1.3). These divisions appear to hamper the broader constituency’s full, active and effective engagement in EITI implementation. There is little evidence to suggest that companies or federations represented on the MSG coordinate among themselves and engage with the broader industry constituency, particularly in the artisanal and small-scale mining sector. There also appears to be little awareness of EITI objectives beyond companies represented on the MSG. The MSG’s ToR are outdated and are not in line with Requirement 1.4.b, with significant deviations in practice. While there are no provisions for any two constituencies over-ruling the third in MSG decisions, there is no evidence of any MSG decision having been taken any other way than by consensus thus far. The lack of clarity on the payment of per diems raises important concerns about the integrity of the MSG’s oversight that need to be addressed, particularly given stakeholder concerns over potential conflicts of interest caused by the per diems practice.

The MSG maintains a triannual EITI work plan, that is fully costed and aligned with the reporting and Validation deadlines established by the EITI Board. The 2017-2019 work plan includes measurable and time-bound activities, identifies domestic and external sources of funding. However, while there is evidence of consultations in developing the triannual work plan, there is no evidence it is updated more than every three years, aside from the exceptional annual update for 2016. In addition, while the objectives of the EITI work plan are somewhat aligned with the EITI Principles, they do not seem to sufficiently reflect national priorities for the extractive industries given their focus on the practicalities of implementation.

The 2014 EITI Report describes the process for awarding and transferring licenses in mining, oil and gas. While its description of the statutory licensing process for mining may appear confusing (first come first served and best technical and financial criteria), all stakeholders consulted confirmed that this reflected current regulations and considered that this had never been an issue in practice (no concurrent applications). The report does not provide technical and financial criteria for licenses issued by direct negotiations in 2014 and does not highlight any non-trivial deviations from the license allocation procedures for licenses awarded in 2014. However, it is possible to access a list of the statutory technical and financial criteria from the government (upon request) and none of the stakeholders consulted raised any doubts about the way in which licenses awarded in 2014 were granted. While it is unclear whether there were any transfers of licenses in 2014 from the report, all stakeholders consulted confirmed the lack of transfers.

The 2014 EITI Report provides, for all mining production, quarrying, oil and gas licenses active at the end of 2014 as well as mining exploration licenses awarded in 2014, the names of license-holders, dates of award and expiry as well as the commodities covered. While Cameroon’s new mining cadastre provides access to all required information for mining licenses, dates of application and coordinates are not publicly accessible for the 31 oil and gas licenses active in 2014. The five quarrying licenses for which dates of application are not publicly accessible are not held by material companies.

The 2014 EITI Report is clear on the government policy on non-disclosure of contracts in the oil and gas sector, it remains vague as regards to the mining sector, generally describing the availability of “some” mining contracts on certain companies’ websites, without providing the exact number of contracts accessible to the public.

The 2014 EITI Report provides an overview of the legal environment and fiscal framework for the extractives, including a description of the roles and responsibilities of government entities, the level of fiscal decentralisation and reforms. The report does not describe the impact of stabilisation clauses in PSCs on the oil and gas fiscal framework, but provides guidance on accessing the model PSC with such stabilisation clauses.

The 2014 EITI Report clarifies the MSG’s definition of beneficial ownership and the government’s policy on disclosure is enshrined in EITI Cameroon’s beneficial ownership roadmap. The government has included beneficial ownership disclosure provisions in mining legislation. However, the 2014 Report does not disclose shareholders of four of the 20 material companies and information on legal ownership of companies in Cameroon is not publicly-accessible.

The 2014 EITI Report covers state participation in the upstream mining, oil and gas sectors, lists upstream state participations in 2014 and provides an overview of financial relations, statutory and in practice, between SOEs and the government in the oil and gas sector, but neither in mining nor the mid- and downstream oil and gas sectors. While the report provides a general description of SNH's sovereign advances on behalf of government, withheld from the state’s in-kind revenues, it does not provide sufficient detail on the allocation of specific expenditures to SNH. The report provides an overview of terms associated with state interests in mining, but not in upstream oil and gas. The financial relationship between the SONARA, SNH and the state is not described. Clarifying SNH’s financial relations with its subsidiaries and joint ventures is key to understanding the basis for dividend payments from the SNH Group to government. The 2014 Report does not refer to any changes in state participation nor to any loans or guarantees by the government to SONARA.

