Le Sénégal atteint un score très élevé dans la mise en œuvre de l’ITIE

The 2021 work plan and planned outcomes are specific and address national priorities which consist in “accompanying the government in operationalising transparency mechanisms to optimise governance that allows citizens to have oversight of the outcomes of the management of the extractive industries ». The 2021 work plan is the last operational phase of the 2017-2021 strategic plan whose overall objective is to strengthen systematic disclosure into the government’s system and improve the quality of data. This aligns with the national priorities set out in the extractive sectoral policy letters which to create "Openness and transparency of the extractive sector, and through them, leverage management based on quality information accessible to as many people as possible so as to promote full collaboration between all stakeholders”. The work plan includes a logical framework and establishes an effective tool for planning and monitoring activities, and it is structured following results-based management principles. Indicators are included to enable monitoring of progress. The MSG has set up a monitoring framework “Monitoring and Evaluation Committee” to follow up on its work plan. It includes activities that seek to improve EITI communication and dissemination outreach tools, build stakeholders’ capacity and engagement, as well as legislative advocacy. Overall 2017-2021 work plan outcomes align with the country’s various sectoral policies including on mining, Oil and Energy and the environment, which are summarised in Senegal’s Development Plan “ Sénégal Plan Emergent”. In addition, the plan clearly addresses the scope of EITI disclosures and the policy changes that the MSG wishes to see result from the EITI. The plan includes an overall budget, costed activities and clear sources of funding for each. Senegal has exceeded the requirement by setting up a “Monitoring and Evaluation Committee” linking its work plan to a monitoring framework. The Secretariat’s assessment is that requirement 1.5 has been exceeded given that all aspects of the requirement, including the encouraged aspects, have been addressed and the objective fulfilled.

Senegal EITI has undertaken active, effective and innovative communication, outreach and dissemination efforts that enable evidence-based public debate on extractive industry governance, in line with the objective of the requirement. The EITI Reports and other Senegal EITI documents are comprehensible and actively promoted through regular ‘EITI Weeks’ public events, newspaper articles and audio-visual broadcasts. Senegal EITI has successfully increased the media’s awareness of extractives data and its capacity to use with focus on specific issues—topics considered priorities by national and local stakeholders. A total of 109 written and audio-visual productions relating to the 2019 EITI Report including 6 community programs for one hour per issue to discuss governance of the extractive sector (see e.g., broadcasts held in Malinke, Pulaar and Wolof). The language of activities varies according to regional needs, and Senegal EITI has developed different types of communication products to ensure that data is accessible to different groups. Community forums were held in local languages during the ‘EITI weeks’, where findings of EITI Reports are shared. Key communication materials have consistently been distributed at these events. EITI data is used by a wide range of actors including academics, civil society and parliamentarians leading to the fulfilment of the EITI Principles by contributing to wider public debate. Stakeholder consultations and the Validation submission demonstrate that EITI data is used to inform decision-making and drive reforms in extractive industry governance. A study commissioned by the MSG demonstrated that the majority of stakeholders polled considered the EITI’s impact on public debate to have been strong. An impact assessment of the EITI in August 2020 recommends improvements to the MSG in order to enhance the EITI’s impact on public debate by further improving the accessibility of information. However, stakeholder consultations and findings from the impact of the EITI study raised concerns that dissemination and capacity building activities target more the Dakar and capitals of extractive regions rather than focusing on affected communities leading to the lack of public debate in zones where extraction takes place. The Secretariat’s assessment is that all aspects of the Requirement 7.1, including the encouraged aspects, have been addressed and that the objective has been exceeded.

Senegal EITI has agreed and published an open data policy. The 2019 EITI Report and its summary, payments project by project and various 2019 annexes (12) are available in excel format through the open data portal. In addition, some contextual data for the 2019 report such as the contribution of the extractive industries to the economy (Requirement 6.3) and data on production (Requirement 3.2) are available in various formats including .xlsx, .csv, .json and .html, while beneficial ownership (requirement 2.5) and state participation (2.6) data are available in .csv and .xlsx. Export data (Requirement 3.3) is mainly disclosed through EITI sources (some figures are also available on the ANSD website, but in a less detailed format). Stakeholder consultations and the Validation template did not highlight any particular concern related to the accessibility of the data for analysis. The Secretariat’s assessment is that all aspects of the requirement have been addressed and that the objective to enable the broader use and analysis of information on the extractive industries has been fully met.

