Cameroon

The Secretariat’s assessment is that Requirement 1.5 is partly met, as in the previous Validation. The Secretariat’s view is that the objective of ensuring that the annual planning for EITI implementation supports implementation of national priorities for the extractive industries while laying out realistic activities that are the outcome of consultations with the broader constituencies is not achieved, but that there have been some minor improvements since the previous Validation. Cameroon EITI’s work planning process has been one of a succession of emergency action plans for much of the period under review, rather than a planned consultative process that involves input from the broader constituencies from the inception of developing the work plan. The ad hoc approach to work planning, combined with the lack of evidence of substantive consultations with the broader constituencies in agreeing work plan objectives, means that the objective is still far from being fulfilled. Most stakeholders did not express particular views on the work plan, although several stakeholders from all constituencies considered that the work plan objectives were aligned with national priorities as described in official government documents. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 1.5. They note that the successive 2021-23 and 2024-26 triennial work plans were prepared in accordance with the EITI Standard and ensured they were publicly accessible. They explain that the emergency work plan covering 2021-22 was developed in the context of Cameroon’s suspension and the related conjunctural challenges, and that the 2023 work plan was developed based on broader consultation. Reference to several minutes of MSG meetings are included, the records of which include comments from MSG members but not evidence of submissions from the broader constituencies. While the International Secretariat acknowledges these points, it notes that the public availability of a current work plan to frame EITI implementation was not consistently ensured during the period under review. While more recent improvements are noteworthy, more consistent consultations with the broader constituencies would be needed to strengthen both stakeholder engagement and Cameroon EITI’s outcomes and impacts. The MSG has regularly adopted new EITI work plans in the period under review, although these work plans have only been agreed and published with significant delays, often over six months after the start of the calendar year and not consistently updated on an annual basis. Since the last Validation, the MSG approved a three-year work plan covering 2021-2023 in November 2020. However, following Cameroon’s suspension in April 2021 for delays in its EITI reporting, the MSG agreed a “mini-action plan” for the lifting of Cameroon’s suspension July 2021, which covered the period April-July 2021. Following the lifting of Cameroon’s suspension in July 2021, the MSG approved a work plan for 2021 that built on relevant sections of the 2021-2023 work plan. There is no evidence that the MSG updated either the 2021-2023 work plan or broke it down to an annual work plan in 2022. In late August 2023 however, the MSG agreed a new three-year work plan covering 2023-2025. The 2023-2025 work plan was only published on the Cameroon EITI website on 8 October 2023, more than a month after its adoption by the MSG (although the Cameroon EITI website (including the work plan) was taken offline in November 2023 given arrears in payment to the website provider). The 2021-2023 and 2023-2025 work plans include a section linking the work plan objectives to national priorities including the 2020-2030 Growth and Employment Strategy Document (DCSE), the 2030 National Development Strategy (SND30), the Cameroon Industrialisation Master Plan (PDI) and the government’s policy for decentralisation since 2018. While the two general objectives of the three-year work plans are partly linked to national priorities, namely improving extractive industry governance, the six specific work plan objectives are only narrowly linked to the EITI process rather than broader national priorities. The 2021-2023 work plan includes as its second axis the mainstreaming of EITI disclosures through government and company systems, but includes only general activities related to agreeing a roadmap on strengthening systematic disclosures. The 2023-2025 work plan includes a work stream under Axis II.2 for the development of a systematic disclosure policy and general reference to its implementation, without details on specific activities or workstreams to strengthen systematic disclosures. The development of the 2023-2025 work plan involved some level of consultations with stakeholders beyond the MSG, although the level of input from the three broader constituencies remains unclear based on available documentation. The MSG’s ‘Outcomes and impact’ template notes that the Cameroon EITI Permanent Secretariat prepares a draft of the work plan for review both by the MSG and the broader industry and civil society constituencies, before being finalised in a two-day MSG workshop in August 2023. Consultations with CSOs engaged in the broader constituency on EITI but not directly represented on the MSG noted that there had been limited opportunities for the broader constituency to provide input to the The Secretariat’s assessment is that Requirement 1.5 is partly met, as in the previous Validation. The Secretariat’s view is that the objective of ensuring that the annual planning for EITI implementation supports implementation of national priorities for the extractive industries while laying out realistic activities that are the outcome of consultations with the broader constituencies is not achieved, but that there have been some minor improvements since the previous Validation. Cameroon EITI’s work planning process has been one of a succession of emergency action plans for much of the period under review, rather than a planned consultative process that involves input from the broader constituencies from the inception of developing the work plan. The ad hoc approach to work planning, combined with the lack of evidence of substantive consultations with the broader constituencies in agreeing work plan objectives, means that the objective is still far from being fulfilled. Most stakeholders did not express particular views on the work plan, although several stakeholders from all constituencies considered that the work plan objectives were aligned with national priorities as described in official government documents. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 1.5. They note that the successive 2021-23 and 2024-26 triennial work plans were prepared in accordance with the EITI Standard and ensured they were publicly accessible. They explain that the emergency work plan covering 2021-22 was developed in the context of Cameroon’s suspension and the related conjunctural challenges, and that the 2023 work plan was developed based on broader consultation. Reference to several minutes of MSG meetings are included, the records of which include comments from MSG members but not evidence of submissions from the broader constituencies. While the International Secretariat acknowledges these points, it notes that the public availability of a current work plan to frame EITI implementation was not consistently ensured during the period under review. While more recent improvements are noteworthy, more consistent consultations with the broader constituencies would be needed to strengthen both stakeholder engagement and Cameroon EITI’s outcomes and impacts. The MSG has regularly adopted new EITI work plans in the period under review, although these work plans have only been agreed and published with significant delays, often over six months after the start of the calendar year and not consistently updated on an annual basis. Since the last Validation, the MSG approved a three-year work plan covering 2021-2023 in November 2020. However, following Cameroon’s suspension in April 2021 for delays in its EITI reporting, the MSG agreed a “mini-action plan” for the lifting of Cameroon’s suspension July 2021, which covered the period April-July 2021. Following the lifting of Cameroon’s suspension in July 2021, the MSG approved a work plan for 2021 that built on relevant sections of the 2021-2023 work plan. There is no evidence that the MSG updated either the 2021-2023 work plan or broke it down to an annual work plan in 2022. In late August 2023 however, the MSG agreed a new three-year work plan covering 2023-2025. The 2023-2025 work plan was only published on the Cameroon EITI website on 8 October 2023, more than a month after its adoption by the MSG (although the Cameroon EITI website (including the work plan) was taken offline in November 2023 given arrears in payment to the website provider). The 2021-2023 and 2023-2025 work plans include a section linking the work plan objectives to national priorities including the 2020-2030 Growth and Employment Strategy Document (DCSE), the 2030 National Development Strategy (SND30), the Cameroon Industrialisation Master Plan (PDI) and the government’s policy for decentralisation since 2018. While the two general objectives of the three-year work plans are partly linked to national priorities, namely improving extractive industry governance, the six specific work plan objectives are only narrowly linked to the EITI process rather than broader national priorities. The 2021-2023 work plan includes as its second axis the mainstreaming of EITI disclosures through government and company systems, but includes only general activities related to agreeing a roadmap on strengthening systematic disclosures. The 2023-2025 work plan includes a work stream under Axis II.2 for the development of a systematic disclosure policy and general reference to its implementation, without details on specific activities or workstreams to strengthen systematic disclosures. The development of the 2023-2025 work plan involved some level of consultations with stakeholders beyond the MSG, although the level of input from the three broader constituencies remains unclear based on available documentation. The MSG’s ‘Outcomes and impact’ template notes that the Cameroon EITI Permanent Secretariat prepares a draft of the work plan for review both by the MSG and the broader industry and civil society constituencies, before being finalised in a two-day MSG workshop in August 2023. Consultations with CSOs engaged in the broader constituency on EITI but not directly represented on the MSG noted that there had been limited opportunities for the broader constituency to provide input to the development of the work plan, given the limited coordination with the broader constituency primarily led by the MSG member from the OSCC-ITIE platform, such as the CRADEC in particular. The industry constituency’s comments on the draft Validation report argue strongly that the broader industry constituency has consistently been consulted in developing Cameroon EITI work plans, citing evidence of extractive companies’ emails to the Cameroon EITI Secretariat. The 2021-2023 and 2023-2025 work plans include time-bound activities to achieve the objectives, which are costed with the source of funding indicated. The 2023-2025 work plan includes only planning per year but presents clear activities, although their link to a monitoring and evaluation framework could be considerably strengthened. However, the activities are not consistently measurable, with general activities such as “follow-up on EITI recommendations” relatively imprecise and challenging to track. The 2021-2023 and 2023-2025 work plans include activities related to addressing capacity constraints of MSG members and the permanent secretariat, including an ambitious list of capacity building activities. Consultations with stakeholders both on and off the MSG, particularly from civil society, noted concerns that many of the planned capacity building activities were not implemented in practice due to budget constraints. The 2021-2023 and 2023-2025 work plans include a few activities related to extending the scope of EITI implementation, mainly focused on contract and beneficial ownership transparency as well as mainstreaming EITI disclosures. The three-year work plan includes workstreams to develop action plans on the energy transition, climate change, environmental protection, critical minerals trading as well as planned studies on social and environmental expenditures and impacts, and on gender considerations. The 2021-2023 and 2023-2025 work plans both include activities linked to ensuring public disclosure of extractive contracts and beneficial owners, although they could be articulated in more detail to improve the way in which they can be monitored. The 2023-2025 work plan includes only a few activities aimed at addressing legal and regulatory barriers to EITI implementation, including a study on legal aspects and challenges to contract transparency planned for 2024 and plans to enact a new Government Decree for the EITI planned for 2023. There are no activities related to addressing legal and regulatory barriers related to the lack of implementing decrees for the 2016 Mining Code or the 2018 Transparency Code. The 2021-2023 and 2023-2025 work plans include general activities linked to following up on recommendations from EITI Reports (categorised as “the IA’s recommendations”) and from Validation, but do not provide any detail on the specific recommendations. A total of 83% of the 2021 work plan was fully implemented according to the 2021 annual progress report, while only 48% of the 2022 work plan was implemented according to the 2022 annual progress report. Consultations with stakeholders beyond the MSG, particularly from civil society, gather views that were highly critical of the level of implementation of the Cameroon EITI work plan and concerns over the transparency and accountability in the implementation of work plan activities, particularly those related to capacity building, outreach and dissemination. work plan and concerns over the transparency and accountability in the implementation of work plan activities, particularly those related to capacity building, outreach and dissemination.

The Secretariat’s assessment is that Requirement 7.1 is partly met, which is a regression from the previous Validation. The Secretariat’s view is that the objective of enabling evidence-based public debate on extractive industry governance through active communication of relevant data to key stakeholders in ways that are accessible and reflect stakeholders’ needs has not been fulfilled in the period under review. Several consulted stakeholders, particularly from civil society, considered that the objective had not been fulfilled in the period under review given limited outreach and communication efforts, particularly at the subnational level in extractive-rich regions. The Secretariat considers that the public debate on extractive issues since the previous Validation, such as on the Glencore affair, has been separate from Cameroon EITI’s outreach and dissemination of EITI information and that the Cameroon EITI communication efforts have been insufficient to make progress towards the objective of EITI data enabling public debate. The single EITI Report launch events are not considered sufficient to progress towards the objective of the EITI informing public debate, with evidence of civil society’s outreach and dissemination yet to be matched by active dissemination efforts by the other constituencies. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 7.1, given the vitality of public debate around issues related to the extractive industries. While they note examples such as the Glencore affair, the terms of the SINOSTEEL contract, Savannah Energy’s acquisition of ExxonMobil’s interests in the Chad-Cameroon oil pipeline and the murder of journalist Martinez Zogo, the links provided to print and broadcast media coverage of these debates do not indicate Cameroon EITI findings and data being actively disseminated and promoted to support this public debate. For instance, the coverage in September 2023 of CSO MSG members’ calls for investigations of Glencore do not reflect the use of EITI data to support this public debate. The International Secretariat acknowledges that there has been some improvement in some CSO MSG members’ public advocacy around extractive industry issues of public debate. However, it considers that a more systematic approach to designing and conducting EITI public dissemination and outreach would strengthen the EITI’s contribution to evidence-based public debate and policymaking. Cameroon has published four EITI Reports (covering 2018-2021) since January 2021, partly to make up for lost time following its temporary suspension in April-June 2021 for delays in publishing the 2018 EITI Report (see Requirement 4.8). The EITI Reports are published on the Cameroon EITI website and republished on the websites of the Ministries of Finance and of MINMIDT. Cameroon EITI has asked the IA that prepared the EITI Reports to prepare executive summaries of the EITI Reports (published on the same webpage as the EITI Reports, up to 2020), although these remain dense documents that are not significantly more accessible (in language, style or format) than EITI Reports. Thematic reports or extracts of EITI data tailored to specific target groups do not appear to have been produced in the period under review. Cameroon EITI has produced some simplified communications products in the period since the previous Validation. In 2021, it produced two newsletters (in French and English), two kakemono wall hangings related to the publication of EITI Reports, and launched the preparation of simplified summaries of the 2017, 2018 and 2019 EITI Reports that were completed in 2022, even though these were not published in 2021 according to the 2021 annual progress report. In 2022, Cameroon EITI published some additional simplified communications products in English. The Cameroon EITI website provides an overview of media coverage in the 2021-2023 period, which list six newspaper articles in Cameroon EITI in 2021, 18 in 2022 (around half of which were linked to the Glencore affair) and 59 in 2023 (around half of which covered the International Secretariat’s April 2023 mission to Yaoundé). Civil society organisations such as PWYP Cameroon have published a few thematic reports, most notably on contract disclosure, but these have not been republished or promoted by Cameroon EITI. Cameroon EITI has continued to primarily publish EITI Reports in full, rather than seeking to explain EITI data in clear and comprehensible terms. Translation of documents has been a broader challenge for the MSG’s operations (see Requirement 1.4) but is also reflected in the overwhelmingly francophone nature of Cameroon EITI’s communications, despite the bilingual nature of the country. While Cameroon EITI has had a Communications Strategy in place for the 2020-2022 period, which it broke down into Communications Strategies for 2020 and 2021, its 2021 annual progress report is transparent in noting that the strategy had not been effectively implemented as of end-2021. Indeed the 2020-2022 Communications Strategy was only translated into the second national language (English) in 2022, according to the 2022 annual progress report. The MSG does not appear to have taken actions to consider different access challenges and information needs of different genders and subgroups of citizens in its communications activities in this period. Cameroon EITI has ensured that some outreach events organised by government have been undertaken to spread awareness of and facilitate dialogue about governance of extractive resources, although these appear mainly limited to formal EITI Report launch events. Thus, it has held high-level launch events for its EITI Reports chaired by the MSG Deputy Chair the Minister of Mines, bringing together some members of the broader constituencies and covered in the press, since the previous Validation. It held launch events for the 2018 EITI Report on 29 June 2021, for the 2019 EITI Report on 19 November 2021 and for the 2020 EITI Report on 16 December 2022. The EITI Report launch events have tended to gather around 100 participants including the MSG and EITI focal points, with televisions and radio broadcast coverage of the events. These are formal launch events, rather than for active public debate. Other outreach and dissemination events led by Cameroon EITI appear to have been severely limited in this period. The 2021 annual progress report only lists the two EITI Report launch events and makes general reference to public statements by the MSG Deputy Chair, Minister of Mines Gabriel Dodo Ndoke, as evidence of EITI communications. Cameroon EITI’s online activities were equally limited in this period. Although the MSG agreed ToR to upgrade the Cameroon EITI website in 2021 and reinvigorate the Cameroon EITI Twitter and Facebook accounts, the website does not appear to have been upgraded to date. The Cameroon EITI Twitter contains ten posts from 2021, seven posts from 2022 and nine posts from 2021, while its Facebook page includes 20 posts from 2021, 18 posts from 2022 and 11 posts from 2023. The civil society constituency has led several of their own outreach and dissemination activities in this period however, even if engagement in EITI communications from the other two constituencies is not clearly documented. Thus, in 2021, civil society organised a three-day mining forum in the eastern town of Bertoua in January 2021, a debate conference on the management of mining revenues in May 2021, and contributions to the first two-day Pan-African Conference on Illicit Financial Flows in October 2021, as documented in the 2021 annual progress report. Civil society also participated in a radio show on extractive industries and sustainable development in January 2021. Civil society has published occasional position papers and advocacy notes. In 2021, the Oxfam Novib-funded CRADEC project on equitable mining issued a position paper on behalf of host communities calling for enactment of implementing regulations for the 2016 Mining Code. However, consultations with civil society raised significant concerns over weaknesses in EITI-related outreach and dissemination. Many CSOs consulted considered that Cameroon EITI efforts were insufficient and focused only on the capital city Yaoundé, not in extractive-rich regions. They also repeatedly highlighted civil society’s own financial capacity constraints, which hindered their ability to plan more proactive outreach and dissemination in extractive-rich regions. The industry constituency’s comments on the draft Validation report argue that extractive companies conduct outreach and dissemination activities targeting their key stakeholders, defined as communities around their activity sites. While the International Secretariat acknowledges extractive companies’ bilateral outreach and dissemination activities planned as part of their commercial operations, it continues to find little evidence of the use of EITI findings and data in these outreach and dissemination efforts. There are opportunities for extractive companies to make greater use of EITI findings and data to support and help drive public debate around extractive industry governance, particularly in relation to their key stakeholders around extractive activity sites. Despite the lack of more proactive dissemination efforts, some Cameroon EITI disclosures have led to significant public debate in this period on a few specific issues during the period under review. For instance, the publication of the SINOSTEEL contract in 2022 led to such public debate that the Minister of MINMIDT was asked to defend the terms in front of Parliament. However, Cameroon EITI has not discussed other current issues in the extractive industries despite public debate, such as the potential impact on Chadian crude oil exports via Cameroon following a change in operatorship of Chad’s Doba oil project and in the equity structure of the Chad-Cameroon oil pipeline. Other public debate about scandals appears to have been incidental to the EITI process. There was considerable public debate in the national press about Glencore’s admission of corruption involving Cameroon’s national oil company SNH in 2022. For instance, Equinoxe TV carried a televised debate on the Glencore affair in June 2022 following the Glencore plea agreement that named Cameroon’s SNH and SONARA. However, Cameroon EITI does not appear to have made any contributions to this public debate until 2023, with only a press release from SNH in May 2022 stating that the national oil company does not engage in such practices. Only following the International Secretariat’s mission did the MSG hold a discussion on the issue at its late August 2023 meeting. Stakeholders from all constituencies involved in the EITI expressed significant frustration at the International Secretariat for the lack of public disclosures of the names of corrupted Cameroonian officials for them to investigate, despite the fact that Glencore is an EITI supporting company. While stakeholders saw the value of a data analysis of crude oil sales in 2017-2020 prepared by the International Secretariat, none of the stakeholders consulted could explain why Cameroon EITI could not conduct this type of analysis on crude oil exports for the 2012-2015 period concerned by the Glencore affair. Overall, the Secretariat considers that there are significant gaps in the technical aspects of Requirement 7.1. These include the lack of any distribution in print format despite access challenges, the lack of translation in appropriate languages (e.g. English) in a timely manner and the limited outreach and dissemination events held by Cameroon EITI and all three constituencies, including civil society, which could allow for more critical public debate using EITI data.