The 2014 EITI Report provides an overview of the extractive industries, including significant exploration activities.

The 2014 EITI Report provides production volumes for oil, gas, condensate and six mineral commodities produced in 2014, but does not provide production values for natural gas nor three quarrying products (used as construction materials). While quarrying materials are marginal, the lack of natural gas production values despite their availability in existing government systems (albeit not publicly-accessible) is of concern given the strategic importance of natural gas to Cameroon’s energy security.

The EITI Board has previously taken the view that exports from artisanal and small-scale mining from companies not included within the scope of EITI reporting should not be taken into account in assessing compliance with this requirement. All stakeholders consulted confirmed that there was no industrial mining production in Cameroon. However, the lack of information on exports by semi-mechanised small-scale miners is a concern given the significant public attention on this issue, particularly by host communities and civil society. Cameroon has gone beyond the minimum requirements by providing additional information on oil export figures disaggregated by company and export market, as well as an assessment of discrepancies between extractives export figures from government and from the IMF.

While the evidence for the MSG’s assessment is not provided in the 2014 EITI Report, the report states that there were no barters or infrastructure provisions in force in 2014.

The 2014 EITI Report confirms the centralised nature of the government’s extractives revenue collection, which implies a lack of direct subnational transfers.

The 2014 EITI Report presents reconciled financial data disaggregated by receiving government entity, by company and by revenue stream. There is partial project-by-project EITI reporting in Cameroon (oil and gas, not mining).

The MSG-approved ToR for the IA was in line with the Board-approved template and the recruitment of the IA was approved by the MSG. There were no significant deviations from the IA’s ToR in practice. The report includes a summary of the IA’s review of audit and assurance procedures and practices in 2014. The MSG approved the reporting templates and quality assurances required from reporting entities and all but one company and all government entities provided the requested assurances for their reporting. While the lack of publication of the Chamber of Count’s detailed findings is disappointing, the International Secretariat understands these are routinely published by the CdC, albeit with some delay. The report names the non-complying company and assesses the materiality of its payments to government, considered insignificant. The IA concludes that the data presented in the report was comprehensive and reliable. While the summary data tables for the 2014 EITI Report had not been published as of the start of Validation (1 July 2017), the IA prepared summary data tables for the 2014 EITI Report, which will be published once finalised.

The MSG has agreed materiality thresholds for selecting companies and revenue streams. The 2014 EITI Report lists and describes all material companies and revenue streams, names the three non-reporting companies and assesses the materiality of their payments, considered insignificant. The report also provides full government reporting of all material revenues from non-material companies.

The 2014 EITI Report provides the volumes of the state’s in-kind revenues of oil, gas, condensate and gold collected in 2014 and the proceeds of sales of the state’s in-kind revenues, but does not provide information on volumes sold nor disaggregate sales information by buyer.

While the MSG’s assessment of the materiality of transport revenues is not explicitly presented in the 2014 EITI Report, it is evident that the MSG has included transport revenues in the scope of reconciliation and the reconciliation of oil transit payments is presented in the 2014 EITI Report. Additional information on transportation arrangements, including the unit price of transit rights, is also provided.

The 2014 EITI Report discloses oil and gas company payments to SNH and SNH payments to the government, while confirming the lack of mining company payments to SNI. There is however insufficient information in the report to determine the value of transfers from SNH to other government entities as budgetary advances on behalf of the government. While stakeholders maintain that SNH’s sovereign advances are budgeted spending, the International Secretariat understands that such advances include some transfers to other government entities, albeit reputedly small. This issue is discussed further in the assessment of quasi-fiscal expenditures (requirement 6.2).

Cameroon has consistently published EITI Reports within two years of the end of the fiscal period(s) covered.

