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Cameroon has made meaningful progress with considerable improvements in implementing the 2019 EITI Standard.

Outcome of the Validation of Cameroon

Decision number
2021-97
Decision basis
EITI Articles of Association 2019-2021, Article 12.1. ix)
21 January 2021

Board decision

The EITI Board agreed the following:

The EITI Board agrees that Cameroon has fully addressed three of the 14 corrective actions from the country’s first Validation. Consequently, Cameroon has made meaningful progress overall in implementing the 2019 EITI Standard, with considerable improvements across several individual requirements.

The Board congratulates Cameroon for addressing some of the shortcoming identified in its first Validation related to production data, sales of the state’s in-kind revenues and transactions related to state-owned enterprises. The Board commends that the government has enshrined key EITI Requirements into national legislation through the 2016 Mining Code and the 2018 Transparency Code. The Board acknowledges improvements in the government’s systematic disclosures, including through the online mining cadastral system, and in financial disclosures by the national oil company SNH. Cameroon’s EITI is commended for drawing attention to arrears in subnational transfers, both of extractive and non-extractive revenues.

The Board encourages Cameroon to ensure comprehensive and reliable disclosures related to contract and license management, license registers, contract disclosure and beneficial ownership transparency. Cameroon is urged to ensure timely reporting and disclosures, including of extractive revenues that are not transferred to Treasury, as well as social, environmental and quasi-fiscal expenditures.

The Board takes note that the MSG’s oversight of EITI implementation appeared to weaken during the 2018-2020 period, amidst fiscal constraints that led to Cameroon securing support from the International Monetary Fund in 2017, general elections in 2018 as well as the escalation of social tensions in the southwest and northwest anglophone regions and the continued fight against Boko Haram in the north. The Board expresses concern that the pace of outreach and contribution to public debate appears to have declined in the period since the first Validation. While the Board recognises that the civil society constituency has broadened its outreach with the creation of a new civil society platform, it notes that the new constituency coordination mechanisms have not yet been fully implemented in practice to coordinate with the broader constituency.

The Board acknowledges the recent activities undertaken to address the shortcomings of the 2018-2020 period, notably in terms of documenting the MSG’s oversight of implementation and its assessment of outcomes, and encourages Cameroon to continue this effort. The Board takes note of Cameroon’s plans to transition to systematic disclosures of EITI data through government and company systems.

The Board has determined that Cameroon will have until a third Validation commencing on 1 April 2023 to carry out corrective actions regarding civil society engagement (Requirement 1.3), MSG oversight (Requirement 1.4), work plan (Requirement 1.5), contract and license allocations (Requirement 2.2), register of licenses (Requirement 2.3), contracts (Requirement 2.4), beneficial ownership (Requirement 2.5), state participation (Requirement 2.6), data timeliness (Requirement 4.8), distribution of revenues (Requirement 5.1), subnational transfers (Requirement 5.2), social expenditures (Requirement 6.1), quasi-fiscal expenditures (Requirement 6.2), public debate (Requirement 7.1) and review of outcomes and impacts of EITI implementation (Requirement 7.4). Failure to demonstrate progress in the third Validation will result in temporary suspension in accordance with Article 6 of the EITI Standard. In accordance with the EITI Standard, Cameroon’s MSG may request an extension of this timeframe or request that Validation commences earlier than scheduled.

Corrective actions and strategic recommendations

The EITI Board agreed the following corrective actions to be undertaken by Cameroon. Progress in addressing these corrective actions will be assessed in a thrid Validation commencing on 1 April 2023:

  1. In accordance with Requirement 1.3.a, civil society must be fully, actively and effectively engaged in all aspects of the EITI process. In accordance with Requirement 1.3.e.ii, stakeholders, including but not limited to members of the multi-stakeholder group must be substantially engaged in the design, implementation, monitoring and evaluation of the EITI process, and ensure that it contributes to public debate.  In accordance with the civil society protocol’s provision 2.3, civil society MSG representatives should engage with other CSOs that are not part of the MSG, including capturing their input for MSG deliberations and communicating the outcomes of MSG deliberations. The constituency could consider the extent to which implementation of its own Constituency Code and ToR for the OSCC-ITIECAM platform could help address concerns over conflict of interest and retention of information by MSG members. Civil society may wish to consider undertaking a capacity needs assessment and formulating actions to address civil society capacity constraints.