The Secretariat’s assessment is that Requirement 7.2 is mostly met. The Secretariat’s view is that the objective of enabling the broader use and analysis of information on the extractive industries, through the publication of information in open data and interoperable formats, is mostly achieved, given delays in publishing all data from Cameroon’s EITI Reports in open format. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 7.2, based on the fact that the MSG had approved the Cameroon EITI open data policy in 2017 and that this led to the operationalisation of open data publication practices by stakeholders such as Gaz du Cameroon. They also note the public availability of EITI summary data files on the Cameroon EITI and relevant ministry websites. While the International Secretariat acknowledges these points, it notes that all data in Cameroon’s EITI Reports has not yet been published in open format in accordance with Requirement 7.2.b, beyond the publication of summary data files for each EITI Report. Cameroon EITI has had an open data policy since 2017 that defines the terms for release, use and reuse of EITI data. While the policy is published on the Cameroon EITI website, it is challenging to locate without a specific search given that it is not linked to from any webpage on the Cameroon EITI website. Since the last Validation, Cameroon EITI has started publishing the annexes to its EITI Reports in open format, with annexes to the 2020 EITI Report and the 2021 EITI Report published in open format. However, all data sets in the EITI Reports have not yet been published in open format, even if the annexes contain much of the required information. In September 2023, the National Institute of Statistics (INS) launched a portal republishing the data on extractive industries’ contribution to GDP, exports and employment from EITI Reports, with an option for bulk download in open format. Cameroon EITI has prepared Summary Data files for the 2018, 2019, 2020 and 2021 EITI Reports published since the last Validation, which it submitted to the International Secretariat and published on its website. None of the data that is systematically disclosed on government and extractive company websites appears yet available in open format, with the notable exception of SNH’s systematic annual disclosures of production and the state’s in-kind revenues. While the assessment of Requirement 7.2 appears borderline between ‘mostly met’ and ‘fully met’, given that the annexes to the EITI Reports published in open format contain much of the data in the EITI Reports, the Secretariat considers that the lack of publication of all EITI data in open format is a concern given the uses of this data by other government portals such as the INS open data portal.

The Secretariat’s assessment is that Requirement 7.3 is mostly met, which is a regression since the last Validation. Stakeholders consulted did not express particular opinions on the objective of ensuring that EITI implementation is a continuous learning process that contributes to policymaking. The Secretariat’s view is that, despite the fact that there is a regular follow up of findings and recommendations from the EITI process, the mechanism for follow-up on EITI recommendations is not sufficiently robust given the insufficient implementation of both corrective actions from previous Validations and recommendations from EITI Reports, which has weakened the effectiveness of the EITI’s contribution to policy making during the period under review. The Secretariat’s view is that there is a mechanism for follow-up on EITI recommendations, which has tended to focus on follow-up on recommendations related to disclosures rather than broader sector reforms or implementation of recommendations and corrective actions related to Cameroon EITI’s governance. Several stakeholders consulted from all constituencies held significantly different views on progress towards the objective, and considered that the objective had been fulfilled given the evidence of tangible reforms in issuing decrees on beneficial ownership and overcoming bottlenecks to subnational transfers of artisanal mining revenues. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 7.3. They highlight that the MSG has regularly discussed a matrix of the status of follow-up on EITI recommendations during its meetings in 2021-23. They argue that the MSG’s discussions of this matrix allowed them to remain updated on advances and challenges in the implementation of specific corrective actions and recommendations. The International Secretariat notes these clarifications, which warrant an upgrade in the assessment of Requirement 7.3 from ‘partly met’ to ‘mostly met’, but emphasises the need for Cameroon EITI to strengthen its follow-up on EITI recommendations, ensuring that the mechanism to do so is robust and publicly accountable. The MSG has tracked progress in following up on corrective actions and strategic recommendations from the previous Validation through a dedicated matrix, which appears to be regularly updated. Stakeholder consulted explained that the mechanism for follow-up on recommendations from EITI Reports consists of the MSG delegating the follow-up to an ad hoc working group composed of both MSG members and national secretariat staff. This ad hoc working group has the responsibility of following up EITI recommendations from both Validation and EITI Reports, in addition to its main role of reviewing draft EITI Reports. The ad hoc working group follows an MSG-adopted ToR, which details its role, members and responsibilities. This working group held several meetings in 2023 in particular, although neither the working group’s ToR, the working group’s resolutions or the matrix of follow-up on EITI recommendations have been made public. In practice, there is evidence from MSG meeting minutes that the MSG has regularly discussed the source and nature of discrepancies in the reconciliation of company payments and government revenues, but has focused less on EITI recommendations linked to broader sectoral reforms. Consulted stakeholders from government and the national secretariat indicated that, in practice, the National Coordinator plays a key role in personally following up on EITI recommendations with specific government agencies. For instance with regards to recommendations related to disclosures by SNH, several stakeholders confirmed that the National Coordinator followed up with SNH directly, without involvement of the MSG. The SNH representative on the MSG participated in MSG meetings, and this was considered the mechanism linking SNH’s follow-up on EITI recommendations with the MSG’s oversight. However, minutes of MSG meetings do not indicate that SNH’s implementation of reforms linked to EITI recommendations have been discussed at MSG meetings. The primary progress has been in the implementation of recommendations related to EITI reporting, although there are still a number of these recommendations yet to be implemented. The 2021 EITI Report indicates that five recommendations from 2019 EITI Report and more than ten recommendations from the 2018 and previous EITI Reports are yet to be implemented. With regards to recommendations from previous two Validations, several recommendations (and corrective actions) related to stakeholder engagement and outcomes and impact are yet to be implemented, Stakeholders consulted seemed aware of weaknesses identified as the basis of these recommendations, although few actions were taken to date, even if progress on corrective actions related to transparency was stronger. Yet the Secretariat’s review of EITI Reports and stakeholder consultations indicate that follow-up on EITI recommendations has led to concrete government legal and administrative reforms. Stakeholders consulted from all constituencies considered that reforms such as the expansion of beneficial ownership reporting requirements to companies in all sectors of the economy was due to advocacy by the EITI, even if such ownership reporting was not yet public. They also highlighted implementation of reforms in the calculations and disbursements of subnational transfers linked to (particularly artisanal) mining revenues was attributable to EITI follow-up. Stakeholders also highlighted reforms such as SNH’s systematic disclosures of oil production and sales in open format and the full text of its 2021 audited financial statements was due to the EITI (see Effectiveness and sustainability indicator 5). While recognising the importance of reforms implemented in the period under review, the Secretariat considers that the mechanism in place for the MSG to follow up on recommendations from EITI reporting and Validation is fragmented and not sufficiently robust. The MSG’s ad hoc working group on reporting also oversees follow up on recommendations (and thus likely prioritises recommendations related to EITI reporting), using a matrix that is not publicly accessible. The National Coordinator is responsible for the follow up with specific entities like SNH to implement certain EITI recommendations, with unclear oversight of the MSG. Meanwhile there is little evidence of the MSG discussing the status of follow-up on recommendations related to broader extractive industry governance or public finance management reform. Thus, the Secretariat considers that the objective is still in the process of being fulfilled.

The Secretariat’s assessment is that Requirement 7.4 is partly met, which is a regression since the previous Validation. Most stakeholders consulted did not express particular views on whether the objective of ensuring regular public monitoring and evaluation of EITI implementation had been achieved. However, several stakeholders considered that this had not been consistently met in the period under review, given that the publication of the 2021 and 2022 annual progress reports were delayed until right before Validation. The Secretariat’s view is that the broader objective is not met given the delay in publishing the APRs, which had already been raised as a corrective action from the previous Validation that has not been addressed. This situation prevents EITI Cameroon from ensuring regular public monitoring and evaluation of implementation, particularly given the lack of sufficient attention to documenting impact and the limited evidence of consultations with the broader constituencies in the annual review. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 7.4, albeit conceding that the publication of the 2021 and 2022 annual progress reports in September 2023 was delayed. However, the comments explain that the MSG has consistently reviewed the status of follow-up on EITI recommendations at the start of each year, which leads to a discussion of EITI outcomes and priority activities for the year ahead. They also argue that the MSG’s 2017 open data policy provided the framework for developing the 2023 work plan. While the International Secretariat acknowledges these points, it continues to emphasise the lack of a publicly accessible review of the EITI’s outcomes and impacts on an annual basis, drawing on input from the broader constituencies. Cameroon published annual reports covering 2021 and 2022 in September 2023. Cameroon EITI did not publish other types of annual reviews of outcomes and impact of the EITI process in the period since the previous Validation. The latest annual progress report includes an assessment of the progress in implementation of 2021-2023 work plan. The report also provides an overview of the status of follow-up on recommendations from EITI Reports and a self-assessment of progress in addressing provisions of the 2019 EITI Standard. The annexes to the annual progress report provide a review of EITI Cameroon’s finances as of 2022. While the annual progress report includes a page on outcomes and impact of the EITI process, it includes a list with a cursory review of some outcomes and impacts, such as a better understanding of the notion of conflict of interest and contribution to public debate on the Glencore affair. However, the list does not clearly articulate how the EITI led to these impacts, nor articulate any views on how the EITI’s impact could be strengthened in Cameroon. The MSG’s comments on the draft Validation report argue that the changes in Cameroon EITI’s use of ad hoc working groups was a consequence of the MSG’s better understanding of the notion of conflict of interest, which was specifically discussed at MSG meetings in June 2021 and August 2022. Explaining the context of the MSG’s use of ad hoc working groups, the comments notes that the reconstitution of working groups in August 2022 led to a reduction in MSG members participating in these working groups, substituted by technical focal points and national secretariat staff. Several stakeholders consulted confirmed their participation in the preparation of the progress reports, although several CSOs not directly represented on the MSG but engaged in the broader constituency on the EITI noted that they were not consulted in the preparations of the Cameroon EITI annual progress reports and did not consider that their views were reflected in the progress report. Thus, the Secretariat considers that there remain significant gaps in addressing the technical aspects of Requirement 7.4, including a lack of clear consultations with the broader constituencies, a lack of annual publication of such reviews of outcomes and impacts, and an insufficient documentation of the MSG’s self-assessment of the impact of the EITI process to date. These gaps imply that the objective is still far from being fulfilled.