The MSG has undertaken significant efforts to strengthen the impact of EITI implementation by acting upon lessons learned. It has set up a systematic approach to follow up on recommendations from EITI reporting or Validation through the creation of an ad-hoc committee by the MSG to follow up on EITI recommendations and a Working Group at the Ministry of Finance and Budget. The MSG’s committee oversees implementation of recommendations and identifies remedy actions. The MSG has compiled the recommendations dating back to 2015 as part of their 2019 EITI Report. In total, 13 of the 25 strategic recommendations from the previous validation have been fully implemented, while several (but not all) recommendations from EITI Reports covering 2015-2018 have been fully implemented. The MSG’s impact assessment notes that SOEs and companies have fully implemented relevant EITI recommendations, while not all recommendations related to government agencies have yet been implemented. The MSG has successfully engaged with stakeholders to ensure implementation of recommendations including at the highest political levels such as a meeting with the President of the Republic of the Senegal around the EITI recommendations. The MSG’s capacity to engage with high-level authorities has been key to implementing recommendations, including on contract disclosure and the beneficial ownership register. Follow-up on recommendations is one of the key pillars of the 2021 EITI work plan. The Secretariat’s assessment is that Senegal has fully met the requirement’s objective to ensure that EITI implementation is a continuous learning process that contributes to policymaking based on the MSG regularly considering findings and recommendations from the EITI process and acting on those recommendations it deems are priorities.

The MSG has undertaken efforts to review the outcomes and impact of the EITI that exceed the requirement. In addition to publishing annual progress reports covering 2018, 2019 and 2020, which include an assessment of progress on the five outcome areas, the MSG commissioned an impact study in 2020 that sought views from different stakeholders from 2013 to 2020. The study captures Senegal-EITI’s efforts to address nationally key priorities, mainstream the EITI into the government system and improve data quality as well as tackle legal constraints through advocacy, and broadly leverage institutionalisation of EITI Requirements in national legislation. The MSG’s efforts to take gender considerations and inclusiveness into account are captured in the impact study and the 2021 work plan. The MSG undertook consultations to give all stakeholders an opportunity to provide feedback on the EITI process and the impact of the EITI and has reflected their views through the 2020 impact study, 2019, 2018 annual reports (Requirement 7.4.b). In addition, stakeholders were able to provide feedback on the EITI process through outreach events. The Secretariat’s assessment is that all aspects of the requirement, including encouraged aspects, have been addressed and that the objective of regular public monitoring and evaluation of implementation that ensures the EITI’s accountability has been exceeded.

Senior government officials, including President Macky Sall and key government Ministers, have regularly expressed public support for the EITI in the 2017-2021 period. A senior government official has consistently been in place to lead EITI implementation, with changes in 2017 and 2019. EITI is featured prominently in Senegal’s letter of intent to join OGP (its first national action plan is under development). The government is fully, actively and effectively engaged in the EITI process. The Senegal EITI secretariat, which has high capacity and commitment, is hosted under the Office of the President of the Republic. Government officials including the MSG Chair and officials up to President Macky Sall have regularly intervened to resolve bottlenecks in EITI implementation, for instance in ensuring the publication of all extractive contracts, the establishment of an online oil and gas cadastre and an EITI open data portal. The government has played an active role in following up on EITI recommendations, including in establishing a dedicated working group within the Ministry of Finance. The government has provided consistent funding for EITI implementation, which increased by 25% from 2018 to 2020 and is institutionalised in the government budget. Relevant government entities and parliamentarians are represented on the MSG and regularly participate in all aspects of EITI implementation. Government agencies, including those not directly represented on the MSG, have been engaged in the provision of EITI data. Government MSG members have ensured regular outreach to agencies not directly represented on the MSG, including to solicit their input in the annual EITI work plan and the MSG’s review of outcomes and impact. There is evidence of regular use of EITI data by various government entities and officials, including in press statements and government reports, with a view to generating public debate. There was consensus among stakeholders consulted that the government’s engagement at both political and operational levels was public and effective. The Secretariat’s assessment is that the requirement’s objective of full, active, and effective government lead for EITI implementation has been fulfilled.