  2. In accordance with Requirement 1.4.a.ii, Cameroon should ensure that each stakeholder group must have the right to appoint its own representatives, bearing in mind the desirability of pluralistic and diverse representation. The nomination process must be independent and free from any suggestion of coercion. Civil society groups involved in the EITI as members of the multi‑stakeholder group must be operationally, and in policy terms, independent of government and/or companies. The multi‑stakeholder group and each constituency should consider gender balance in their representation to progress towards gender parity. In accordance with Requirement 1.4.b.ii, the MSG should undertake effective outreach activities with civil society groups and companies, including through communication such as media, websites and letters, informing stakeholders of the government’s commitment to implement the EITI, and the central role of companies and civil society. The multi‑stakeholder group should also widely disseminate the public information that results from the EITI process. In accordance with the Requirement 1.4.b.iii, all MSG members should establish mechanisms for coordination with their broader respective constituencies. In accordance with the Requirement 1.4.b.vi, the MSG should oversee the EITI reporting process and engage in Validation. To strengthen implementation, the MSG may wish to consider developing a capacity needs assessment and capacity-building action plan to ensure that all MSG members have adequate capacity to oversee all aspects of EITI implementation. In accordance with the Requirement 1.4.b.vii, Cameroon should ensure that its per diem practice does not give rise to allegations of conflict of interest. Cameroon may wish to consider the extent to which clarification of the actual per diem practice for all EITI officeholders could address allegations of conflict of interest. In accordance with the Requirement 1.4.b.ix, the MSG must keep written records of its discussions and decisions.

  3. In accordance with Requirement 1.5, the MSG should agree a work plan that is linked to national priorities and is revised annually to take account of changing conditions and opportunities, based on input from the various constituencies. Cameroon should ensure that its annually updated EITI work plan be publicly available, of critical importance for enhancing MSG members’ accountability towards their respective constituencies.

  4. In accordance with Requirement 2.2.a.ii, Cameroon should ensure that a description of the statutory process for transferring licenses in the mining, oil and gas sector is publicly disclosed, including the specific technical and financial criteria assessed and any weightings of these criteria. Cameroon should ensure that the number of mining, oil and gas licenses awarded and transferred annually is publicly disclosed.

  5. In accordance with Requirement 2.3.b.ii-iii, Cameroon should ensure that coordinates and dates of application, award and expiry are publicly accessible for all active mining, oil and gas licenses. Cameroon is encouraged to use EITI reporting as an annual diagnostic of license data management systems with a view to strengthening the comprehensiveness of these disclosures.

  6. In accordance with Requirement 2.4.b, Cameroon is expected to agree and publish a plan for disclosing contracts with a clear time frame for implementation and addressing any barriers to comprehensive disclosure. This plan will be integrated into work plans covering 2020 onwards. The MSG should agree a plan for disclosing contracts or integrate it in its workplan. In accordance with Requirement 2.4.a, Cameroon is required to disclose any contracts and licenses that are granted, entered into or amended from 1 January 2021. Cameroon is invited to consider the extent to which implementation of Article 6 of the July 2018 Transparency Code on contract disclosure would help meet these corrective actions.

  7. In accordance with Requirement 2.5 and the Board-agreed framework for assessing progress, Cameroon is required to disclose the beneficial owners of all companies holding or applying for extractive licenses by 31 December 2021. To achieve this target, the following measures are recommended:

  8. In accordance with Requirement 2.6.a.ii, Cameroon should ensure that the terms to state and SNH participation in oil and gas companies and projects are publicly disclosed, including their level of responsibility for covering expenses at various phases of the project cycle. Where the government or SNH have provided loans or loan guarantees to mining, oil and gas companies operating within the country, details on these transactions should be disclosed, including loan tenor and terms (i.e. repayment schedule and interest rate). The MSG may wish to consider comparing loans terms with commercial lending terms. In accordance with Requirement 2.6.b, Cameroon is expected to publish the comprehensive version of SNH’s audited financial statements or explain the barriers to such disclosures. Cameroon is invited to consider the extent to which progress against this corrective action would support broader implementation of Article 8 of the July 2018 Transparency Code on transparency in state participation.