The Secretariat’s assessment is that Requirement 1.1 is mostly met, which is a regression from the previous Validation. The Secretariat’s view is that the objective of full, active and effective government lead for EITI implementation at both political and operational levels has been mostly fulfilled in the period under review. Opinions of consulted stakeholders were split over whether government engagement in the EITI was full and effective. Stakeholders from government, industry and some within civil society considered that the government was fully engaged and that the lack of the MSG Chair’s participation in meetings did not have an impact because he always sent a representative to observe, and that the MSG Vice-Chair, the Minister of Mines, often chaired MSG meetings in the MSG Chair’s absence. However, other stakeholders, including from civil society, considered that government leadership of the EITI had fluctuated over the years and had not been consistently effective. Several MSG members considered that MSG decisions were not systematically implemented given weaknesses in the Cameroon EITI Secretariat’s capacities and the lack of the MSG Chair’s attendance. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 1.1, emphasising the high degree of engagement of the various government entities that publish documents such as laws and activity reports on the extractive industries on their respective websites. References to the websites of the Ministry of Finance, MINMIDT, the national oil company SNH and the anti-corruption body CONAC are provided. The International Secretariat acknowledges the importance of these points, particularly related to the government’s commitment to the EITI and its gradual regularisation of secretariat staff and payments to vendors, yet it notes that these improvements took place in recent months and that weaknesses in the state’s engagement in all aspects of the EITI process persisted during the period under review. Sustaining the recent improvements in the government’s operational leadership of the EITI will be crucial to sustaining progress in EITI implementation. There have been relatively regular statements of commitment to the EITI from senior government officials since the previous Validation concluded in January 2021. This has included statements from Minister of Finance and Cameroon EITI MSG Chair Louis Paul Motaze (such as in April 2023 in meeting a mission from the International Secretariat), from the Delegated Minister to the Minister of Finance Abdoulaye Yaouba, and from the MSG Vice-Chairs. The MSG’s ‘Transparency’ template for this Validation lists the President of the Republic’s agreement to revise the EITI Decree and instructions to the Prime Minister to renew the government’s commitment to the EITI. The MSG comments on the draft Validation report highlight that the new government decree on the EITI was enacted in January 2024. It also highlights the legal reforms related to collecting beneficial ownership data (see Requirement 2.5) and the publication of mining contracts as examples of government leadership in overcoming barriers to the EITI. There was consensus among stakeholders consulted that there was high-level government commitment to the EITI and that several international commitments referenced the EITI process, including the government’s commitments under the IMF programme. The MSG’s comments on the draft Validation report highlight an official letter in October 2023 from the Secretary General of the Presidency to the Prime Minister directing the government to create a new budgetary line explicitly dedicated to the EITI, which the MSG notes as strong evidence of EITI engagement from the highest levels of the state. The MSG’s comments also provide a letter from the Prime Minister to EITI Chair Helen Clark highlighting the government’s commitment to EITI implementation. There has consistently been an EITI Champion to help steer the EITI process. Minister of Finance Louis Paul Motaze has acted as Cameroon EITI and MSG Chair since 2018, supported by the Delegated Minister to the Minister of Finance Abdoulaye Yaouba. In practice, while the Minister of Finance has taken steps to lead EITI implementation by issuing relevant Decrees and Orders, the operational engagement in MSG has been led by the Minister of MINMIDT and Cameroon EITI MSG Vice Chair, who was Gabriel Dodo-Ndoke until his untimely death in January 2023, replaced by Calistus Gentry. Indeed the MSG Chair has not attended any EITI meetings in the period under review. At the operational level, most government entities attend MSG meetings, but do not contribute or engage at the same level across government entities. There are important variations between the host Ministry of Finance and its departments and the MINMIDT on the one hand, and other government entities that are less directly responsible for oversight of the extractive industries. Government entitles have broadly provided the required data for the last four (2018-2021) EITI Reports produced since the last Validation. The most active government entities in the EITI (MoF and MINMIDT representatives) participate in the few outreach and dissemination activities organised by Cameroon EITI (as documented in media cuttings collected by Cameroon EITI – see Requirement 7.1) but there is little evidence of government entities and officials using or promoting EITI data further beyond republishing some EITI documents. For instance, the websites of the Ministries of Finance and of MINMIDT republish the EITI Reports annually. While government engagement in the EITI process has been structured in hierarchical terms within each relevant government entity, there is evidence of MSG members coordinating with their broader constituency. As documented in the MSG’s ‘Stakeholder engagement template, government MSG members have canvassed the views of their colleagues within each relevant government entity in developing the annual work plans and annual progress reports in 2021-2022, although the level of input from the broader constituency in response to this canvassing remains unclear (see Requirement 1.5). Several government officials consulted explained that all EITI focal points in government entities participated in a common WhatsApp group on the EITI, in addition to using their respective government entities’ WhatsApp groups to disseminate EITI information. The government has taken some steps to overcome legal barriers to the EITI, including starting work with the MSG on revisions to the July 2018 Government Decree on EITI as early as 2021, with the new decree was finally enacted after the start of this Validation, in January 2024. The MSG established an ad hoc working group in 2021 to lead drafting of proposed revisions and the working group completed a new draft EITI decree, according to the 2021 annual progress report. There is evidence of government follow-up on some EITI recommendations, such as those related to subnational transfers. The government has taken steps to follow up on the Glencore affair, mainly in requesting the names of corrupted Cameroonian officials and threatening legal prosecution of Glencore. Government officials consulted stated that investigations into the affair were ongoing, but there is no public documentation of government efforts to investigate the national oil company and oil refinery to identify responsible individuals to date. The government’s financial support for EITI implementation has increased significantly in the period under review, although stakeholders have reported that this support has been insufficient to cover all aspects of the EITI process beyond production of EITI Reports. Government funding for the EITI process grew in the period under review, according to the respective annual progress reports and work plans.: • XAF 146.7m (around USD 254,980) in 2020 • XAF 481.4m (around USD 866,500) in 2021 • XAF 317.4m (around USD 507,860) in 2022 • XAF 598.7m (around USD 960,700) in 2023 The MSG’s comments on the draft Validation report highlight an official letter in October 2023 from the Secretary General of the Presidency to the Prime Minister directing the government to create a new budgetary line explicitly dedicated to the EITI. This increase in funding notwithstanding, there remain symptoms of dysfunctions within the government’s provision of national secretariat support to its EITI MSG. Indeed, the Secretariat’s understanding is that at the start of this Validation (October 2023), the contracts of national secretariat staff had still not been signed, some having worked for Cameroon EITI for as long as 12 years. The MSG’s comments on the draft Validation report highlighting the signing of employment contracts for all national secretariat staff after the commencement of Validation and included copies of each employment contract. The MSG’s comments also provide a copy of a January 2024 order from the Minister of Finance establishing a working group within the Ministry to oversee the regularisation of the status of all secretariat staff and the settlement of their salary arrears. Meanwhile Cameroon EITI was significantly delayed in completing payment for the 2016 and 2017 EITI Reports that were produced in February 2019 and February 2020 respectively, but for which payment was only completed in 2021 according to the 2021 annual progress report. Likewise, the Independent Administrator (IA) for the 2020 and 2021 EITI Reports has been operating without a contract, with consequently delayed payments for its services. The Secretariat’s understanding is that there are also unpaid arrears to various vendors, such as for website maintenance. The MSG’s comments on the draft Validation report note that the IA accepted to work without a finalised contract given its confidence in the state and the need to comply with reporting deadlines, explaining that the settlement of payments to the IA follows the conventional administrative procedures. The comments also note the strict commitment to settle any outstanding payments to vendors such as the website service provider, which led to the reactivation of the Cameroon EITI website. Thus, while most aspects of the objective of full and effective government leadership of the EITI process have been fulfilled, there remain gaps in the government’s operational oversight of the EITI process, in the financial management of the Cameroon EITI Secretariat and the need to reinforce its technical capacities.

The Secretariat’s assessment is that Requirement 1.2 is mostly met, which is a regression from the previous Validation. The Secretariat’s view is that the objective of full, active and effective industry engagement in the EITI has been mostly fulfilled in the period under review. Most consulted stakeholders considered that extractive companies’ EITI engagement was limited to providing the required data for EITI Reports and attending MSG meetings and EITI-organised dissemination events, rather than more proactive engagement in other aspects of the EITI process, such as input to the design of the process or driving their own outreach and dissemination efforts. While company representatives consulted considered that the industry constituency’s engagement in the EITI was strong, they conceded that there was scope for improving on the timeliness and efficiency of company EITI reporting. Industry representatives considered the objectives of their EITI engagement to be primarily a compliance issue. Several government officials considered that companies should be more proactive in driving EITI outreach and communications, and not just wait for the Cameroon EITI Secretariat to take the lead. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 1.2, noting evidence of the constituency’s input to the development of EITI documents and plans to reinvigorate the mining sub-constituency’s engagement in the EITI process. The International Secretariat takes note of these points and plans for the future, but notes that there were weaknesses in the broader industry constituency’s engagement in many aspects of the EITI process during the period under review, particularly with regards to the broader constituency’s input to key EITI documents (beyond input from MSG members) and the design and conduct of EITI outreach and dissemination. The industry constituency continues to structure its engagement in the EITI process according to a protocol concluded on 31 October 2018, which remains unpublished. Industry’s participation in the EITI has remained focused on participation in MSG meetings and the provision of data for EITI reporting. The key companies and organisations in the sector remain represented on the MSG as in the previous Validation, when this was assessed as fully met. In practice the industry MSG members attend or delegate attendance to a consistent proxy for all MSG meetings in the period under review. Material companies have provided the required data and quality assurances for EITI reporting in the last four reports published since the previous Validation in 2020. While systematic disclosures of EITI data by extractive companies remains highly limited in Cameroon, one oil and gas company (Gaz du Cameroun) has begun publishing its EITI disclosures on its website as of mid-2023. There is very limited evidence of companies using, promoting or disseminating EITI data, beyond GICAM’s use of EITI data during its commission meetings and debate dinners. The MSG’s comments on the draft Validation report highlight a higher engagement from extractive companies through their publication of extractive industry information. The industry constituency’s comments on the draft Validation report argue that extractive companies are engaged in transparency efforts around their own operations, but consider it the role only of the Cameroon EITI Secretariat to undertake outreach and dissemination around the EITI. Nonetheless, the constituency’s comments include extractive companies’ commitment to help drive communications efforts as part of their participation in Cameroon EITI and the MSG. In terms of practical methods for coordinating the constituency, the MSG’s ‘Stakeholder engagement’ template lists a communications platform established on EITI between oil and gas companies, a WhatsApp group established by the Cameroon EITI Secretariat to communicate with the broader constituency, occasional in-person meetings of the broader constituency and another WhatsApp group of industry members of the Cameroon EITI MSG. The Chamber of Commerce, Industry, Mines and Handicraft (CCIMA), which holds a seat on the MSG, maintains a WhatsApp group for over 200 of its members and staff, where it occasionally shares information on EITI developments, and publishes some information about the EITI (such as EITI Reports and key MSG decisions) on the CCIMA website. However, in practice these groups appear to have been used to disseminate information rather than facilitate a two-way conversation between industry MSG members and the broader constituency and the effective canvassing of views of the broader constituency. Indeed the ‘Stakeholder engagement’ template explains that the finalised work plans and annual progress reports have been disseminated through the Cameroon EITI Secretariat’s WhatsApp group and that feedback from the broader constituency can be sent to the Cameroon EITI Secretariat, rather than to industry MSG members. Industry representatives consulted noted that companies’ coordination on the EITI remained informal, using their existing communications channels to discuss EITI issues on an ad hoc basis. The MSG’s comments on the draft Validation report argue that there was no large operator in the mining sector during the period under review, given that the sector was dominated by artisanal and small-scale mining. The comments explain that the SOE SONAMINES will play the role of constituency coordinator for the mining sector following the example of SNH for the petroleum sector in order to strengthen the constituency’s engagement in the EITI. The MSG’s comments highlight that the industry constituency provided input to the development of key EITI documents such as EITI work plans and annual progress reports, and that they engaged in webinars organised by the International Secretariat. Notwithstanding the industry constituency’s own internal weaknesses in its EITI engagement, there remains an enabling legal and regulatory environment for company participation in all aspects of the EITI process.

The Secretariat’s assessment is that Requirement 1.3 is partly met, which is a regression since the previous Validation. The Secretariat’s view is that the objective of full, active and effective civil society engagement in the EITI process is far from being fulfilled, given weaknesses in the constituency’s engagement in the EITI and challenges in its ability to use the EITI process to influence public decision-making linked to a lack of accountability in a majority of civil society’s representatives on the MSG and broader MSG governance challenges (see Requirement 1.4). The Secretariat also considers that the objective of an enabling environment for civil society engagement in the EITI process and public debate on extractive industry governance is far from being fulfilled, given breaches of the EITI protocol: Participation of civil society related to freedom of expression. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 1.3, based on evidence and arguments presented by the civil society constituency. In particular, the comments argue that the constituency’s engagement is demonstrated through several documents including civil society’s separate comments on the draft Validation report, a letter from CSO MSG members reiterating their commitment to the EITI, a press release by the constituency’s OSCC-ITIE platform, minutes of the OSCC-ITIE’s 26 January 2024 meeting as well as references to the CRADEC and Transparency International Cameroon websites. The civil society comments acknowledge the Validation report’s concerns related to the environment for civil society engagement and weaknesses in the constituency’s organisation. However, the comments include objections to the Validation report’s arguments that the constituency’s broader engagement, including outreach and dissemination efforts, are driven by the minority of organisations nominated to the MSG through open and competitive procedures. The constituency’s comments confirm that there have been constraints on its ability to play its full role in EITI implementation, constraints that it considers linked to the broader socio-political and legal context but categorised as factors that civil society has not been able to influence. The comments include a commitment for civil society to pursue its advocacy with government to ease constraints on civic space. With regards to the lack of a spokesperson for the OSCC-ITIE platform, weaknesses in the platform’s functioning and the lack of accountability of some CSO MSG members to the broader constituency, the comments also include a commitment to resolve all of these challenges with urgency, as confirmed at the constituency’s meetings on 12 and 26 January 2024, at which a spokesperson was appointed according to civil society’s detailed comments. The International Secretariat welcomes these commitments to address challenges identified in this Validation with urgency. While the International Secretariat understands that lifting constraints related to civil society’s ability to play its full role in the EITI process and public debate on extractive industry governance are not the sole purview of the civil society constituency and that action by authorities and the MSG will also be required, it considers that the comments received on the draft Validation report confirm the existence of constraints on freedom of expression and of operation in relation to the EITI process that have contributed to weakening civil society’s ability to fulfil its EITI responsibilities, further exacerbating divisions within the constituency. While the constituency’s commitment to start addressing these challenges is welcome, the Validation’s assessment of the period since 2021 has highlighted challenges that should be addressed to optimise the EITI’s contribution to improvements in extractive industry governance. Cameroon’s scores in international civic space rankings have remained low in the period under review. Cameroon’s ranking in the Freedom in the World has declined slightly from 18 points (out of 100) in 2020 to 15 points in 2023, albeit consistently ranked as ‘not free’ throughout this period. The international NGO CIVICUS has continued to rank Cameroon’s civic space as ‘repressed’ throughout this period (since 2016). The continued security challenges in the Anglophone western regions and linked to Boko Haram in the north have provided a challenging context for civic space in those areas in particular. Civil society has developed a draft bill for the protection of human rights defenders that was submitted to the Senate in early 2022, but the status of the bill remains unclear as of October 2023. In terms of expression, there is evidence that the 2014 Law on the Repression of Terrorist Acts and the criminal defamation provisions of the 2016 Penal Code have constrained civic space more broadly in Cameroon, although not specifically on the EITI process. In practice, there have been growing attacks on journalists, including both from government and private armed groups. Several journalists investigating corruption were murdered in early 2023, although the perpetrators of these crimes remain unidentified at the time of this Validation. Many international civil society and development partner analyses of civic space in Cameroon (such as from CIVICUS, Freedom House and the US Department of State) indicate strong suspicions of self-censorship on sensitive issues related to the Presidency and the oil and gas sector in particular. Opinions of stakeholders consulted were split, with some CSOs considering that there were no constraints on their freedom of expression, while others considered that the broader civic space constraints caused CSOs to be cautious in their public statements, for fear of potential reprisals from the state. Within a broader environment for public expression and the media that remains constrained according to international civic space indicators, the Secretariat’s view is that civil society substantially engaged in the EITI process have followed a pattern of caution in their public statement, with different statements made in public than in confidential bilateral conversations. In contradiction to the main body of MSG comments, the detailed civil society comments on the draft Validation report strongly oppose this statement, arguing that there are no restrictions on civil society’s freedoms of expression, operation or association, citing examples of public statements on the Glencore affair by CSOs engaged in the EITI. The Secretariat’s assessment is that civil society representatives are not able to speak freely in public about all issues covered by the EITI process, such as allegations of corruption in the mining, oil and gas sectors, without fear of reprisal from the state. This is considered a breach of the EITI protocol: Participation of civil society related to freedom of expression. In terms of operation, civil society appears able to register without excessive administrative burdens. Despite broader civic space reports’ references to delays and difficulties in registering some CSOs engaged in governance, anti-corruption and human rights, all CSOs substantially engaged in the EITI process appear duly registered. Statutory procedures requiring government approval for access to foreign funding remain unenforced, as in the previous Validation. There is evidence that CSOs engaged in the EITI are able to access foreign funding, as they have continued to do since 2021 even if there are reports of growing challenges in CSOs working on extractive issues accessing foreign funding given donors’ evolving thematic focus. In terms of association, there continue to be administrative restrictions to civil society organising public meetings and demonstrations, despite constitutional guarantees for freedom of association. The MSG’s ‘Stakeholder engagement’ template provides an inventory of events organised by civil society on issues directly related to the EITI process and linked to broader extractive industry governance issues. Most events have consisted in press conferences, public workshops and capacity building events, rather than public demonstrations or rallies. The OSCC-ITIECAM platform established in 2018 as the key channel for organising civil society’s engagement in the Cameroon EITI process continued to act as the constituency’s key coordination mechanism in the period under review. A constituency spokesperson has not yet been appointed for OSCC-ITIECAM, although opinions of CSOs consulted were split on the necessity of appointing a permanent spokesperson. Most CSOs consulted outside of the MSG did not consider that the OSCC-ITIECAM platform was operating the way it should, in part due to lack of funding from its members. The Secretariat considers that civil society is able to associate in relation to all aspects of the EITI process, given that CSOs consulted did not cite constraints on their ability to hold public events related to the EITI despite government restrictions on the holding of public events. In terms of engagement, there do not appear to be any statutory government constraints on civil society’s ability to engage in the EITI process since the previous Validation. Civil society representatives regularly and consistently attend MSG meetings and conduct some analysis of EITI Reports. However, active engagement in MSG discussions, outreach and dissemination appears to be driven by organisations that have been nominated by their broader constituency to represent them in the EITI process, rather than organisations that have been statutory named in the EITI Decree to represent their specific organisations in the EITI process. The civil society detailed comments on the report highlight that PWYP Cameroon conducted EITI outreach and dissemination activities during this period. Only two of the eight MSG seats reserved for the civil society constituency are earmarked for members to be appointed by their broader constituency, namely two CSOs working on extractive industry governance and a representative of the Cameroonian PWYP coalition. The Secretariat understands that several current MSG members from civil society (named by the EITI Decree) currently work for (or have recently retired from) government. While there were different views among different CSOs consulted over whether such government employment constituted a conflict of interest, the Secretariat considers this a concern given that the vast majority of the constituency’s engagement in the EITI process appears driven by the minority of CSOs that have been appointed to the MSG by the broader civil society constituency, rather than representatives of organisations statutorily appointed to the MSG that have in many cases not changed for over ten years. The civil society detailed comments argue strongly that there should be a distinction between individuals and organisations represented on the MSG, noting that there had been rotation in PWYP Cameroon’s Technical Secretary but that the representative had consistently been engaged in EITI outreach and dissemination. The MSG’s comments highlight that the new government decree on the EITI was enacted in January 2024 and expanded the number of civil society MSG seats from eight to 12, opening up all seats to open, competitive nominations. In terms of access to decision-making, there do not appear to be any statutory barriers to civil society using the EITI process to discuss extractive industry issues of relevance for public debate and public policy making. In practice, it appears that CSOs – particularly those nominated in an open, fair and transparent manner to represent the constituency on the MSG – are able to add to the agenda of Cameroon EITI MSG meetings and to use the EITI process to follow up on issues of priority for their constituency. However, several CSOs consulted considered that there were weaknesses in the MSG’s capacities to effectively oversee the EITI process given capacity constraints within the Cameroon EITI Secretariat and the lack of attendance at MSG meetings by the MSG Chair. While consulted civil society representatives’ views were split over this issue, some CSOs considered that MSG decisions were not always implemented given the Cameroon EITI Secretariat’s staffing challenges and the fact that the MSG Chair and Minister of Finance did not always implement the MSG’s decisions. The Secretariat considers that civil society’s ability to use the EITI process to access public decision making remains only partial given weaknesses in the accountability of a majority of MSG members representing the constituency and broader weaknesses in the MSG's governance.