The industry constituency is fully, actively, and effectively engaged in all aspects of EITI implementation. The MSG includes company representatives that reflect the industry’s structure, including four members from mining and quarrying and two members from oil and gas. Most industry MSG members actively participate in all aspects of EITI implementation, with some weaknesses in MSG attendance by a minority of mining, oil and gas company representatives. The constituency has been proactive in replacing representatives that are not able to participate in MSG meetings. There are clear mechanisms for coordination of the broader constituency, including through the Chamber of Mines and the Upstream Oil and Gas Companies Consultation Framework. Consultations indicate that most companies view EITI as more than a compliance exercise, with scope for influencing policy-making and public debate particularly on the emerging oil and gas sector. The broader constituency has provided input to key EITI documents including the annual work plan and the MSG’s annual assessment of outcomes and impact. There is evidence of use of data by companies and industry associations in both the mining and petroleum sectors. There is an enabling environment for company participation in the EITI. The constituency has not highlighted any barriers to its participation in all aspects of implementation, both in the ‘Stakeholder engagement’ template and in consultations. All material companies (26 in 2019) have participated in EITI reporting. The government has issued executive decrees and enacted legislative changes to support EITI implementation in Senegal, including in the 2016 Mining Code and the 2019 Petroleum Code. Over the years, government officials have followed up with companies to encourage full participation in EITI reporting as well as beneficial ownership disclosures.

Evidence and stakeholder consultations indicate that the Civil society constituency is fully and effectively engaged. The nomination procedure has been codified and it publicly available on the website of Senegal ITIE. This new process seems to have been followed in practice during the last round of nomination in 2021. The Publish What You Pay Coalition is leading the constituency, with four seats reserved to the members of the coalition, and three seats distributed to other organisations. The constituency contributed to strengthen engagement, outreach, and coordination during the period under review. There is evidence of regular outreach by MSG members to the broader constituency, even if this has not generated significant feedback or input. Civil society in its broader sense uses and disseminates EITI data in research, including at the local level. There is no evidence of any barriers to civil society participation or input to the EITI process related to freedom of association, expression, operation, or access to public decision-making. There was consensus among stakeholders consulted that the constituency had undertaken some efforts to expand the group to newer organisations, although most of the seven seats are currently held by organisations with a long experience with the EITI. Thus, the Secretariat’s assessment is that all required aspects of the requirement have been addressed and the requirement’s objective has been fulfilled.

The MSG is a mature institution and includes self-appointed representatives from each stakeholder group with no suggestion of interference or coercion. Nominations procedures for industry and civil society have been publicly codified. The mechanism for civil society nominations on the MSG is open to the public and CSO members of the MSG are operationally and in policy terms independent from government and companies. Information on nominations procedures is publicly available on the national EITI website. The ToR for the MSG addresses the requirements of the EITI Standard, and stakeholders have not highlighted any significant deviations from the ToR in practice. Meetings are convened with sufficient advance warning and MSG members generally appear to have sufficient time to review documents ahead of meetings. Attendance of most MSG members is consistent. The MSG’s per diem policy is clearly described on the Senegal EITI website and there do not appear to be any deviations in practice.

Senegal has addressed all aspects of this requirement: an comprehensive overview of the mining sector is available on the Senegal EITI website. It includes the most recent developments (2021), a brief history and a summary of the main present / past projects. A similar presentation is made about the nascent hydrocarbon sector.

Senegal has exceeded the objective of this requirement by publishing the extractive industries’ contribution, in absolute and relative terms, to GDP, government revenues, exports and employment, through systematic disclosures. While Senegal’s EITI reporting has not included estimates of the informal sector’s contribution to the extractive industries, public reports on the government’s statistics agency’s website (ANSD) provide estimates of informal activities. Although the 2019 EITI Report presents the economic contribution of the extractive sector in a clearer and more accessible manner, the website of the ANSD contains all the information listed under Requirement 6.3.

Senegal has addressed all aspects of this requirement by ensuring that Senegal’s EITI reporting summarises descriptions of the legal environment and fiscal regime for mining, oil and gas, including the roles of government entities, the level of fiscal devolution and ongoing of planned reforms in oil and gas, rather than mining. Government websites provide some of this information in a dispersed manner, including updates on ongoing reforms in the mining sector. The Secretariat’s assessment is that Senegal has fully addressed the requirement’s objective but has not yet exceeded the requirement given that the majority of this information is not yet systematically disclosed on government and company websites.

Senegal has exceeded the objective of Requirement 2.4 by comprehensively disclosing all contracts and licenses for the 1979-2021 period, using the EITI platform to improve the accessibility of information. All aspects of the Requirement have been addressed, including the encouraged aspects of disclosing all historical contracts. State contract disclosure practices are aligned with policy, which the MSG has documented. The MSG has compiled a comprehensive list of all contracts and associated licenses, indicating the public accessibility of each. The Secretariat’s assessment is that Senegal has exceeded the objective of the requirement given the accessibility of this data, and its relevance to public debate.