  9. In accordance with Requirement 4.8, Cameroon should publish regular and timely information in accordance with the EITI Standard and the agreed work plan (see Requirement 1.5) on an annual basis, with data no older than the second to last complete accounting period.

  10. In accordance with Requirement 5.1, Cameroon should ensure that a clear description of which extractive industry revenues, whether cash or in‑kind, are recorded in the national budget is publicly disclosed. Where revenues are not recorded in the national budget, the allocation of these revenues must be publicly explained, with links provided to relevant financial reports as applicable.

  11. In accordance with Requirement 5.2, Cameroon should ensure that material transfers are disclosed, including the revenue-sharing formula, as well as any discrepancies between the transfer amount calculated in accordance with the relevant revenue sharing formula and the actual amount that was transferred between the central government and each relevant subnational entity. Cameroon is encouraged to agree a procedure to address data quality and assurance of information on subnational transfers, in accordance with Requirement 4.9. Cameroon may further wish to report on how extractive revenues earmarked for specific programmes or investments at the subnational level are managed, and actual disbursements.

  12. In accordance with Requirement 6.1, Cameroon should undertake a comprehensive review of all mandatory social expenditures and environmental payments mandated by law or contract. Cameroon should ensure that public disclosures of mandatory social expenditures and environmental payments in future EITI reporting be disaggregated between cash and in-kind expenditures, by type of payment and beneficiary, clarifying the name and function of any non-government (third-party) beneficiaries. Cameroon may wish to ensure that mandatory social expenditure requirements are more clearly codified in mining contracts with set timeframes to ensure more efficient monitoring and oversight.

  13. In accordance with Requirement 6.2, Cameroon should ensure public disclosures from SOEs on their quasi‑fiscal expenditures, through a reporting process that achieves a level of transparency commensurate with other payments and revenue streams and includes SOE subsidiaries and joint ventures. Cameroon may wish to take the IMF’s definition of quasi‑fiscal expenditures into account when considering whether expenditures are considered quasi‑fiscal.

  14. In accordance with Requirement 7.1.a.i-ii, Cameroon should ensure that EITI findings and data are widely accessible and distributed, in both official languages (French and English) and in formats that are more accessible than the comprehensive version of the EITI Report. Cameroon should ensure that EITI data and findings are comprehensible, including by considering access challenges and information needs of different genders and subgroups of citizens. In accordance with Requirement 7.1.a.iii, Cameroon should ensure that outreach events, whether organised by government, civil society or companies, are undertaken to spread awareness of and facilitate dialogue about governance of extractive resources, building on EITI disclosures across the country in a socially inclusive manner. In accordance with Requirement 7.1.b.iii, Cameroon is encouraged to organise capacity-building activities, especially with civil society and through civil society organisations, to improve understanding of the information and data from the reports and online disclosures and encourage use of the information by citizens, the media and others.

  15. In accordance with Requirement 7.4.a. Cameroon should undertake an annual review to document the results and impact of the EITI process in Cameroon. In accordance with Requirement 7.4.a.i-v, Cameroon’s review of outcomes and impact should include progress against EITI Requirements, follow-up on EITI recommendations, progress towards work plan objectives, and a narrative account of efforts to strengthen the impact of EITI implementation on natural resource governance. In accordance with Requirement 7.4.b, the MSG should ensure that all stakeholders are able to participate in the annual review of the impact of EITI implementation, including those not serving on the MSG. To strengthen implementation, Cameroon may wish to consider a formalised impact assessment after thirteen years of EITI implementation.

The government and the MSG are encouraged to consider the other recommendations in the  International Secretariat’s assessment, and to document the MSG’s responses to these recommendations in the next annual progress report.