The Secretariat’s assessment is that Requirement 1.4 is partly met, as in the previous Validation. The Secretariat’s view is that the objective of an independent MSG with active and meaningful oversight of all aspects of EITI implementation is not fulfilled in the period under review. Most consulted stakeholders from all constituencies conceded that there had been challenges to the MSG’s operations in the period under review, but most stakeholders considered that the objective of MSG oversight was now in the process of being fulfilled. In particular, industry and government representatives considered that there had been a net improvement in the MSG’s oversight since the challenges of early 2021 when Cameroon was suspended due to delays in its EITI reporting. However, many CSOs consulted considered that there were challenges in the MSG’s functioning, although opinions within the constituency were split over the nature of the challenges and over whether they were in the process of being addressed. Some partners consulted considered that it was the status quo since the previous Validation in terms of the MSG governance and oversight of the EITI process. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 1.4, given the regularisation of secretariat staff contracts, statutory provisions for greater coordination and engagement of the constituencies in the EITI process, provisions related to gender balance in MSG representation and plans for greater constituency involvement in outreach and dissemination. The International Secretariat acknowledges these important points, but considers that weaknesses in the constituency’s representation and engagement in the EITI process during the period under review, combined with weaknesses in MSG oversight, imply that the objective of balanced multi-stakeholder oversight of the EITI was still far from being achieved in recent years. With regards to constituency representation in the EITI process, the MSG has not comprehensively renewed its membership since the last renewal in August 2018. While the MSG members’ terms is set at three years renewable once in the 2018 EITI Decree, the MSG’s composition has not been renewed since the previous Validation given that the Ministry of Finance decision confirming the composition of the MSG was only issued in February 2020, thereby only requiring a renewal of MSG membership in 2023. There is no indication that the procedures for renewing the MSG’s membership had started as of the commencement of this Validation (in October 2023). There have been ad hoc renewals of MSG members following the replacements of specific individuals within their respective organisations, including five MSG members from government and two from industry. As noted in the previous Validation, while government followed its hierarchical procedures for appointing its members to the MSG, there is no procedure in place to ensure that the majority of industry and civil society MSG members are appointed by their broader constituencies in open, free and fair nominations procedures. There were five replacements of government MSG members in this period. The MSG Chair did not attend any of the 43 MSG meetings in this period, and only seven of the 16 MSG members from government, parliament and local government attended a majority of MSG meetings since January 2021. The new EITI decree enacted in January 2024 integrates the Ministry of Environment and the new mining SOE SONAMINES into the MSG. Of the eight MSG seats reserved for industry, there is only evidence of a codified procedure for appointing the four oil and gas company representatives, while the EITI Decree reserves two seats for the industry associations (CCIMA and GICAM) and one seat each for companies in the oil transportation and mining sectors respectively. There continues to be no indication that a codified procedure exists for a competitive appointment of the mining company representative. Company representatives consulted confirmed that the national oil company SNH has continued to play the role of sub-constituency coordinator for the oil and gas sector, despite being listed as part of the government constituency in all public Cameroon EITI documents including the MSG’s ‘Stakeholder engagement’ template. The MSG’s comments on the draft Validation report confirm that SNH continued to play the role of oil and gas industry constituency coordinator during the period under review, in accordance with the sub-constituency’s protocol for coordination. Industry consultations indicated that oil and gas companies expect SNH to take the lead on substantive discussions regarding broader sector reforms, with illustrative examples provided such as the MSG’s work on disclosure of production-sharing contracts. Consulted company representatives considered their role on the MSG to be limited to compliance with Cameroon EITI rules related to attendance at MSG meetings and the provision of required data for EITI reporting, but not to proactive leadership in the design of the EITI process or in EITI-related outreach and dissemination (see Requirement 1.2). The MSG’s comments on the draft Validation report highlight provisions in the Cameroon EITI national communications strategy for each constituency to actively engage in outreach and dissemination, going beyond the provision of data for EITI reporting. The list of industry MSG members is provided in the ‘Stakeholder engagement’ template, including the replacements of the MSG members from Addax and GICAM in December 2021 and April 2023 respectively. Only half of the eight industry MSG members participated in a majority of the 43 MSG meetings held in the period under review, with MSG members from Perenco, Noble Energy, the Mining Federation of Cameroon and GICAM attending only a smaller number of meetings. Of the eight MSG seats reserved for civil society, a minority of only two seats (currently held by CRADEC and AGNR) are open for competitive appointments based on an open, free and fair nominations procedure facilitated by the OSCC-ITIECAM platform. The other six seats are reserved for representatives of organisations named in the EITI Decree, namely PWYP Cameroon, Transparency International Cameroon (TI-C), the Union of Journalists of Cameroon, and the three religious communities’ organisations. While PWYP Cameroon and TI-C are organisations that undertake some work on extractive industry governance, the relevance to the EITI process of activities of the other four organisations named in the EITI Decree is less clear. The MSG’s comments on the draft Validation report explain that the inclusion of religious organisations in the scope of the civil society constituency represented in the EITI is relevant in relation to communities hosting extractive activities, given the religious organisations’ reach in the country. The MSG’s comments also highlight the enactment of the new EITI decree in January 2024, which opened up all civil society MSG seats to open nominations and expanded their number from eight to 12. None of the CSO MSG members have been replaced since the previous Validation, while representatives of the three religious organisations appear to have been members of the MSG for over ten years. While all eight CSO MSG members attended a majority of MSG meetings in this period, a review of meeting minutes indicates that the most active MSG members from the constituency are those that have been appointed through a competitive process, as well as representatives from PWYP Cameroon and TI-C. In addition, it appears that at least two of the MSG members from religious organisations either currently work for (or have recently retired from) government employment. In terms of gender representation, a minority of only four of the 32 MSG members are women, including two each from the government and industry constituencies (and none from civil society). In preparation of the draft Validation report, there did not appear to be provisions for the consideration of gender in appointments to the MSG by either of the three constituencies’ nominations procedures and practices. However, the MSG’s comments on the draft Validation report noted that the civil society MoU for the participation of CSOs in the EITI process includes provisions for the consideration of gender aspects in the appointment of MSG members. Civil society representatives consulted noted that there was one woman civil society member of the Technical Secretariat of EITI focal points, which was confirmed in the MSG’s comments on the draft Validation report, but many CSOs expressed frustration at the low number of women representatives on the MSG. With regards to the MSG’s oversight of the EITI process, the general indicators of healthy MSG oversight were not positive in Cameroon during the period under review. Three months after Cameroon’s last Validation, it was suspended for missing its (extended) deadline for the 2018 EITI Report. The staff and vendors (e.g. website service provider) have continued to work without permanent contract (some for as long as 12 years) and with arrears in payment. The IA for the 2020 and 2021 EITI Reports have worked without a formal contract, with arrears in payment that have caused delays in reporting. The MSG has developed a draft new Decree governing the EITI, with significant input from civil society, the draft was still under review by the Minister of Finance as of the commencement of this Validation (October 2023). Thus, the Cameroon EITI MSG continued to operate under the 2018 Decree (2018/6026/PM) governing the EITI, which was assessed in the previous Validation and had not yet been updated for the 2019 EITI Standard. Following Cameroon’s suspension by the EITI in April 2021 due to the missed 2018 EITI Report deadline and the prolonged absence of key secretariat staff, the MSG chair and deputy chair established a “Provisional Administrative Management Unit” (UGAP) the same month in order to expedite production of the delayed EITI Report. Following publication of the EITI Report in June 2021, the unit was renamed “Priority Actions Management Unit” (UGAP). This unit essentially replaced key secretariat staff during their prolonged absence in 2021, steering the National Secretrariat and MSG’s work. The MSG also established an ad hoc working groups starting in the second quarter of 2021 to oversee production of the 2018 and 2019 EITI Reports. The MSG’s comments on the draft Validation report clarified that the temporary working groups to oversee production of the EITI Reports were disbanded when the UGAP was established in April 2021. Meanwhile the Technical Secretariat, which convened EITI focal points in government agencies, industry and civil society, appears to have continued some work informally, although it is unclear whether the previous practice of paying per diems for Technical Secretariat meetings continues. The MSG successfully navigated the mobility restrictions linked to the COVID-19 pandemic by holding online and hybrid meetings in 2021-2022. There are discrepancies between the number of MSG meetings listed in the MSG’s Stakeholder engagement template and successive annual progress reports and minutes of meetings available online. The higher frequency of MSG meetings in 2021 was due to the prolonged absence of key secretariat staff at a time of Cameroon’s suspension for delays in publishing its 2018 EITI Report. Civil society attendance is stronger in civil society, with all members attending regularly, than in industry or government, where only around half of MSG members participate regularly. The MSG includes anglophone members of all three constituencies, but makes little accommodation for their interventions given the lack of translation of basic documents or the substance of MSG discussions into English. There is a significant divide between anglophone and francophone MSG members that Cameroon EITI appears to have done little to alleviate. Nonetheless, decision-making appears to have continued to be consensual, if formal. All MSG members confirmed the consensual nature of MSG decisions in consultations. Documents appear to be largely circulated with sufficient advance notice, despite capacity constraints of the national secretariat. Minutes of MSG meetings are published on the Cameroon EITI website. There remain significant concerns, including from some stakeholders consulted off the MSG, over conflicts of interest on the MSG, in several respects. The long-standing issue of per diems has been clarified in terms of the rules and the practices, but the practices have not changed. The same people have been members of the MSG for over ten years. The other potential conflict of interest is the fact that several of the MSG members from the civil society constituency, namely the representatives from the Islamic Cultural Association and the Protestant Churches Council, appear to be employed by government (the Ministry of Finance and the Prime Minister’s Office respectively). These MSG members appear less active in discussions, based on MSG meeting minutes, and appear to not effectively represent the broader civil society constituency (see Requirement 1.3). A significant capacity constraint for the MSG lies in its support from a properly capacitated Cameroon EITI Secretariat. There was consensus among stakeholders consulted that the Cameroon EITI Secretariat did not have sufficient technical resources. Although four of the secretariat’s seven staff did not receive their “advances on salaries” in the period 2019-2020, Cameroon EITI’s 2021 annual progress report explains that these arrears in salary advances were paid in 2021. However, the contractual status of the permanent secretariat’s staff had not been regularised as of October 2023, with only gradual steps taken to address the irregularities. In 2021, the annual progress report explains that secretariat staff were provided with certificates of employment confirming each employee’s start date and attestations of their effective presence in their employment positions. The UGAP developed draft statutes and employment contracts for secretariat staff and a draft set of internal guidelines (règlement interieur) that were submitted to the Minister of Finance in 2021, although these were not enacted as of October 2023 even though the 2021 annual progress report states that the regularisation of the secretariat’s staff employment was close to finalisation. Many stakeholders consulted from all constituencies highlighted the main revision in the draft new EITI Decree was a more capable and efficient structure for the permanent secretariat, alongside more institutionalisation of government budget support for the EITI. The MSG’s comments on the draft Validation report highlighted the recent signature of all Cameroon EITI secretariat staff contracts (and provided copies of each contract) and the establishment of a working group within the Ministry of Finance to oversee the regularisation of staff contracts and settlement of salary arrears. Yet the International Secretariat considers that this reflects a dysfunction in the MSG’s oversight of a key aspect of the EITI process, particularly a properly operated and capacitated national secretariat.