Senegal has mostly met the objective of this requirement. The legal framework relative to environmental management is addressed in the 2019 EITI Report and the environmental contributions are published, including the procedures for Environmental Impact Assessments. The Ministry of Environment website discloses relevant legal documents and procedures as well as a description of the general impact of Climate Change on Senegal and the country’s objective of greenhouse gases reduction. However, there is little evidence of public disclosure of the evaluations performed on environmental impacts of extractive projects or the monitoring of extractive companies’ environmental obligations in practice. Environmental expenditures are disclosed in Annex 8, which does not seem to distinguish between mandatory and voluntary expenditures nor to disaggregate the transactions by revenue stream. The distinction between voluntary and mandatory environmental tax has been clarified after consultation with the Ministry of Environment, with mandatory expenditures consisting of payments to the rehabilitation funds (Fonds de rehabilitation) and environmental and social management plans (Plan de gestion environnementale et sociale) while voluntary expenditures consist of institutional support (‘Appui institutionnel’). It is possible to identify most of the individual environmental payments in the reporting templates of the material companies provided in the annexes, and therefore to disaggregate the environmental payments/expenditures by revenue stream. Several environmental mechanisms, such as the rehabilitation funds or the pollution tax do not seem to be currently operational, and no contributions have been noted in 2019. Thus, the Secretariat’s assessment is that the requirement’s objective has not yet been achieved that Requirement 6.4 should remain as not assessed in order not to penalise Senegal for gaps in progress towards an aspect of the EITI Standard that is only encouraged.

Senegal has mostly met the objective of this requirement by providing a public overview of awards and transfers of oil, gas and mining licenses, the statutory procedures for license awards and transfers and an attempt at assessing whether these procedures are followed in practice. Senegal’s EITI reporting has provided annual disclosures of the numbers and identities of licenses awarded and transferred, the general award and transfer procedures and has been transparent about the lack of technical and financial criteria until the publication of the Ministry of Mines and Geology’s Procedural Manual and the 2020 Decree implementing the 2019 Petroleum Code. The MSG has prepared diagnostic reports on licensing practices in the mining sector, as a means of informing public policy making and reforms. All the 97 mining license awards have been reviewed by an independent consultant. The results, including the assessment of non-trivial deviations, are available in the annex 3 of the study. Based on the review, the MSG has also made recommendations to licensing authorities in Senegal, such as using the newly adopted manual of procedures to assess future awards and transfers of extractive licenses. However, the Secretariat’s assessment is that the MSG’s assessment of non-trivial deviations in practice did not fulfil the MSG’s own Terms of Reference for this diagnostic assessment, raising concerns over the comprehensiveness of the study’s findings, given the lack of availability of documentation related to some of the license awards reviewed. Given the lack of new oil and gas license awards and transfers in 2019, the MSG did not carry out the same type of diagnostic work on petroleum license awards and transfers, either for 2019 or earlier periods. Therefore, the Secretariat’s assessment is that the objective of Requirement 2.2 has not yet been fulfilled given that Senegal EITI’s review of non-trivial deviations in the mining sector has not yet been replicated in the oil and gas sector, despite significant public attention to petroleum licensing practices.

The two new cadastral systems with online portals in both the petroleum and mining sectors, launched in May and June 2021, respectively, has comprehensively addressed all aspects of Requirement 2.3. The development of these cadastral portals took several years (from 2018) given the establishment of government systems involved. Senegal has exceeded the objective of this requirement to ensure the public accessibility of comprehensive information on property rights related to extractive projects by the timeliness and accessibility of the data on the two new cadastre portals for mining and petroleum.

Senegal has fully met the requirement’s objective of enabling the public to know who ultimately owns and controls the companies operating in the country’s extractive industries and to help deter improper practices in the management of extractive resources. All aspects of the initial criteria for Validation of Requirement 2.5 have been addressed, including establishing an appropriate legal framework and reporting practices for beneficial ownership disclosures. The MSG has published an assessment of the comprehensiveness and reliability of beneficial ownership disclosures by material companies included in the scope of reconciliation for 2019, and has published an assessment of disclosures to date by all companies after the start of the Validation in accordance with Requirement 2.5.c. Out of the 284 license holders in the extractive sector, 13 beneficial ownership declarations have been submitted and five effectively registered by the commercial courts (“greffes du tribunal du commerce”). Requests for beneficial ownership disclosures appear to have been sent to all companies holding or applying for extractive licenses, since February 2021. The cost of information on legal owners and beneficial owners (XOF 2500 / EUR 4 per company) is not considered a constraint by stakeholders consulted. In accordance with Requirement 2.5.f.iii, links to the stock exchange filings of the 22 extractive companies in Senegal that are wholly-owned subsidiaries of publicly listed companies have been disclosed through the comments of the MSG.