Background

Cameroon was admitted as an EITI Candidate in 2007. The first Validation of Cameroon against the EITI Standard commenced on 1 July 2017. On 29 June 2018, the EITI Board found that Cameroon had made a meaningful progress in implementing the 2016 EITI Standard. Fourteen corrective actions were identified by the Board, pertaining to the following requirements:

  1. Civil society engagement (Requirement 1.3),
  2. MSG governance (Requirement 1.4),
  3. Work plan (Requirement 1.5),
  4. License register (Requirement 2.3),
  5. Policy on contract transparency (Requirement 2.4),
  6. State-participation (Requirement 2.6),
  7. Production data (Requirement 3.2),
  8. In-kind revenues (Requirement 4.2),
  9. SOE transactions (Requirement 4.5),
  10. Distribution of revenues (Requirement 5.1),
  11. Subnational transfers (Requirement 5.2),
  12. SOE quasi-fiscal expenditures (Requirement 6.2),
  13. Public debate (Requirement 7.1),
  14. Outcomes and impact of implementation (Requirement 7.4).

The Board asked Cameroon to address these corrective actions to be assessed in a second Validation commencing on 29 December 2019. The Board did not approve Cameroon's extension request on 13 February 2020 and agreed that the second Validation would commence on 13 February 2020, taking account of all information published up to that date.

Cameroon has undertaken a number of activities to address the corrective actions:

  • The MSG met 6 times during the second half of 2017; 3 times in 2018 as well as in 2019 and, finally, 3 times between the 1st January 2020 and 13th February 2020, the start of the Validation;
  • On 14 November 2017, the MSG adopted a dissemination timeline and an update of the communication strategy;
  • On 28 December 2017, the MSG adopted the 2016 Annual Progress Report;
  • On 8 February 2018, the MSG adopted the Independent Administrator's ToRs for the 2016-2017 Reports; 
  • On 17 May 2018, the MSG adopted the updated 2017-2019 work plan for 2018;
  • On 17 July 2018, the government issued the Decree No. 2018/6026/PM of 17 July 2018 on the creation and organisation of the EITI Committee;
  • On 10 August 2018, the MINFI issued an Order of 10 August 2018 appointing the National Coordinator of the EITI Cameroon; 
  • On 21 November 2018, the civil society constituency adopted an action plan and constituency guidelines codifying the coordination mechanisms and the process of designation of CSOs representatives on the MSG;
  • On 18 December 2018, the MSG adopted the scoping studies for the 2016 and 2018 EITI Reports;
  • On 5 February 2019, the Prime Minister’s office issued the Order N° 025/CAB/PM of 05 February 2019 fixing the indemnities of the Committees and working groups;
  • On 12 February 2019, the MSG adopted the 2017 annual progress report; 
  • On 22 February 2019, the MSG organised an event for the public launch of the 2016 Report; 
  • On 23 December 2019, the civil society constituency undertook a pre-Validation self-assessment of progress in addressing the corrective measures from the first Validation;
  • On 26 December 2019, the MSG adopted an emergency action plan for preparing the second Validation; 
  • On 6 February 2020, the MSG adopted the 2017 EITI Report and conducted a public press event for its launch. The MSG also adopted the EITI Code of Conduct;
  • On 12 February 2020, the MINFI issued Order No. 361(bis)/MINFI of 12 February 2020 institutionalising the composition of the new MSG. 

Cameroon’s second Validation commenced on 13 February 2020. The EITI International Secretariat has assessed the progress made in addressing the 14 corrective actions established by the EITI Board following Cameroon’s first Validation in 2018. Progress in implementing Requirement 2.5 on beneficial ownership, as well as new Requirements 6.4 and 7.2 of the 2019 EITI Standard were also assessed. The Secretariat’s assessment is that Cameroon has fully addressed three of the 14 corrective actions, that it has achieved “meaningful progress” in addressing another nine corrective actions and it has made “inadequate progress” with considerable improvements in addressing the other two corrective actions. The Secretariat has also reviewed progress on Requirements 2.5, 4.7 and 4.8, with assessments of “inadequate progress” for the first and “meaningful progress” for the subsequent two.  