The Secretariat’s assessment is that Requirement 3.1 is fully met, as in the previous Validation. The Secretariat’s view is that the objective of ensure public access to an overview of the extractive sector and its potential is fulfilled, given Cameroon’s use of its EITI reporting to provide an overview of the extractive industries on an annual basis, with some information on significant exploration activities. Consulted stakeholders did not express particular views on progress towards this objective. There are few systematic disclosures of information on the mining, oil and gas sectors, either on the MINMIDT or SNH websites. Cameroon’s 2021 EITI Report provides an overview of these sectors, including of the artisanal and semi-mechanised mining sectors as well as significant exploration activities in the year under review. Given that most of this information is not yet systematically disclosed, the assessment of Requirement 3.1 is not yet ‘exceeded’.

The Secretariat's assessment is that Requirement 6.3 is mostly met, which represents a regression since the previous Validation. The Secretariat’s view is that the objective of ensuring a public understanding of the extractive industries’ contribution to the national economy is mostly fulfilled, given Cameroon’s use of its EITI reporting to disclose comprehensive information on the macro-economic contribution of the extractive industries, including estimates of informal extractive activities, but the lack of attempt to disaggregate employment data by gender, company and occupation. Consulted stakeholders did not express particular views on progress towards the objective. There are limited systematic disclosures of information on the extractive industries’ contribution to the national economy. The sole form of disclosures consist of the National Statistics Institute’s (INS) annual report on national accounts, published on its website, which provides in absolute and relative terms the extractive industries’ contribution to GDP. Since September 2023, the INS website has also started republishing data from Cameroon EITI Reports in open format on the extractive industries’ contribution to the national economy, although this remains a means of improving the accessibility of Cameroon EITI data from PDF-format reports rather than a form of systematic disclosures. Cameroon’s 2021 EITI Report provides the extractive industries’ contribution, in absolute and relative terms, to GDP, government revenues, exports and employment, including estimates of the value of informal extractive activities (namely artisanal and semi-mechanised mining). An overview of the location of main extractive activities is also provided. The EITI Report provides extractive employment data only disaggregated between mining and petroleum, but not by company, occupation level or gender. Although the Secretariat’s understanding is that this more granular employment data is not currently collected by government entities, it considers that Cameroon EITI could have contributed to collecting such data from companies included in the scope of EITI reporting.

The Secretariat’s assessment is that Requirement 2.1 is fully met, as in the previous Validation. The Secretariat’s view is that the objective of ensuring public understanding of all aspects of the regulatory framework for the extractive industries is fulfilled, but not yet exceeded pending the systematic disclosure of information on the legal framework and fiscal regime, including significant ongoing and planned reforms, on relevant government websites. Consulted stakeholders did not express particular views about progress towards this objective. In oil and gas, the national oil company SNH’s website provides the full text of applicable laws and regulations in the sector (as well as the model production-sharing contract), in the absence of a Ministry of Petroleum in Cameroon. The 2021 EITI Report provides a more extensive overview of applicable laws and regulations, the roles and responsibilities of key government entities, the general fiscal regime and an outline of the main fiscal terms of oil and gas contracts, and the level of fiscal devolution related to oil and gas revenues. The report’s overview of recent reforms is restricted to a description of the implementing decree for the 2019 Petroleum Code. While there is scope for expanding the overview of ongoing and planned reforms, such as the impact of the CEMAC’s new foreign exchange regime on oil and gas contracts, Cameroon EITI’s 2021 annual progress report briefly describes this reform. In mining, the Ministry of Mines, Industry and Technological Development website systematically discloses some of the key laws and regulations related to the mining sector, alongside the full text of six active mining contracts. Cameroon’s 2021 EITI Report provides a more extensive overview of the applicable laws and regulations in the mining and quarrying sector, the fiscal regime, the key roles and responsibilities of state entities with oversight on mining and quarrying, as well as the level of fiscal devolution and subnational transfers of mining revenues. While the report’s overview of reforms in the mining and quarrying sector is cursory – covering only government reforms to collect more revenues from quarrying and the nomination of the members of the new mining SOE’s board of directors, the Secretariat considers that, on balance, there is a sufficient overview of mining and quarrying reforms.

The Secretariat’s assessment is that Requirement 2.4 is partly met. The Secretariat’s view is that the objective of ensuring the public accessibility of all licenses and contracts underpinning extractive activities is not fulfilled, given the lack of a clear government policy on the public disclosure of extractive contracts, the lack of publication of all mining, oil and gas contracts and licenses awarded and amended since January 2021, and the lack of a comprehensive inventory of all active extractive licenses and contracts (covering annexes, amendments and riders), identifying licenses and contracts not yet published. Most consulted stakeholders focused on the recent publication of mining contracts to argue that the objective was in the process of being fulfilled, although some CSOs raised concerns over the unclear path forward for the disclosure of oil and gas contracts. Many civil society stakeholders considered that there had been significant progress on contract disclosure, a priority for civil society (see Requirement 1.3). Several international partners highlighted the importance of oil and gas contract disclosure and noted the opportunity of a number of active contracts nearing expiry as an opportunity to remove confidentiality clauses in future production-sharing contracts (PSCs). While the 2018 Transparency Code provides a general framework for the public disclosure of extractive contracts and licenses, the 2021 EITI Report argues that the government’s policy regarding publication of extractive contracts remains unclear pending the issuance of an implementing decree for the Transparency Code. This statement was contested in stakeholder consultations, with most stakeholders consulted considering that the government’s policy was clear given the 2018 Transparency Code. The EITI Report also clarifies that confidentiality provisions of oil and gas contracts hinder their public disclosure (albeit without describing what these contractual confidentiality provisions cover – i.e. whether they cover the full text of the whole contracts or only specific terms – and only explains that SNH has undertaken extensive internal consultations on the issue of oil and gas contract disclosure, with the outcomes of these internal deliberations to be made public “in due course”. State officials reiterated that SNH had undertaken extensive internal reflexions and that it was expected to issue a statement in the coming months. While Cameroon EITI’s 2021 annual progress report briefly notes the December 2021 regional (CEMAC) directive requiring oil and gas companies to repatriate their rehabilitation provisioning to Cameroon from offshore, which has led to the renegotiation of oil and gas contracts in other countries and the removal of confidentiality provisions therein, the 2021 EITI Report does not discuss this reform nor its potential implications for the need for renegotiation or amendment of oil and gas contracts in Cameroon. In practice, the government has only publicly disclosed the full text of six mining contracts and seven mining licenses, including two mining contracts (with SINOSTEEL and CIMENCAM) that were awarded after January 2021. However, the annexes of some of these contracts (e.g. CIMENCAM’s contract) do not appear to have yet been publicly disclosed, even if the Secretariat understands that the CIMENCAM contract is no longer active. There was consensus among all stakeholders consulted that all active mining contracts had been published. The publication of the SINOSTEEL contract in particular prompted significant public debate and for the Minister of MINMIDT to present the terms of the contract to Parliament (see Requirement 7.1). However, given that at least 27 mining licenses were awarded in 2021 alone (as confirmed in the EITI Report), the Secretariat concludes that there are gaps in the public disclosure of mining licenses awarded since January 2021. None of the oil and gas licenses or contracts have yet been publicly disclosed by the government or companies. The SNH website has only published the template production sharing contract and a list of 3 concessions and 20 PSCs awarded up to July 2017 (there are currently 26 active oil and gas contracts as listed on the MINMIDT webpage for the petroleum register). Industry stakeholders consulted highlighted stabilisation clauses in their contracts that tended to be over ten years old and awarded under the 1999 Petroleum Code. Companies noted that all government agencies had access to the full text of the PSCs, just not the public, and that SNH was an effective negotiator to represent the country’s interests. While the government has published four mining contracts and licenses awarded prior to 2021, there remain a large number of extractive licenses and contracts awarded prior to 2021 that have not yet been published, as encouraged under Requirement 2.4.a. Cameroon EITI has not yet published a comprehensive list of all active mining, oil and gas licenses and contracts (covering annexes, amendments and riders) in accordance with Requirement 2.4.c.ii, indicating which contractual and license documents have been published and which have not, with specific references (hyperlinks) to facilitate access to each published document and identifying those documents yet to be published.

The Secretariat's assessment is that Requirement 6.4 remains not assessed, given that several encouraged aspects of this requirement remain to be addressed by Cameroon EITI. The Secretariat’s view is that the objective of providing a basis for stakeholders to assess the adequacy of the regulatory framework and monitoring efforts to manage the environmental impact of extractive industries is not fulfilled, given the scope for strengthening disclosures by Cameroon EITI or relevant government entities on practices related to environmental impact management as well as other environmental monitoring procedures, administrative and sanctioning processes of governments, as well as environmental liabilities. Consulted stakeholders from both government and civil society highlighted environmental impacts of mining as an issue of particular concern where they wanted the EITI to do more work on. Cameroon EITI significantly expanded its coverage of the management and monitoring of the environmental impact of the extractive industries in its 2021 EITI Report. The EITI Report provides an overview of the legal and regulatory framework for managing environmental impacts in both mining and petroleum, a cursory description of administrative procedures and an overview of practices related to oil and gas companies’ contributions to environmental rehabilitation. The PASIE project published a study in August 2020 on adherence to environmental standards in the mining sector in Cameroon, although this report does not appear to have informed Cameroon EITI’s work despite the fact it was produced partly by EITI staff. There is scope for significantly expanding Cameroon’s use of its EITI reporting to provide a diagnostic of rules and practices related to environmental management, including expanding its overview of practices beyond provisions for environmental rehabilitation and strengthening its disclosures of practices related to environmental monitoring, administrative and sanctioning processes, as well as managing environmental liabilities.

The Secretariat’s assessment is that Requirement 2.2 is mostly met, as in the previous Validation. The Secretariat’s view is that the objective of providing a public overview of the rules and practices of oil, gas and mining license awards and transfers is mostly fulfilled. Most consulted stakeholders did not express particular views on progress towards the objective. In oil and gas, there are no systematic disclosures on the licensing process by state entities or SNH. The 2021 EITI Report confirms the lack of awards or transfers of oil and gas rights in 2021 and lists three licenses that reached expiry in 2021. The report describes the statutory procedure for awarding oil and gas rights and transferring participating interests therein, confirming that all licenses are associated to contracts. However, the report only provides a list of documents required of applicants to demonstrate their technical and financial capacities, but does not describe how these documents are assessed (i.e. according to which criteria) aside from noting that no weighting is applied to the different documents. In consultations, the IA explained that there was no administrative procedure that described the criteria beyond the list of documents provided in the EITI Report, but the IA confirmed that no weighting was applied to the different documents as all had to be provided. The report includes a description of the expiry date of three oil and gas licenses in 2021 and their subsequent extension in 2023, but without providing an assessment of non-trivial deviations from statutory procedures in these license extensions (even if such disclosures are encouraged, not required, under the EITI Standard). In mining, there are few systematic disclosures on the MINMIDT website aside from a set of 2016 guidance for various administrative procedures including license applications. Cameroon’s 2021 EITI Report provides an overview of the statutory license award and transfer process. The report provides inconsistent information between its Section 3.2.2.4 and Annex 12 in terms of the number of license awards in 2021, with the former citing 27 awards and the latter listing 41 licenses awarded in 2021, without explanation for this apparent inconsistency. The IA noted that it would try to provide explanations of this apparent inconsistency. Mining licenses are awarded on a first-come-first-served basis, so there is no competitive tender. The report’s description of the technical and financial criteria assessed in mining license awards and transfers list the documents required of the applicant, but without explaining how these documents are assessed (i.e. the criteria for assessing an applicant’s technical and financial capacities). In consultations, both the IA and government officials explained that there was no administrative document that described the way in which the documents were assessed (i.e. the criteria), but confirmed that no weighting was applied for different documents as all had to be submitted. The government officials explained that the assessment of technical documents was clearly defined within the MINMIDT given that this assessment pre-dated the 2016 Mining Code, but that the lack of implementing decree for the 2016 Mining Code meant that MINMIDT personnel could not follow set procedures for assessing applicants’ technical capacities. The EITI Report provides two different views on whether there were any non-trivial deviations in licensing practices in 2021. The report presents the results of the IA’s review of a sample of 12 license awards and transfers, which indicate a number of deviations from statutory procedures in the review of applicants’ technical and financial criteria and the timeframe for awarding licenses. Yet at the same time, the report presents a letter from the MINMIDT stating that there were no non-trivial deviations from statutory procedures in the awards of mining licenses in 2021, without explaining the basis for this statement. The MINMIDT’s confirmation also covers oil and gas license awards, despite the lack of such awards in 2021. In consultations, national secretariat staff explained that the two conclusions (the MINMIDT letter and the IA’s work) were not necessarily inconsistent, since the MINMIDT statement was one of policy while the IA’s work was a more detailed technical review. In consultations, the IA explained that the deviations identified related primarily to licenses for artisanal and small-scale mining, and were due to archiving challenges that had led to document loss rather than deviations that implied a corruption risk. The IA considered these deviations to be marginal. Several government officials noted that the cadastre department’s digitisation efforts were ongoing, but that in the meantime applications for mining licenses were sent to the MINMIDT’s general post box rather than the cadastre department directly. However, they did not consider that the transit of mining license applications through the Minister’s office had any impact on either the efficiency of the system or respect of the first-come-first-served principle given that the Minister’s office never delayed or withheld applications. The officials explained that the cadastre department’s digitisation efforts would lead it to be fully independent operationally from the MINMIDT.

The Secretariat’s assessment is that Requirement 2.3 is mostly met, as in the previous Validation. The Secretariat’s view is that the objective of ensuring the public accessibility of comprehensive information on extractive industry property rights is mostly fulfilled, given that similar gaps in the public accessibility of license information (namely dates of application and coordinates for a minority of active licenses) remain outstanding since the previous Validation. Consulted stakeholders from government and industry considered the objective to have been fulfilled. In oil and gas, the MINMIDT website systematically discloses an overview of all active oil and gas rights, including information on the names of operators and partners (and level of participating interests of each company), dates of application and award for 14 of the 26 active oil and gas licenses and dates of expiry for all 26 of them, coordinates for 23 of the 26 active licenses (the coordinates for the Zina-Makary, Moudi and Dissoni Nord blocks are missing) and commodities covered by each license. Two of the three oil and gas blocks for whom coordinates are not disclosed (Moudi and Dissoni Nord) involve a material company (Perenco) included in the scope of reporting. Cameroon’s 2021 EITI Report provides a copy of this information, with the same gaps and without including the coordinates of active licenses. In consultations, SOE and state officials explained that gaps in the provision of dates for any licenses was due to loss of the government decrees awarding those licenses. However, while most of the technical aspects of Requirement 2.3 are met in the oil and gas sector, the Secretariat considers that the lack of coordinates for three active oil and gas licenses is a material gap that hinders broader transparency on property rights in the oil and gas sector, given that the local of oil and gas rights is a key aspect of property rights. In mining, the MINMIDT’s cadastral portal systematically discloses all information on active mining licenses as listed in Requirement 2.3.b, aside from dates of application for certain mining licenses. The 2021 EITI Report provides an overview of the public accessibility of license information, noting only that dates of application are not available for "certain" mining licenses without providing the list of active mining licenses for which this information is not publicly accessible. In consultations, government officials and secretariat staff explained that all of the dates of application of all available government decrees had been scraped, but that the few licenses for which dates of application were missing was due to weaknesses in archiving of older documents.