Senegal seems to have achieved the objective of this Requirement. Most of the information required by Requirement 2.6 is available in the 2019 EITI Report and in the 'State Enterprises' section of the Senegal EITI website. With regard to the statutory rules relating to the financial relations of state-owned enterprises, in particular the clarification of the rules relating to retained earnings, in accordance with requirement 2.6.ai, the publication of the financial statements of PETROSEN for the years 2014-2019 adequately provided information about PETROSEN’s relation with the state for the period under review. As for the ability of state-owned enterprises to raise funds from third parties and a possible sovereign guarantee, this point was clarified through the publication of an explanatory note concerning the two major gas projects, Grande Tortue and Sangomar, as well as during consultations with stakeholders (Ministry of Petroleum, PETROSEN, College of Industry).

Senegal appears to have fully met all aspects of the requirement 4.2. The state’s and PETROSEN statutory in-kind revenue entitlements are commercialised by the operator of the sole production license, FORTESA, who transfers the proceeds in cash to the government. The volume of gas constituting the State's production share and the volume corresponding to the share attributable to PETROSEN are disclosed in the EITI report, as well as the value corresponding to the sale of these shares. The transactions were reconciled between the FORTESA company and the State / PETROSEN. The annex 24 of the 2019 EITI report also contains additional information on the entirety of the sale of gas in-kind, such as the identity of the buyer, the tariff price, contract number, date, all disaggregated by individual delivery. As these declarations are included in the declaration form sent to companies, they benefit from the same level of data assurance as the rest of financial disclosures.

Senegal seems to have fully met all aspects of the Requirement 4.5. The revenue streams perceived by the state companies are correctly described in the 2019 EITI Report. It should be noted that only PETROSEN collects revenues. Regarding transfers between the State and MIFERSO/PETROSEN, no payment (apart from regular taxation) has been made to the State from PETROSEN or MIFERSO. The State granted an operating subsidy to MIFERSO, demonstrated non-material by the MSG (less than 0.3% of total income). The MSG has also produced a note explaining the nature and status of three short-term debts from shareholders (including the State) contracted by MIFERSO and appearing in its audited financial statements. Regarding the completeness and reliability of the data, MIFERSO and PETROSEN have provided reporting templates certified by an auditor and signed by management, in compliance with the required quality assurance.

Senegal has achieved the objective of this requirement. Extractive production data are disclosed, in volume and value, disaggregated by commodities but also by project. Production data is available on the Senegal EITI open data portal, disaggregated by raw material but not by project.

Senegal has achieved the objective of the requirement. Extractive export data is disclosed, in volume and value, disaggregated by commodity but also by project and country of destination. Export data is also available on the ANSD portal, but at a lower level of sophistication than the EITI Report.

Senegal has fully met the objective of this requirement. The MSG’s decisions on materiality thresholds and scope of EITI reporting are published on the EITI Senegal website, and no revenue stream appears to have been excluded. Material companies, revenue streams and government agencies are clearly identified in the 2019 EITI Report, and no company or government agency failed to provide their reporting template. The full government disclosure from the extractive sector, including non-material revenues, is also clearly disclosed by the government and disaggregated by revenue stream and by company. The coverage for the reconciliation exercise is 96%. The audited financial statements of material companies are also made public, except for three.

Senegal has fully met the objective of this requirement. The barter-type agreement is for the government to give up its option to acquire a 10% stake in the Oromin Joint Venture Group (OJVG) mining company in exchange for the company committing to US$10 million in in-kind social expenditures (agreed with the government and the host community) over a period of several years. In practice, EITI Senegal has disclosed the social expenditures for 2019 under this agreement, which consist of office and IT expenses for public administration. Based on clarifications published on the EITI Senegal website in June 2021 and consultations with government and company stakeholders, the Secretariat understands that PETROSEN's financing arrangements with Kosmos, BP and Woodside Petroleum do not constitute loans in exchange for deliveries of physical crude oil or natural gas commodities. The Secretariat’s assessment is therefore that these financing arrangements of PETROSEN are not covered by Requirement 4.3.