The draft assessment was sent to the Cameroon EITI MSG on 30 September 2020. Following comments from the MSG submitted on 18 November 2020, the assessment was finalised for consideration by the EITI Board.

Scorecard for Cameroon: 2020

Assessment of EITI requirements

  • Not met
  • Partly met
  • Mostly met
  • Fully met
  • Exceeded
Scorecard by requirement View more Assessment View more

Overall Progress

MSG oversight

1.1Government engagement

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.

1.2Industry engagement

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.

1.3Civil society engagement

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, while few, 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. The constituency has established a new platform (OSCC-ITIECAM) that has broadened the network, the implementation of coordination is only starting in practice. 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.

1.4MSG governance

Since the first Validation, the MSG has renewed its membership and updated its statutory governance rules. However, the new Decree institutionalising the EITI in July 2018 effectively designates six of the eight CSO MSG members and two of the eight industry MSG members. While civil society and the oil and gas industry have codified MSG nominations procedures, the mining sub-sector has not. However, there is little evidence that the constituencies’ coordination mechanisms have been implemented in practice. Decree 2018/6026/PM updates the MSG’s ToR and covers most aspects of Requirement 1.4.b. There was little documentation of MSG meetings in the 2018-2020 period, although minutes of the few meetings were disclosed in November 2020. There were delays in MSG approval of the annual work plans, annual progress reports and EITI Reports in the 2018-2020 period. The MSG’s per diem policy has been formalised, with stakeholder consultations confirming that per diems were paid at the statutory rate in this period. However, there remain significant concerns about conflicts of interest linked to per diem payments on the part of several civil society representatives consulted. The MSG approved an EITI Cameroon Code of Conduct.

1.5Work plan

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 2018 update to the 2017-2019 work plan includes measurable and time-bound activities and identifies domestic sources of funding. However, there is no evidence of consultations in developing the update of the triannual work plan, and this version has not been published online. There is furthermore no evidence that it is updated more frequently than every three years, aside from the exceptional annual update in 2018 that was never approved by the MSG. 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.

Licenses and contracts

2.1Legal framework

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.

2.2Contract and license allocations

While most aspects of Requirement 2.2 have been addressed in the 2017 EITI Report, there are inconsistencies in the number of mining licenses awarded in 2017. While the report describes the process for awarding and transferring licenses in the mining, oil and gas sectors and confirms the lack of non-trivial deviations in mining license awards and oil and gas license transfers in 2017, it only describes the specific technical and financial criteria assessed for mining, oil and gas license awards, not for transfers.

2.3Register of licenses

Cameroon has developed an online cadastral portal for mining in 2017 and published a comprehensive list of oil and gas licenses in early 2020 that provides all of the information listed under Requirement 2.3.b for most active licenses. There are only a handful of gaps on licenses held by companies making material payments to government, including missing dates of application for 11 oil and gas licenses, missing coordinates for a quarrying license, missing dates of application for five industrial mining licenses and missing dates of award and expiry for one quarrying and two mining exploration licenses.

2.4Contracts

The government’s policy on contract disclosure is clearly enshrined in the 2018 Transparency Code, which provides government policy despite the lack of implementing regulations to date. The 2017 EITI Report documents this pro-disclosure policy and confirms that no signed mining or oil and gas contract has been published to date, aside from model contracts. While the MSG has established a working group on contract transparency, it has yet to formulate a plan for disclosing all new contracts and amendments from January 2021 onwards.

2.5Beneficial ownership

Cameroon has agreed an appropriate definition of “beneficial owner” and embedded it in national mining legislation, although it has yet to formalise the definition and list of politically-exposed persons (PEP). Cameroon has requested and disclosed some legal and beneficial ownership information from material companies included in the scope of reconciliation in the three most recent EITI Reports, although there is no evidence to date of outreach or data collection from other extractive companies not included in EITI reconciliations. Beneficial ownership information had been disclosed for a total of only 11 oil and gas companies and three mining and quarrying companies included in the 2017 EITI Report. The MSG had not reviewed gaps in reporting of beneficial ownership by all extractive companies.