The Secretariat’s assessment is that Requirement 2.5 is partly met. The Secretariat’s view is that the objective of enabling the public to know who ultimately owns and controls the companies operating in the country’s extractive industries is still far from being fulfilled, despite encouraging recent reforms including the 2023 Budget Law requiring companies in all sectors to report their beneficial owners to the tax department (DGI). While recent efforts by Cameroon EITI to collect beneficial ownership information from all extractive companies is welcome, it has proved unsuccessful to date. Consulted stakeholders from all constituencies considered that the objective was in the process of being fulfilled, arguing that the legal framework was broadly in place and that data collection by the tax department (DGI) had already started in earnest. The MSG’s comments on the draft Validation report argue for an upgrade in the assessment of Requirement 2.5, given the establishment of an enabling legal and regulatory framework for the collection of beneficial ownership data and legal provisions for transparency institutions such as the EITI to access this data for their purposes. The detailed civil society comments on the draft Validation report confirm that the plan is to ensure the public accessibility of the planned beneficial ownership register. The International Secretariat acknowledges the importance of these efforts, but considers that the lack of clear legal provisions ensuring the free public accessibility of all such beneficial ownership information, combined with the lack of collection of such ownership data on all companies holding and applying for extractive rights, implies that the objective is still far from being fulfilled. However, continued progress building on the recent reforms could support Cameroon’s swift progress in improving transparency in beneficial ownership in the extractive industries. The government has codified its policy on the public disclosure of beneficial owners of extractive companies in the 2018 Transparency Code, although the lack of implementing decree for this code to date has meant that the government’s policy is not operational, in the same way as its contract disclosure policy (and as noted in the 2021 EITI Report). Likewise, the 2016 Mining Code introduced a beneficial ownership disclosure threshold of 5%, but there has been no implementing decree for this code to date meaning this provision has not been implemented. The government now intends to revise the 2016 Mining Code. Cameroon’s 2021 EITI Report confirms that an enabling legal and regulatory environment for the collection and public disclosure of beneficial ownership of extractive companies has not yet been established. The 2023 Budget Law introduced a requirement for companies in all economic sectors to report their beneficial ownership to the Tax Department (DGI), but not to publicly disclose this information. On 27 September 2023, the Prime Minister issued Decree 2023/06801/CAB/PM as the implementing decree for the provisions of the 2023 Budget Law related to the collection of beneficial ownership information from all companies. In consultation, government officials explained that the intention was for the DGI to build a database of beneficial ownership data from all companies and to transfer it to the business register (RCCM) once its ongoing digitisation effort had been completed. The officials argued that this implied that this beneficial ownership information would be published by the RCCM, even though there were no legal provisions for the public disclosure of beneficial ownership data beyond the provisions of the 2018 Transparency Code that had not yet been implemented through decree. The government officials explained that the DGI had already collected the company statutes of 70% of companies registered with the DGI, which included information on the companies’ legal owners. The MSG’s comments on the draft Validation report argue that the September 2023 decree implementing legal provisions on beneficial ownership transparency includes provisions for transparency institutions like Cameroon EITI to access beneficial ownership data collected by the DGI for their own purposes. While this implies that Cameroon EITI may be able to publish this beneficial ownership data in due course without the need for further legal reforms, the lack of explicit legal or regulatory provisions to ensure the free public accessibility of all such data is a concern. The International Secretariat acknowledges the personal data privacy constraints, but emphasises the need to publish at least basic information on beneficial owners in accordance with Requirement 2.5.d, i.e. beneficial owner name, nationality, country of residence, status as politically exposed person and share of control of the company. In the absence of an enabling regulatory environment for both collection and public disclosure of beneficial ownership data, the MSG has piloted beneficial ownership reporting and agreed definitions of ‘beneficial owner’ and ‘politically exposed person’ (PEP) for EITI reporting purposes. It agreed a materiality threshold of 5% of a company’s ownership or control for disclosure of beneficial owners, although there is no indication that the MSG agreed to disclose PEP ownership of extractive companies without any materiality threshold. However, several government officials consulted called for greater clarity on the scope of PEPs in the Cameroonian context, given that the Constitution only referred to the President, Prime Minister and members of the government, but it was not necessarily clear whether the senior management of government entities were also covered by this definition. The MSG’s comments on the draft Validation report argue that the list of individual categorised as PEPs is clearly defined in the Constitution of Cameroon. For the first time as part of preparations of the 2021 EITI Report, Cameroon EITI sent beneficial ownership reporting templates to all companies holding mining, oil and gas rights. This effort has not yet extended to integrating beneficial ownership reporting as part of the licensing process in order to cover beneficial ownership disclosure from companies that apply, unsuccessfully, for extractive rights. The IA explained that the MINMIDT requested the company’s statutes as part of the licensing process, but that company statutes only contained the beneficial owners of those companies at incorporation, not updated for any subsequent changes. These laudable efforts of beneficial ownership data collection by Cameroon EITI have largely proved unsuccessful to date however, with only a one oil and gas company and six mining companies disclosing their beneficial ownership information, wPith 11 oil and gas companies and 16 mining companies reporting their shareholders (legal owners), while 54 mining companies and one oil company did not report anything on their legal or beneficial ownership (Annexes 10-1 and 10-2 of the 2021 EITI Report). The annexes provide only one oil and gas companies and two mining companies’ disclosures of a link to statutory reporting to the stock exchange regulator where their mother company is publicly listed. Several government officials consulted considered that this level of beneficial ownership reporting was already a significant achievement and expressed confidence that the level of company reporting would increase in future years. Several company representatives considered that beneficial ownership was still a new concept for many companies, which explained why the company reporting rate was not yet higher. The MSG has published an assessment of Cameroon EITI’s efforts to collect beneficial ownership data in the 2021 EITI Report. Yet the company register – the Registre du Commerce et du Crédit Mobilier (RCCM) – provides reportedly only on-demand shareholder information and there is no evidence that Cameroon EITI has sought to access shareholder (legal ownership) information on all extractive companies from the RCCM to provide a diagnostic of the availability of legal ownership information. State officials explained that the RCCM was currently digitising its company register, which was expected to enable online access to shareholder information on all companies, but did not provide a timeframe for completion of this important reform.

The Secretariat's assessment is that Requirement 2.6 is mostly met, which represents a regression from the previous Validation. The Secretariat’s view is that the objective of ensuring an effective mechanism for transparency and accountability for well-governed SOEs and state participation is mostly fulfilled. While most of the technical aspects of Requirement 2.6 are publicly addressed in the oil and gas sector, the Secretariat’s view is that the objective is only mostly fulfilled given the perfunctory nature of SNH disclosures (e.g. of its audited financial statements), the continued lack of clarity on the decision-making in directing SNH to undertake certain expenditures on behalf of the state (and not others), and the concerns over corporate governance of the national oil company (and the national refinery company) raised by the Glencore affair. Consulted government stakeholders considered that this objective had been fulfilled with the strengthening of SNH’s systematic disclosures, with some stakeholders explaining that the mining SOE was just being established as an explanation for the lack of comprehensive coverage of SONAMINES’ financial relations with the state in the latest EITI Report. In oil and gas, the national oil company SNH has made improvements in its systematic disclosures of data on its production, exports and succinct summaries of its financials, as well as publication for the first time the full text of the audited financial statements of its two entities – SNH-Mandat (on behalf of the state) and SNH-Fonctionnement (a commercial entity) – for 2021 only, in the weeks leading up to this Validation. In consultations, government officials confirmed that the intention was for SNH to publish its complete financial statements annually, and that the 2022 financial statements would be published as soon as the SNH-Mandat statements received final approval. However, the Secretariat considers that it should also have been possible to publish the audited financial statements of the two SNH entities for years prior to 2021. Several CSOs consulted highlighted the publication of SNH’s full financial statements as a significant impact of the EITI process. Some state officials consulted noted that the Chamber of Accounts had launched an audit of SNH as a SOE in 2023, which was entirely separate from the annual audit of SNH’s financial statements. Cameroon’s 2021 EITI Report confirms that SNH is the only material SOE for EITI reporting purposes and justifies the exclusion of SONARA as a midstream SOE. The report describes the rules related to SNH’s distribution of profits, retained earnings, reinvestments, but not of third-party financing. However, the statutes of SNH confirm SNH as a company 100% owned by the state, implying that it cannot seek third-party equity finance. In consultations, the IA confirmed that SNH was statutorily entitled to raise third-party debt financing (e.g. through bank loans) but that it usually did not resort to this given that its Treasury usually had ample funds to finance its operations. The EITI Report describes the practices of SNH’s dividends and retained earnings in 2021, but not of its reinvestments or third-party (debt) financing. However, the 2021 audited financial statements of both SNH-Mandat and SNH-Fonctionnement published in September 2023 provide the required data on SNH’s reinvestments and third-party (debt) financing in 2021. Cameroon’s EITI reporting has listed the state and SNH’s equity interests in upstream companies and projects, including the terms for all but its equity interests in upstream oil and gas companies. Nonetheless, in consultations the IA confirmed that SNH’s equity interests in upstream oil and gas companies is full-paid equity. Cameroon has started expanding its EITI reporting to providing a succinct overview of the rules related to corporate governance and links to the composition of SNH’s board of directors and organigramme, but this has not yet expanded to a more detailed diagnostic of SNH’s corporate governance, particularly with longstanding leaders in the company. In mining, without systematic disclosures of information on mining SOEs, Cameroon EITI has provided the most extensive information on SOEs like recently (2020) created SONAMINES, even if there remain gaps in its coverage of the rules and practices of SONAMINES’ financial relations with the state. The 2021 EITI Report remains ambiguous on the materiality of mining SOEs in the year under review, although the International Secretariat considers that newly established SONAMINES was a material entity in 2021 given its taking over the responsibility from the CAPAM to collect state revenues in kind from semi-mechanised gold miners as of the second quarter of 2021. In consultations, the IA explained that SONAMINES started collecting ‘synthetic tax’ from artisanal miners in mid-2021, but that aside from this it did not have any operations in 2021. Nonetheless, the IA concurred that SONAMINES’ collection of material revenues on behalf of the government in the second half of 2021 would qualify it as a material mining SOE for EITI reporting. The EITI Report does not clearly categorise the state asset manager SNI (Société Nationale d'Investissement) as a SOE, and the Secretariat does not consider it a SOE given that it remains a passive investor with only a 40% equity interest in CAMIRON. The report does not explain the rules and practices of the financial relations between SONAMINES and the state, although it does list the state’s equity in mining companies and the terms attached to each equity interest. The report does not comment on the reasons for the lack of accessibility of SONAMINES’ audited financial statements, as expected under Requirement 2.6.b, nor the rules and practices related to its corporate governance aside from listing the members of its board of directors. In consultations, the IA and state officials explained that the IA had requested copies of SONAMINES’ audited financial statements for 2021 but that it had not received them. There are opportunities to significantly strengthen Cameroon’s use of EITI reporting as a diagnostic of the rules and practices related to SOEs in the mining sector.

The Secretariat's assessment is that Requirement 4.2 is fully met, as in the previous Validation. The Secretariat’s view is that the objective of ensuring transparency in the sale of in-kind revenues of minerals, oil and gas is fulfilled, given Cameroon’s use of its EITI disclosures to build on the more aggregated systematic disclosures on the sale of the state’s in-kind oil and gas revenues on the SNH website. Consulted stakeholders from government broadly considered that the objective had been fulfilled, while representatives from other constituencies did not express particular views on the issue. However, several CSOs called for more transparency on oil sales in response to the corruption allegations involved in the Glencore affair. In oil and gas, the SNH website systematically discloses annually data on the state’s in-kind crude oil revenues per project and by quarter, SNH’s aggregate sales of crude oil, natural gas and liquefied petroleum gas (LPG), although this data is only disaggregated by buyer for natural gas and LPG, not for crude oil sales. SNH’s disclosures only cover oil volumes, not values. In consultations, SOE officials explained that it should theoretically be possible for SNH to systematically disclose data on sales of the state’s in-kind oil and gas revenues at cargo level, given that this data was already being provided to and disclosed by Cameroon EITI. Cameroon’s EITI Reports have built on these systematic disclosures to provide granular cargo-level data for the sale of the state’s in-kind revenues of crude oil, natural gas, LPG and liquefied natural gas (LNG), although the report clarifies that in the case of LNG and LPG, it is the operator that sells the state’s share on its behalf, transferring the proceeds to SNH-Mandat. Cameroon’s 2021 EITI Report provides additional detail on SNH’s subsidiary TRADEX’s trading of crude oil. While Cameroon has gradually expanded its EITI disclosures on commodity sales, it has yet to disclose additional information on the rules and practices related to the buyer selection process, information of high relevance to the vibrant public debate on the Glencore affair. In consultations, state officials explained that SNH no longer sold crude oil on the basis of term contracts since 2019, and had transitioned to a system of only spot sales through competitive tender since then. In mining, Cameroon’s 2021 EITI Report provides detailed information on in-kind payments of gold by artisanal and semi-mechanised miners to the state, which consist of three revenue streams (corporate income tax, the state’s share of production and ad valorem tax) combined and paid as one ‘synthetic tax’ (‘impôt synthétique’). The revenue was collected by CAPAM until end of Q1 2021 and SONAMINES from Q2 2021 onwards according to the EITI Report, and subsequently transferred as gold lingots to the Treasury. Consultations with state officials however revealed that CAPAM collected ‘synthetic tax’ until June 2021, while SONAMINES took over from July 2021. While the Treasury is meant to sell the gold in order to partly fund subnational transfers (see Requirement 5.2), it has only started commercialising the gold since 2023. The EITI Report provides the volumes of in-kind revenues collected by CAPAM/SONAMINES and the volumes transferred to the Treasury, as well as the estimated value of gold shipments. While the data on in-kind gold volumes collected is only disclosed as one ‘synthetic tax’, in consultations the IA confirmed that it was methodologically sound to divide the gold volumes by the statutory shares of each of the three revenue streams within ‘synthetic tax’. Thus, the Secretariat considers that the lack of disaggregation of ‘synthetic tax’ in-kind revenues by individual revenue stream does not constitute a material gap in progress towards the objective of transparency in the state’s in-kind gold revenues.

The Secretariat's assessment is that Requirement 4.5 is mostly met, which represents a regression from the previous Validation. The Secretariat’s view is that the objective of ensuring the traceability of payments and transfers involving SOEs is mostly fulfilled, given weaknesses in disclosures of transactions related to SOEs in the mining sector. Consulted stakeholders did not express particular views on whether the objective had been fulfilled. In oil and gas, Cameroon’s 2021 EITI Report comprehensively discloses and reconciles oil and gas companies’ payments to SNH-Mandat and SNH-Fonctionnement, including five revenue streams collected in cash and three revenue streams collected in-kind. The report also discloses and reconciled SNH-Mandat and SNH-Fonctionnement’s transfers to the state (e.g. dividends) and provides unilateral disclosure of SNH-Mandat’s transfers to other government entities on behalf of the state, in the form of SNH’s ‘direct interventions’. These ‘direct interventions’ are not reconciled with disclosures from the beneficiary government entities given that they are outside of the scope of reconciliation (being non-extractive government entities), but are compared with disclosures from the Treasury. The report also confirms the lack of financial transfers from the state to SNH in the period under review. In mining, the 2021 EITI Report discloses information on the new mining SOE SONAMINES’ collection of revenues in-kind from artisanal and semi-mechanised miners on behalf of the state in the form of the ‘synthetic tax’, including unilateral reporting of the volumes collected in aggregate, not disaggregated by individual artisanal and semi-mechanised miner (see Requirement 4.2). The report also provides unilateral disclosures on SONAMINES’ transfers of physical gold collected as ‘synthetic tax’ to the Treasury, although these transfers are not reconciled despite being considered material. The report does not comment on the existence of any financial transfers from the state to SONAMINES in 2021, which presents a material gap in the Secretariat’s opinion given the lack of clarity around how the new mining SOE financed its operating expenditures in 2021 (see Requirement 2.6). There are not yet systematic disclosures of transactions involving SOEs either in the mining or petroleum sectors, aside from the recent disclosure of the full set of SNH’s audited financial statements for 2021 that provide information on transactions related to the national oil company’s two legal entities, SNH-Mandat and SNH-Fonctionnement.