For the mining sector, transport is provided by the companies' own means. The transport activity is therefore taxed within the framework of the activities of said companies and the related taxation is considered in the mining revenues collected by the government. For the oil and gas sector, no payment for the use of the PETROSEN pipeline was made in 2019. This seems to be confirmed by the absence of a declaration from PETROSEN of payment for the lease for the transport of the gas.

The 2019 EITI Report describes the MSG's definition of a project and presents reconciled financial data disaggregated by government entity, revenue stream, company and (where relevant) project. The project-disaggregated data is available on the national website and is included in the 2019 summary data template.

Senegal EITI data has been published in a sufficiently timely manner, with financial data published within less than one year of the fiscal period covered, for example the EITI Report covering 2019 was published in December 2020. This supports the Secretariat’s assessment that Senegal has exceeded the requirement’s objective of ensuring that public disclosures of company payments and government extractive revenues are sufficiently timely to be relevant to inform public debate and policy making has been exceeded.

Senegal has fulfilled the requirement’s overall objective and has addressed all aspects of the requirement, ensuring that appropriate measures have been taken to ensure the reliability of disclosures of company payments and government revenues from oil, gas and mining. Although the public sector audit reports from the Cour des Comptes are not yet available for the period under review (2019), the 2019 EITI Report does contain the Independent Administrator’s assessment of comprehensiveness and reliability of the reconciled financial data. Senegal EITI could do more to develop recommendations for the EITI to contribute to strengthening routine government and company audit and assurance systems and practices.

Senegal has fully met the requirement’s overall 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. The 2019 EITI Report describes the types of extractive revenues not recorded in the national budget, consisting primarily of extractive revenues collected and retained by the SOE PETROSEN. In June 2021, PETROSEN published its audited financial statements for the 2015-2019 period, providing a financial report describing its management of extractive revenues not recorded in the national budget.

Senegal has addressed some aspects of this requirement, primarily through EITI reporting. However, while the MSG has provided some information on revenue management and expenditures, it has not addressed aspects of the requirement related to ensuring accountability in management of earmarked revenues, budget assumptions and projections. The public sector audit reports from the Cour des Comptes are not yet publicly accessible for the period under review. It cannot yet be found that Senegal has fully met all technical aspects and the overall objective of this requirement. Thus, the Secretariat’s assessment is that the requirement’s objective has not yet been achieved that Requirement 5.3 should remain as not assessed in order not to penalise Senegal for gaps in progress towards an aspect of the EITI Standard that is only encouraged.

The Secretariat’s assessment is that Requirement 4.6 was not applicable to Senegal in 2019. The only supposedly subnational payment is the "Patente", which is not specific to the extractive sector. The total amount is XOF 2,146,612,383, or about 1.5% of total income, and has been reconciled This tax is however collected by the public treasury under common law conditions and then transferred to the benefit of the local governments where extractive companies are located, thus qualifying it more as a transfer. The 2019 EITI Report further notes that the “Patente” is to be replaced by a new tax for future reporting years.

The Secretariat’s assessment is that Senegal has fully addressed all technical aspects of the requirement. While subnational transfers were not yet operational in either the mining or petroleum sectors in 2019, Senegal EITI has provided a comprehensive description of the statutory mechanisms for subnational transfers and disclosed the calculated subnational transfers that should have been executed in 2019 according to the revenue sharing formula. The Secretariat considers that the requirement’s objective has been fulfilled, on which there appeared to be consensus during stakeholder consultations.

Senegal has fully met the objective of this requirement. Mandatory social expenditures are disclosed in Annex 6 of the 2019 EITI Report with details including the name of the company, the nature of the payment (in kind or in cash), a description of the type of expenditure and the beneficiary. Senegal has gone beyond the required disclosure by providing similar details for voluntary social expenditures in Annex 7. Regarding environmental payments to government, it has been reported that the companies in the oil and gas sector refused to pay the only environmental tax, surface tax (“taxe superficiaire”), arguing that the calculation of the tax was not adapted to the offshore sector and would lead to unreasonable amounts due. This revenue stream was therefore only paid by mining companies in 2019 and has been comprehensively reconciled in the 2019. Mandatory environmental expenditures, including contributions to environmental rehabilitation funds and expenditures under environmental and social management plans are covered under Requirement 6.4.