2.6State participation

In mining, the 2017 EITI Report confirms the lack of a state-owned company and describes the state’s minority equity interest in two mining companies (held directly and through SNI), including the terms attached with state equity in each. In oil and gas, the 2017 EITI Report confirms that the only SOE is SNH and describes the company’s roles, responsibility and statutory financial relations with government. The SNH’s financial relations with the government in practice in 2017 are described in the 2017 EITI Report. The 2017 EITI Report provides a list of companies and subsidiaries in which SNH holds equity and describes the terms attached to these equity interests. However, while the report provides a list of oil and gas projects in which SNH holds participating interests either on behalf of the state or its own account, it only describes the terms attached to these participating interests in general terms. the lack of state loans or guarantees to extractives companies outstanding in 2017 is not categorically confirmed in the 2017 EITI Report or other publicly accessible documents.

Monitoring production

3.1Exploration data

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

3.2Production data

The 2017 EITI Report provides production volumes and values for all extractive commodities produced in 2017, including oil, gas, quarrying and ASM gold and diamond, with some indication of the location of production.

3.3Export data

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.

Revenue collection

4.1Comprehensiveness

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.

4.2In-kind revenues

The government is entitled to three types of in-kind revenues in Cameroon: crude oil, natural gas and artisanal-mined gold. In practice, it collects two in-kind (oil and gold). For oil, the 2017 EITI Report discloses and reconciles the volumes of the state’s in-kind revenues that were collected, the volumes actually sold and the proceeds of the sales, disaggregated (but not reconciled) by buyer and by cargo. For gold, the report provides the volumes collected and volumes transferred to the Ministry of Finance, without the proceeds of sales given that there is no cash settlement for these transfers. It is encouraging that SNH has made efforts to disclose terms of the general statutory buyer selection process.

4.3Infrastructure provisions and barter arrangements

Not applicable

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.

4.4Transportation revenues

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.

4.5SOE transactions

In mining, the 2017 EITI Report discloses and reconciles the dividends to the government paid by the two companies in which the state holds a minority interest. In oil and gas, the report discloses and reconciles oil and gas company payments in cash and in kind to SNH and SNH’s transfers to government (dividends and proceeds of oil and gas sales). While the SNH’s transfers to other government entities as ‘direct interventions’ are only unilaterally disclosed by SNH and reconciled with the budget execution report, not with the recipient government entities, weaknesses in disclosures of SNH’s ‘direct interventions’ are covered more extensively under Requirements 5.1 and 6.2.

4.6Subnational payments

Not applicable

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

4.7Level of disaggregation

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).

4.8Data timeliness

Cameroon published its two latest EITI Reports with data older than the second to last complete accounting period upon publication. The MSG approved the report period for EITI reporting.

4.9Data quality and assurance

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.

Revenue allocation

5.1Distribution of revenues

The 2017 EITI Report confirms that there were three exceptions in 2017 to the single Treasury account principle for public financial management in Cameroon. The largest exception in value is comprised of deductions from government revenues by SNH-Mandat and spent on ‘direct interventions’ of security-related expenditures provided for in the national budget. While the 2017 EITI Report provides the breakdown in recipients of these ‘direct interventions’ in 2017, it only provides the general breakdown in the use of these funds in aggregate. The other two types of extractive revenues that are not transferred to the single Treasury account are SNH-Mandat’s deductions from its transfers to government to cover the state’s share of costs associated with its participation in oil and gas projects, as well as CAPAM’s in-kind gold collections on behalf of the government, partly retained by CAPAM.

5.2Subnational transfers

The 2017 EITI Report covers three types of statutory subnational transfers, two of which are linked to the extractive revenues. It discloses the revenue-sharing formula for each and calculates the notional value of subnational transfers according to the formula, even if this data is not disaggregated by local government (commune). Reforms such as the creation of the Ministry of Decentralisation and Local Development and the joint commission of CAPAM and the Ministry of Finance have led to the identification of arrears in subnational transfers host local governments (communes) and disbursement of a first tranche of subnational transfers of extractive revenue. The report confirms the lack of effective transfer of one of the extractives-related subnational transfers but does not provide the value of transfers for the other two types of subnational transfers (one of which is extractives-related) disaggregated by local government (commune). Thus, it is only possible for readers to assess the discrepancy between rules and practices for one of the three types of subnational transfers.