The Secretariat's assessment is that Requirement 6.2 is mostly met, as in the previous Validation. The Secretariat’s view is that the objective of transparency in extractive-funded quasi-fiscal expenditures to ensure accountability in their management is mostly fulfilled, given that the previous Validation’s corrective action to disaggregate SNH’s ‘direct interventions’ by budget code remains outstanding and would be needed to ensure that transparency on these ‘direct interventions’ is commensurate with that of conventional budgetary expenditures. While the MSG and IA do not consider that Requirement 6.2 is applicable to Cameroon in 2021 based on its view that extractive SOEs did not undertake any quasi-fiscal expenditures in 2021, the Secretariat considers that there are at least two types of activities by the national oil company SNH that are not aligned with conventional budgetary discipline but cover expenditures that would normally be considered the preserve of the state (i.e. national security spending and de facto subsidies to the national refinery) and should thus be considered forms of quasi-fiscal expenditures. Consulted government stakeholders confirmed their view that the objective of this requirement was not applicable to Cameroon in the period under review. In consultations, the IA considered that SNH’s ‘direct interventions’ were in between conventional budgetary expenditures and quasi-fiscal expenditures. There are limited systematic disclosures of information on extractive SOEs’ quasi-fiscal expenditures by government entities, beyond the publication of the 2021 audited financial statements of SNH-Mandat, which provide the aggregate value of SNH’s ‘direct interventions’ for 2021. While the government’s TOFE includes a line on aggregate ‘direct interventions’ by SNH, the TOFE does not appear to be routinely published online. Cameroon’s 2021 EITI Report confirms the lack of quasi-fiscal expenditures undertaken by mining SOEs in 2021. The EITI Report documents the MSG’s view that SNH’s ‘direct interventions’ on national security on behalf of the state are not forms of quasi-fiscal expenditures. This argument is based on the fact that all national security expenditures are included in the annual national budget law and that all SNH ‘direct interventions’ are regularised ex post in the TOFE and budget execution law, through the reconciliation of these SNH expenditures with Treasury and Ministry of Finance accounts. The International Secretariat’s view is that SNH’s ‘direct interventions’ are undertaken outside of the conventional budget and expenditure cycle, in line with the categorisation of these expenditures in Cameroon’s 2018 letter of intent in the context of its request for an extended credit facility from the IMF. While the aggregate value of SNH’s ‘direct interventions’ is reflected in the government’s TOFE and budget execution law, the Secretariat considers that there remains a lack of transparency on the decision-making involved in directing SNH to cover certain types of budgeted national security expenditures and not others. Indeed, significant fluctuations in the value of ‘direct interventions’ to specific beneficiaries and the identity of beneficiaries since Cameroon’s EITI reporting has provided this data (i.e. since the 2018 EITI Report) imply that there is significant discretion in the types of national security expenditures covered by SNH on an annual basis. In addition, the fact that a share of national security expenditures are funded through accounts other than the single Treasury account weakens ex-ante parliamentary oversight of these expenditures. Finally, the ex-post regularisation of SNH’s ‘direct interventions’ in the TOFE and budget execution report weakens the oversight of the supreme audit institution, the Chamber of Accounts (‘Chambre des comptes’), given the lack of communications between the Chamber of Accounts and the Superior State Council (‘Conseil Superieur de l’Etat’ – CONSUPE), which is tasked with auditing decision-making on public expenditures, including on SNHG’s ‘direct interventions’. The CONSUPE does not publish its audit reports and is answerable only to the Presidency, which has direct oversight of the national oil company SNH. In consultations, several government officials confirmed that SNH was directed to undertake ‘direct interventions’ but that it then provided receipts of these expenditures to the Budget Department, for them to reconcile these items with budgeted expenditures and allocate a budget code to each. However, government officials and development partners explained that there were always a number of SNH ‘direct interventions’ that were categorised as “expenditures to regularise” in the budget execution report at the end of the year. Some development partners also highlighted the risk that SNH’s ‘direct interventions’ displaced other budgeted expenditures, given that it diverted state revenues from the Treasury. Nevertheless, the 2021 EITI Report is based on dedicated reporting templates sent to SNH and the Treasury (DGTCFM) developed for the reporting of SNH’s ‘direct interventions’. The EITI Report provides the value of these ‘direct interventions’ in 2021 disaggregated by each of the 11 beneficiary government entities, providing only a very succinct description of the purpose of transfers (e.g. ‘national security’). However, while the previous Validation’s corrective action required Cameroon EITI to present data on SNH’s ‘direct interventions’ for each beneficiary disaggregated between the two budget codes for these interventions directed to national security (i.e. Account 2279 in the “Investment” line (covering “material, machinery, installations, technology and operational services”) and Account 6189 in the “operations” line (covering “other external payment services”)), the 2021 EITI Report does not present this data to these required levels of disaggregation. Rather, it refers to most expenditures as being linked generally to “national security” without specification of the budget code. State officials explained that SNH would not know under which budget code these expenditures would be categorised, but that the Budget Department would be able to provide this information. Other state officials explained that the Budget Department could only provide the budget code for those ‘direct interventions’ that were not categorised as “expenditures to regularise” at the end of the year. Thus, the Secretariat continues to consider that the level of transparency in disclosures of SNH’s ‘direct interventions’ either by SNH or the national budget is not yet commensurate with other payments and revenue streams that transit through the single Treasury account. The 2021 EITI Report also documents the MSG’s view that the state-owned oil refinery SONARA’s outstanding debt for payment of crude oil supplies from SNH – worth a total of XAF 28.3bn (around USD 45.6m) in 2021 – does not constitute a form of quasi-fiscal expenditures. This argument is based on the view that these remain outstanding arrears in payment rather than a form of subsidy, given that SNH intends to be repaid for this debt, which is still carried in its balance sheet. The EITI Report provides calculations of the additional interest due on the XAF 28.3bn in principle due, estimated at an additional XAF 16.3bn (around USD 26.2m), bringing the total due by SONARA to SNH to XAF 44.6bn (around USD 71.8m) in 2021. In consultations, the IA argued that the inclusion of additional interest owed on the original debt demonstrates that this outstanding debt does not constitute a form of quasi-fiscal expenditures, since interest owed was calculated based on prevailing market rates. The EITI Report explains that SONARA has formally requested from the Ministry of Finance that this outstanding debt be forgiven, although this request is still in process of being considered. In consultations, the IA considered that this outstanding debt would become a form of quasi-fiscal expenditure only if and when the Ministry of Finance writes off this debt, which could potentially then be counted as a loss for SNH. While the International Secretariat considers the calculations of outstanding interest owed on the original SONARA debt to SNH to be robust, it maintains its view that this outstanding debt represents a de facto subsidy to SONARA by SNH pending the regularisation of this outstanding debt. Finally, the EITI Report describes two other SNH activities that it explicitly considers do not constitute forms of quasi-fiscal expenditures. The first consists of SNH-Mandat’s retention of state revenues to cover the costs associated with the state’s participation in oil and gas projects. The second consists of confirmation that the pricing of SNH’s crude oil sales was aligned with international prices. The Secretariat agrees with the MSG’s view that neither of these constitute forms of quasi-fiscal expenditures.

The Secretariat’s assessment is that Requirement 3.2 is fully met, as in the previous Validation. The Secretariat’s view is that the objective of ensuring public understanding of extractive commodities production levels and their valuation is fulfilled, given Cameroon’s use of its EITI reporting to provide information on oil, gas and mineral production, including estimates of artisanal and semi-mechanised mining production. Consulted stakeholders did not express any views on progress towards this objective. In oil and gas, the national oil company SNH’s website systematically discloses on an annual basis information on monthly production volumes and values of crude oil and natural gas production, albeit without disaggregating crude oil from oil condensate production. This information is broken down by individual producing oil and gas project. Cameroon’s 2021 EITI Report republishes this information, albeit without adding value by describing the methodology for tracking and calculating production volumes and values. While crude oil and oil condensate production values are not presented disaggregated by specific commodity, there is sufficient information in the EITI Report to estimate production values for each separately. In mining, there are no systematic disclosures of mineral production data at present, either on the MINMIDT website or elsewhere. The 2021 EITI Report provides mineral production volumes and values for gold (including from semi-mechanised gold production), diamonds, and six of the seven types of quarrying materials (used for construction), with only production values for ‘moellons’ (rubble) missing from the EITI Report. The Secretariat considers this to be a gap of marginal importance, given that none of the material companies included in the scope of reporting produced this quarrying commodity in 2021 and that the value of this commodity is low.

The Secretariat’s assessment is that Requirement 3.3 is fully met, as in the previous Validation. The Secretariat’s view is that the objective of ensuring public understanding of extractive commodities export levels and the valuation is fulfilled, given SNH’s systematic disclosures of oil and gas export data as well as Cameroon’s use of its EITI reporting to clarify mining exports. Consulted stakeholders did not express any views on progress towards this objective. In oil and gas, the SNH website systematically discloses on an annual basis crude oil and natural gas monthly export volumes and values, disaggregated by project. While crude oil and oil condensate exports are not presented in a disaggregated manner, the Secretariat’s view is that this is a marginal gap given that both are exported in the form of crude oil. Cameroon’s 2021 EITI Report republishes this information, albeit without adding value by describing the methodology for tracking and calculating export volumes and values. In mining, there are no systematic disclosures of mineral export data aside from diamond export data published through the Kimberley Process. The 2021 EITI Report provides mineral export volumes and values for gold and diamonds, the two mineral commodities exported, covering mineral smuggling and seizures of illegal gold exports. This is a welcome practice that could be expanded to include more third-party estimates of other extractive commodities smuggling, such as gold. There is no further information on the methodologies for tracking and calculating export volumes and values.

The Secretariat's assessment is that Requirement 4.1 is fully met, as in the previous Validation. The Secretariat’s view is that the objective of ensuring comprehensive disclosures of company payments and government revenues from oil, gas and mining is fulfilled, given Cameroon’s use of its EITI reporting to comprehensively disclose material company payments and government revenues from the extractive industries. Consulted stakeholders from all constituencies broadly considered this objective to have been fulfilled through EITI reporting. There are no systematic disclosures of government revenues from the extractive industries in Cameroon at present, although the Secretariat’s understanding of planned reforms to the single Treasury account backed by the IMF is that they involve plans to systematically disclose extractive industry revenues by revenue flow in the government’s financial management dashboard and budget in future. Cameroon’s 2021 EITI Report describes the MSG’s approach to agreeing the scope of EITI reporting, with its materiality decisions related to revenue streams, government entities and extractive companies considered reasonable. While the target reconciliation coverage remains around 50% of government revenues from the mining sector, the mining sector’s low contribution to government revenues means that Cameroon’s 2021 EITI Report still covered over 99.9% of government revenues from the mining and petroleum sectors combined. In consultations, the IA expressed confidence that all material company payments and government revenues had been comprehensively and reliably reconciled in the 2021 EITI Report. All material extractive companies and government entities duly reported for the 2021 EITI Report, which contains a statement from the IA that the reconciliation of material payments and revenues was considered comprehensive. In addition, government entities provided full unilateral disclosure of total government revenues, including from companies below the materiality threshold. Going beyond the minimum EITI Requirement, Cameroon has piloted the public disclosure of oil and gas company costs in the 2021 EITI Report for the first time, making progress towards new aspects of the 2023 EITI Standard (Requirement 4.10). While there is no explanation for the lack of public disclosures of extractive companies’ audited financial statements, as expected under Requirement 4.1.e, the Secretariat considers that, on balance, all required technical aspects of Requirement 4.1 have been addressed.

The Secretariat's assessment is that Requirement 4.3 remains not applicable, as in the previous Validation. The Secretariat’s view is that the objective of ensuring public understanding of infrastructure provisions and barter-type arrangements does not apply in Cameroon during the period under review. The 2021 EITI Report confirms that there are no active barter-type infrastructure arrangements in Cameroon in 2021. While the MSG’s own Transparency template asked for clarification around the status of the agreement to supply natural gas from the Logbaba field to industrial customers in Douala, the Secretariat’s view is that this appears to consist of a sale of natural gas rather than the settlement of a payment to government in-kind. None of the stakeholders consulted expressed any views on progress towards this objective, although the Secretariat concludes that it is not applicable to Cameroon in the period under review.

The Secretariat's assessment is that Requirement 4.4 is fully met, as in the previous Validation. The Secretariat’s view is that the objective of ensuring transparency in government and SOE revenues from the transit of oil, gas and minerals is fulfilled, given Cameroon’s long-standing use of its EITI reporting to disclose comprehensive information on the Chad-Cameroon pipeline and transit fees. Consulted stakeholders did not express particular views on progress towards this objective. In the absence of systematic disclosures of information on the Chad-Cameroon pipeline transit fees to the government, Cameroon EITI has sustained its long-established annual disclosures of information on the pipeline company COTCO’s payments to government, disaggregated by revenue stream. Cameroon has not used its EITI reporting published in 2023 to comment on the changes in the composition of the pipeline consortium following ExxonMobil’s exit from Chad in 2023. Moreover there is no evidence that Cameroon EITI has discussed the implications of the change in operatorship of Chad’s Doba project and change in ownership of the Chad-Cameroon pipeline on Cameroon’s transit revenue prospects.

The Secretariat's assessment is that Requirement 4.7 is fully met. The Secretariat’s view is that the objective of ensuring disaggregation in public disclosures of company payments and government revenues from oil, gas and mining is fulfilled, in spite of minor gaps in project-level disclosures of relevant government revenues (less than 0.1% of relevant revenues). Most consulted stakeholders did not express particular views on progress towards this objective, although the IA considered that the objective had been broadly fulfilled given that only six material company payments to government were not disaggregated at a project level despite being levied as such. Cameroon’s 2021 EITI Report presents reconciled financial data on government revenues disaggregated by government entity, revenue stream, company and, for most applicable revenue streams, by individual project. The report describes the MSG’s agreement on a definition of project for EITI reporting purposes that is aligned with the definition in Requirement 4.7, scopes out the specific revenue streams that are levied at a project level, and confirms the lack of projects that cover several substantially interconnected agreements (e.g. licenses or contracts). The MSG’s definition of project consists of individual contracts or licenses. While the majority of government revenues that are levied at a project level are disclosed by project, six material payment streams (one from SNH and five from the two material mining companies) were not disclosed disaggregated by individual project. In consultations, the IA explained that this gap was due to the lack of reporting of certain relevant payment streams by project by the three material companies. These six payments to government account for only 0.03% of total government revenues from the mining and petroleum sectors in 2021. Thus, the Secretariat considers that the objective of project-level disaggregation of all applicable government revenues has been fulfilled.