The MSG’s position is that SNH’s deductions from the state’s in-kind revenues to pay sovereign advances on behalf of the Treasury represents a form of budgetary spending. The 2014 EITI Report explains how extractives revenues are recorded in the national budget and the allocation of the small share of extractives revenues retained by individual government entities such as CAPAM. However, the process for deciding SNH’s sovereign advances for specific budgeted expenditure is not clearly explained. The International Secretariat takes the view of other institutions like the IMF that SNH sovereign advances are not a normal form of budgeted expenditure and breaks with the principle of a single Treasury account. In this view, the 2014 EITI Report does not sufficiently explain the types of expenditures covered as sovereign advances by the SNH, nor the process for delineating the expenditures to be covered by the SNH. Given the materiality of SNH sovereign advances, at roughly a quarter of total government extractives revenues in 2014, the broader objective of the requirement is not met.

The 2014 EITI Report describes statutory subnational transfers linked to extractives revenues and provides the general formula for calculating transfers. However, the calculations of the value of subnational transfers according to the formula are provided in aggregate, not disaggregated by local government unit (LGU). It is unclear why the computations are not disaggregated by LGU, while the value of actual subnational transfers in 2014 was disaggregated by LGU. Given the significance of aggregate discrepancies and the potential for aggregates to net out discrepancies at a per-commune level, the broader objective of subnational transfer traceability is considered unmet.

It is encouraging that the MSG has made some attempt at including information on the budget-making process and revenue earmarks in the 2014 EITI Report.

The 2014 EITI Report confirms the existence of mandatory social expenditures and discloses the nature and value of mandatory social expenditures, including identifying the beneficiaries. Cameroon has gone beyond the minimum requirements by providing additional information on discretionary social expenditures as encouraged by the EITI Standard.

There is insufficient information in the 2014 EITI Report to assess whether the report’s own assessment that there were no quasi-fiscal expenditures in 2014 is correct and reliable. Given the lack of clarity surrounding the types of government expenditures covered by SNH sovereign advances and the doubts raised under Requirement 5.1 related to the MSG’s classification of this spending as budgeted spending, it is unclear whether Requirement 6.2 is applicable to Cameroon in the year under review. The MSG has clearly considered this issue and included questions related to quasi-fiscal expenditures in the reporting templates, although there is no description in the 2014 EITI Report of the basis for concluding this Requirement as not applicable. The lack of information on the structure of fuel subsidies involving SONARA, the financial relationship between SNH and its subsidiaries and the materiality of revenues withheld by the SNH to cover government expenditures supports the assessment.

The 2014 EITI Report provides, in absolute and relative terms, the extractives contribution to GDP, government revenues, exports, and employment, although it only provides material companies’ reporting of their staffing levels. Nonetheless, the results of material companies’ reporting of their staffing numbers in absolute terms is encouraging, even if it is unlikely to provide comprehensive employment numbers in absolute terms. The report also provides an overview of the location of production and an estimate of informal activity.

As of 1 July 2017, data from all of Cameroon’s EITI Reports aside from the latest covering 2014, is available in machine readable format through the EITI Cameroon country page of the EITI global website.

The MSG has produced annual progress reports that provide a summary of activities conducted and present the strengths and weaknesses of the EITI process. While the APR alone provides a fragmented assessment of the impact of the implementation of the EITI, it can be complemented by other MSG documents. However, the APR does not allow to measure progress against meeting work plan objectives, nor does it provide a clear picture of the MSG’s efforts to follow-up on recommendations from reconciliation and Validation.

The MSG has worked towards making the EITI Reports comprehensible and accessible online. The MSG has agreed a policy on the access, release and reuse of EITI data. There is evidence that civil society organisations and the Technical and Permanent Secretariats are leading on efforts to disseminate the EITI Report and encourage public debate about the mining sector. However, lack of funding has limited outreach activities outside the capital in recent years, and there is only limited evidence of MSG attempts to promote the use of EITI data in public debate about the extractive industries. There does not appear to have been dissemination of the 2014 EITI Report beyond the capital since its publication in December 2016.

There is evidence that recommendations are discussed at MSG meetings, that mechanisms are in place to follow-up on them, that discrepancies highlighted by EITI Reports are investigated and that the implementation of recommendations has improved EITI Reporting as well as disclosure of data on the sector.