5.3Revenue management and expenditures

Not assessed

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.

Socio-economic contribution

6.1Social and environmental expenditures

The 2017 EITI Report describes in general terms mandatory social expenditures according to the terms of mining, oil and gas contracts, but does not provide a comprehensive review of contractual social expenditure provisions. Reliant on self-reporting by material companies, the EITI Report presents only one quarrying company’s social expenditures categorised as mandatory. The other five oil and gas companies and one mining company that reported any type of social expenditures disclosed only voluntary social expenditures. The single company’s mandatory social expenditures provide only the aggregate. There is no evidence of MSG discussions of environmental payments,

6.2SOE quasi-fiscal expenditures

The 2017 EITI Report categorically states that the SNH did not undertake any quasi-fiscal expenditures in 2017, although the MSG’s definition of quasi-fiscal expenditures is narrower than that in the EITI Standard and in the IMF’s Fiscal Transparency Manual, by focusing only on social expenditures undertaken outside of the national budgetary process. Nonetheless, the report also refers to SNH’s assurances that it did not undertake any financing of infrastructure works or servicing of national debt in 2017. However, there is evidence of at least one type of expenditures, funded by revenues that are not transferred to the single Treasury account, which could be considered forms of quasi-fiscal expenditures. This consists of SNH ‘direct interventions’ of security-related expenditures on behalf of government. In light of the assessment that these do not represent conventional forms of budget execution (see Requirement 5.1), the International Secretariat considers these to be quasi-fiscal expenditures. While the report provides the general breakdown in these ‘direct interventions’ between equipment and services, it does not provide this disaggregation for each of the 13 government entities that received such transfers from SNH in 2017.

6.3Contribution of the extractive sector to the economy

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.

6.4Environmental impact

Not assessed

Implementing countries are not required to address environmental impact and progress with this requirement does not have any implications for a country’s EITI status. It is encouraging that Cameroon has started to include some brief references to plans to establish rehabilitation funds in the mining sector.

Outcomes and impact

7.1Public debate

Cameroon has made efforts to disseminate the full version of the 2016 and 2017 EITI Reports online, through the national EITI website and social media. There is evidence of efforts to proactively ensure the comprehensibility of EITI data through a number of infographics on the EITI Cameroon website homepage. English translation of the 2016 EITI Report was belatedly published online in 2020, while plans to publish an English version of the 2017 EITI Report appear delayed by the Covid-19 crisis. There is no evidence that EITI Cameroon has prepared summary or thematic EITI Reports to improve the public accessibility of EITI findings and data. There is evidence that the EITI Cameroon Technical and Permanent Secretariats led some efforts to disseminate the EITI Report in the period under review. However, these activities were limited to the capital city Yaoundé. There is limited evidence of MSG attempts to promote the use of EITI data in public debate about the extractive industries.

7.2Data accessibility and open data

Cameroon EITI has agreed and published an Open Data Policy. Data from Cameroon’s EITI Reports has been published in open data format, based on summary data for all of Cameroon’s EITI Reports to date accessible from the EITI global website.

7.3Follow up on recommendations

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.

7.4Review of outcomes and impact of implementation

Cameroon has published annual progress reports in accordance with Requirement 7.4 in the 2017-2019 period but covering old years (2016-2017) rather than timelier reporting. The latest MSG review of outcomes and impacts available at commencement of Validation is the 2017 annual progress report, which covers July to December 2017. That annual progress report was focused on the process of EITI implementation, activities, rather than an overview of the output, outcomes and impacts of MSG activities during the year. The MSG published the 2018 and 2019 annual progress reports in November 2020. While weaknesses in the MSG’s review of the outcomes and impacts of EITI implementation on an annual basis in the period from 2017 to October 2020 remain, these recent publications have provided an overview of outcomes and impacts in this period, even if delayed.

Countries
Cameroon