The Secretariat's assessment is that Requirement 4.8 is fully met. The Secretariat’s view is that the objective of ensuring that public disclosures of government revenues from oil, gas and mining are sufficiently timely to be relevant to inform public debate and policy making is fulfilled on balance, despite delays in production of previous EITI Reports. Consulted stakeholders from all constituencies expressed pride at the number of EITI Reports published in the last three years and broadly considered that the objective was achieved. Cameroon published its 2018 EITI Report in June 2021, its 2019 EITI Report in November 2021, its 2020 EITI Report in December 2022 and its 2021 EITI Report in October 2023. The delays in publication of the 2018 EITI Report led to the temporary suspension of Cameroon by the EITI Board right after the conclusion of its previous Validation in April 2021, although the suspension was lifted once the report was published in June 2021. Notwithstanding this delay in publishing the 2018 EITI Report, the subsequent EITI Reports have been published within the two-year timeframe dictated by Requirement 4.8. The 2021 EITI Report confirms the MSG’s approval of the reporting period. The MSG has general plans to improve the timeliness of its EITI disclosures by strengthening systematic disclosures, as reflected in the 2023-2025 Cameroon EITI work plan, and a review of systematic disclosures is ongoing by the IA for the 2020 and 2021 EITI Reports as of the fourth quarter of 2023.

The Secretariat's assessment is that Requirement 4.9 is fully met, as in the previous Validation. The Secretariat’s view is that the objective of the EITI contributing to strengthening routine government and company audit and assurance systems and practices and ensuring that stakeholders can have confidence in the reliability of the financial data on payments and revenues is fulfilled, given Cameroon’s EITI Report’s robust methodology for data quality and assurances that were followed by all reporting entities. Consulted stakeholders from all constituencies considered that the objective was met and that the financial data in EITI Reports was reliable. The only systematic disclosures related to data quality and assurances in Cameroon consist of the Chambre of Accounts (‘Chambre des comptes’) website, although it only discloses audits of government accounts up to and including 2020, as well as the SNH website that has published the national oil company’s full audited financial statements and audit report for the first time in 2021. Cameroon’s 2021 EITI Report appears to be based on a robust methodology for data quality and assurances. There is evidence that the MSG approved the quality assurances for EITI reporting by both material companies and government entities, and an overview of statutory audit procedures is provided in the EITI Report, even if the review of audit practices could be significantly strengthened. Indeed, government officials consulted explained that the Chambre of Accounts was undertaking a financial audit of government revenues starting only with the 2022 government accounts, as it had not audited government revenues in the past. This is not described in the 2021 EITI Report. In addition, the EITI Report does not comment on the split in responsibilities between the two institutions that act as supreme audit institutions, i.e. the Chamber of Accounts and the Superior State Council (Conseil Supérieur de l’Etat – CONSUPE). The quality assurances agreed for EITI reporting explicitly reference the reporting entity’s audited financial statements for the year under review. All material companies and government entities duly provide the required quality assurances, which enabled the IA to provide a statement in the EITI Report confirming the comprehensiveness and reliability of the reconciled financial data on company payments and government revenues. There is scope for strengthening Cameroon’s use of its EITI reporting to provide a diagnostic of broader company and government audit and assurance practices, and to formulate recommendations for reform that could further strengthen these prevailing audit and assurance practices.

The Secretariat's assessment is that Requirement 5.1 is mostly met, as in the previous Validation. The Secretariat’s view is that the objective of ensuring the traceability of extractive revenues to the national budget and ensuring the same level of transparency and accountability for extractive revenues that are not recorded in the national budget is mostly fulfilled, given Cameroon’s efforts to improve transparency on extractive revenues not transferred to the single Treasury account, even if more granular information on these revenues backed by publicly accessible financial reports is still pending. There are only limited systematic disclosures on the distribution of the government’s extractive industry revenues in Cameroon. The Ministry of Finance website publishes the annual budget law but does not appear to routinely publish the state’s financial operations dashboard (‘Tableau des Opérations Financières de l'Etat’ – TOFE). The Secretariat’s understanding is that the TOFE includes a specific line to cover SNH’s ‘direct interventions’ on behalf of the state, but not for other extractive revenues that are not transferred to the single Treasury account. Cameroon’s 2021 EITI Report lists the extractive revenues that are not recorded in the national budget, including four types of government revenues: (i) the share of proceeds from the sale of the state’s in-kind revenues withheld to cover costs associated with the state’s interests in oil and gas projects, (ii) bonus and royalty collected by SNH-Mandat, (iii) professional training contributions collected by SNH-Mandat, and (iv) artisanal gold mining taxes collected by CAPAM/SONAMINES. While the report confirms that revenues collected and retained by SOEs are not transferred to the single Treasury account, it explicitly categorises SNH’s ‘direct interventions’ as not constituting quasi-fiscal expenditures given that they are reflected ex post in the government’s TOFE and the budget execution report. While the International Secretariat concedes that the value of SNH’s ‘direct interventions’ in national security expenditures on behalf of the state are reflected ex post in the government’s budget documents, it echoes the IMF’s view that these expenditures do not follow conventional budgetary discipline and thus considers that they should be covered as extractive revenues not transferred to the single Treasury account under Requirement 5.1 and as forms of quasi-fiscal expenditures (see Requirement 6.2). Most stakeholders consulted aside from development partners and some CSOs strongly rejected the categorisation of SNH’s ‘direct interventions’ as being off-budget and as quasi-fiscal expenditures. The 2021 EITI Report provides some explanation for the management of these extractive revenues not transferred to the single Treasury account, albeit without reference to financial reports providing the same level of transparency and accountability on these extractive revenues managed outside the Treasury account as for revenues transiting through the single Treasury account. The EITI Report’s description of the management of professional training contributions collected by SNH-Mandat is cursory and does not explain the allocation of these funds in 2021, only providing the value of oil and gas companies’ payments of these contributions in 2021. Likewise, the EITI Report provides a breakdown in the beneficiaries of SNH’s ‘direct interventions’ on behalf of the state, but does not explain the uses of these funds beyond reference to ‘national security’ and does not refer to the different budget codes for SNH’s ‘direct interventions’ (see Requirement 6.2). There are opportunities for further improving the transparency of extractive revenues not transferred to the single Treasury account, which could support fulfilling Cameroon’s commitments to the IMF as part of its extended credit facility.

The Secretariat's assessment is that Requirement 5.3 remains not assessed, given that several encouraged aspects of this requirement remain to be addressed by Cameroon EITI. The Secretariat’s view is that the objective of strengthening public oversight of the management of extractive revenues, the use of extractives revenues to fund specific public expenditures and the assumptions underlying the budget process is not fulfilled, given the lack of public disclosure of information that could further public understanding and debate around issues of revenue sustainability and resource dependence. Consulted stakeholders did not express particular views on progress towards the objective. There are few systematic disclosures of information on revenue management and expenditures by government entities beyond the publication of the annual budget law and quarterly budget execution reports on the Ministry of Finance’s General Direction of Budget website and annual audit reports on government accounts on the Chamber of Accounts website. Cameroon’s 2021 EITI Report provides a general overview of earmarked extractive revenues as well as the budget and audit cycle, with links to these systematic disclosures. The EITI Report does not describe the structure of the supreme audit institutions in Cameroon however, including the relation between the Superior State Council (CONSUPE) and the Chamber of Accounts, even though there remains some relevant information on this issue in Cameroon’s last Public Expenditure and Financial Accountability (PEFA) assessment in 2017 (the next PEFA assessment is ongoing in 2023). However, the report does not provide any additional information on assumptions underpinning forthcoming years in the budget cycle and relating to projected production, commodity prices and revenue forecasts arising from the extractive industries and the proportion of future fiscal revenues expected to come from the extractive sector. There is no evidence of Cameroon discussing the implications of recent developments such as the change in operatorship of Chad’s Doba oil project on the expected throughput in the Chad-Cameroon pipeline and related transit fees to the Government of Cameroon. There are significant opportunities to strengthen Cameroon’s use of its EITI implementation to meet public demand for information could further public understanding and debate around issues of revenue sustainability and resource dependence.

The Secretariat's assessment is that Requirement 4.6 remains not applicable, as in the previous Validation. The Secretariat’s view is that the objective of enabling stakeholders to gain an understanding of benefits that accrue to local governments is not applicable in Cameroon during the period under review. Consulted stakeholders confirmed this view. Cameroon’s 2021 EITI Report confirms that extractive companies are not required to make any direct payments to subnational state entities. The Secretariat’s understanding is that there have been no reforms of the fiscal regime for mining or petroleum that introduced any new direct subnational payments since the period review in the previous Validation.

The Secretariat's assessment is that Requirement 5.2 is mostly met, as in the previous Validation. The Secretariat’s view is that the objective of enabling stakeholders at the local level to assess whether the transfer and management of subnational transfers of extractive revenues are in line with statutory entitlements is mostly fulfilled, given gaps in disclosures of executed subnational transfers of two of the three types of transfers. Consulted stakeholders from all constituencies highlighted the improvements in execution of subnational transfers of (artisanal) mining revenues as a direct impact of EITI implementation, given that EITI disclosures had consistently highlighted the lack of distribution of subnational transfers as a governance gap, with related recommendations. Most consulted stakeholders considered the objective broadly met, despite the gaps in disclosures of calculations of expected subnational transfers by beneficiary subnational government for two of the three types of subnational transfers. While acknowledging the important advances in receiving more subnational transfers of extractive revenues, local government representatives consulted considered that they did not have sufficient visibility on what they were owed in line with the statutory revenue-sharing formula. There are no systematic disclosures of information on subnational transfers of extractive revenues by government entities. There are three types of subnational transfers of extractive revenues in Cameroon: transfers of a share of (i) ad valorem tax and extraction tax, (ii) additional communal transfers (‘Centimes Additionnels Communaux’), and (iii) ad valorem tax on artisanal mining. Cameroon’s 2021 EITI Report provides a greater level of transparency on the first type of subnational transfers than on the other two. The general revenue sharing formula is provided for all three types of transfers. With regards to subnational transfers of a share of ad valorem tax and extraction tax, the 2021 EITI Report provides the notional and actual value of subnational transfers per company, but not by individual beneficiary local government entity. Given that mining companies may hold several licenses in different local government areas, it is likely that the data on subnational transfers is not effectively disaggregated by beneficiary local government, as confirmed by the IA in consultations. The IA noted that it would be possible to publish more disaggregated data (by beneficiary) on these transfers. The EITI Report notes that the data on notional and actual subnational transfers covers only revenues from tax offices (branches of the DGI) that are connected to the tax office’s ‘MESURE’ system but does not include transfers related to extractive revenues collected by DGI branches in more remote parts of the country that are not connected to ‘MESURE’. In consultations, the IA explained that the vast majority of extractive companies were registered in Yaoundé and Douala, whose tax offices were connected to ‘MESURE’, and thus that the revenues collected by non-connected DGI branches were not considered material. Indeed, the IA explained that only some artisanal and semi-mechanised miners may be registered in more remote local government areas with DGI branches that were not connected to ‘MESURE’. With regards to subnational transfers of a share of additional communal transfers (‘Centimes Additionnels Communaux’), the 2021 EITI Report provides only the aggregate value of extractive revenues that should have been transferred to eligible local governments in 2021 according to the revenue-sharing formula, but not disaggregated by individual beneficiary. The report explains that data on the value of these subnational transfers that were executed in 2021 was not provided, and thus it was not possible to identify discrepancies between notional and actual subnational transfers of this type. With regards to subnational transfers of a share of ad valorem tax on artisanal mining, the 2021 EITI Report provides the value of subnational transfers executed in 2021, disaggregated by individual beneficiary. Yet the report explains that this data was sourced from Ministry of Finance disclosures that were not corrected by the IA despite the fact it identified errors in the total figures communicated by the Ministry. State officials consulted confirmed that there were errors in the disclosures in the 2021 EITI Report but that these would be corrected in the next EITI Report. The report does not provide an assessment of whether the subnational transfers executed in 2021 were in line with the value of transfers according to the revenue-sharing formula. In consultations, state officials explained that the EITI Report contained the calculations of subnational transfers related to the ad valorem tax on artisanal mining collected by the CAPAM until Q2 2021, but not those collected by SONAMINES from Q3 2021 onwards. The initial transfers related to SONAMINES’ collections of this artisanal mining tax for Q3 2021 onwards were only made in October 2023. Thus, the Secretariat finds that it is only possible to identify discrepancies in the value of executed subnational transfers in 2021 for one of the three types of transfers.

The Secretariat's assessment is that Requirement 6.1 is mostly met. The Secretariat’s view is that the objective of enabling public understanding of extractive companies’ social and environmental contributions and providing a basis for assessing extractive companies’ compliance with their legal and contractual obligations to undertake social and environmental expenditures is mostly fulfilled, given concerns over the comprehensiveness of disclosures of social and environmental payments to government. Consulted stakeholders did not express particular views on the objective aside from the IA who considered the disclosures comprehensive. One industry representative stated that certain oil and gas contracts did contain mandatory social expenditure requirements, as part of ‘social investments’. There are no systematic disclosures of social expenditures or environmental payments and expenditures by mining and petroleum companies operating in Cameroon. While the SNH website has published annual reports up to and including 2020, these do not detail social or environmental expenditures. With regards to social expenditures, the 2021 EITI Report confirms the lack of effective mandatory social expenditure requirements in either the petroleum or mining sectors, although it confirms mandatory social expenditures required of COTCO in the oil transportation sector. While the IA’s review of legal and contractual provisions in the petroleum sector was limited to a review of the 1999 Petroleum Code and the production sharing contract (PSC) template, in consultations the IA considered it highly unlikely that any of the active PSCs contained any requirements for social expenditures and expressed strong confidence in its finding that there were no mandatory social expenditures in the upstream petroleum sector. However, one oil industry representative stated that some oil and gas contracts had requirements for mandatory social expenditures (‘social investments’), which would imply that disclosures of social expenditures in the 2021 EITI Report are not comprehensive. The Secretariat thus has concerns over the comprehensiveness of disclosures of mandatory social expenditures, which cannot be confirmed independently given the confidentiality of oil and gas contracts. In mining, the EITI Report explains that the 2016 Mining Code includes requirements for mining companies to include a local content plan covering social expenditures in their mining contract, but noted that the lack of an implementing decree for the 2016 Mining Code meant that these legal provisions were not effective to date. The IA’s review of mining contracts identified social expenditure requirements in the mining contracts with CAMIRON and GEOVIC, but the EITI Report explains that these contracts were not yet active in 2021. Thus, the only form of mandatory social expenditures in Cameroon’s extractive industries appears to be limited to the oil transportation sector. The 2021 EITI Report provides the value of COTCO’s mandatory social expenditures disaggregated by beneficiary, confirming that these were made in cash (not in-kind) and the identity of all non-government beneficiaries. While all material companies were requested to report their voluntary social expenditures in 2021, only four oil and gas companies reported any such expenditures, disaggregated to levels mandated under Requirement 6.1.a. With regards to environmental payments and expenditures, the 2021 EITI Report provides a list of such payments and expenditures without clearly distinguishing environmental payments (such as fees for environmental permits) from environmental expenditures to non-government beneficiaries (such as provisioning and contributions to environmental rehabilitation). Despite being requested to disclose any environmental payments to government, none of the material mining and petroleum companies disclosed any such payments. However, the Ministry of Environment, Protection of Nature, and Sustainable Development (MINEPDED) was included in the scope of EITI reporting for the first time in 2021, and it disclosed a total of XAF 11m in environmental revenues collected from four mining companies that were not considered material for EITI reporting in 2021. While material companies did not disclose any other form of environmental expenditures, the EITI Report discloses three oil and gas companies’ provisioning of funds for environmental rehabilitation within their own accounts, although these were not transferred to environmental rehabilitation funds in 2021. The Secretariat considers that Cameroon EITI has undertaken some efforts to disclose environmental payments to government, but considers that there are opportunities to strengthen the comprehensiveness of such disclosures in future EITI reporting cycles through close consultations with MINEPDED and material extractive companies.