Researcher + Peer Reviewer3885: The Ministry of State Property and Land Tenure is the government organ responsible for selling off state assets to potential buyers, including defence and military assets. All revenue from these sales is supposed to be returned to the state Treasury and subsequently back into the budget (Interviewee 2, 2014). In practice, defence and military assets are rarely disposed of through this process as much of the equipment of the armed forces is in extremely poor condition: the majority of vehicles and airplanes owned by the armed forces are considered unusable, and no maintenance support chain exists throughout the forces (Bagayoko-Penone, p. 51). As a result, most assets simply depreciate and are abandoned instead of being sold at auction, although an inventory of all abandoned and depreciated material is kept by the government (Interviewee 2, 2014).

According to Bagayoko-Penone, smaller assets are often stolen by defence and security personnel for their own personal use - everything from fuel, to computers, printers, and multi-sockets are taken, leaving many offices barely functional (p. 51).

On the rare occasion that large assets are sold, controls on these sales are virtually non-existent. Interviewee #1 pointed out that many “shady deals” occur during these transactions where the face value of items are manipulated by those conducting the transaction. Such manipulation is difficult to detect as the defence and security establishment are not subject to audits or any other oversight (International Budget Partnership, 2011). Thorough research did not uncover any up to date evidence that asset disposals, plans for asset disposals, nor their financial results, are ever publicised The research also did not identify any speculation in the media and among civil society organisations about corruption in asset disposals.

Researcher + Peer Reviewer3885: The defence and security sectors in Cameroon are not audited and there is no information about revenue from asset disposals in the 2015 budget. The Constitution places matters of defence and security under the purview of the government, and scrutiny of these institutions is at the government's discretion (Article 35). No evidence could be found of governmental audits being conducted on asset disposals, nor is there any evidence of other forms of scrutiny, for example, by the media or civil society.

Researcher + Peer Reviewer3885: Financing of the intelligence services and initiatives related to national security come from a sub budget out of the master budget for defence, or from the budget of the Presidency. It is not possible to deduct an estimate as the budgets for defence and the Presidency are presented in aggregate, with no further breakdown of how the funds are to be allocated and spent.. According to interviewee 2, the details of both are not made public, as they are considered state secrets.

Researcher + Peer Reviewer3885: The legislature is not given full information on all secret spending relating to national security and military intelligence. There is very limited parliamentary oversight of and access to the defence budget (International Monetary Fund, 2010), issues of defence and security remain “almost the exclusive domain of the head of state” (Bagayoko-Penone, p.63; Interviewee 2, 2014). and parliament does not have the power to interfere (WikiLeaks, 2009). Initiatives related to intelligence and national security are considered state secrets, and are therefore confidential (Interviewee 2, 2014; Constitution, Article 35). While more recent documented information is not available, Interviewee 2 confirms the situation remains the same regarding the oversight of secret military and security spending in Cameroon.

Researcher + Peer Reviewer3885: The defence and security sectors in Cameroon are not audited and legislative oversight of the defence and security sector in Cameroon is very weak. While Article 35 of the Constitution enables Parliament to scrutinize Government action through &quoute;oral or written questions and by setting up committees of inquiry,&quoute; it also states that information related to &quoute;national defence, the security of the State or the secrecy of the criminal investigation&quoute; is exempt from such scrutiny, at the discretion of the government.

In addition to the constitutional restrictions, Parliament's oversight abilities are also handicapped by the control exercised by the President over the legislature. The ruling Cameroon People's Democratic Movement (CPDM) currently holds 148 out of 180 seats in the National Assembly, and it is through this majority that the executive exercises control, limiting the ability of the legislature to provide independent government oversight. In regards to issues of defence and security, they are “almost the exclusive domain of the head of state” (Bagayoko-Penone, p.63) and parliament does not have powers of oversight.

Researcher + Peer Reviewer3885: While it is not known whether off-budget military expenditures are legally permitted, external examinations show such expenditures do occur for a variety of reasons, such as emergency situations or confidentiality (International Monetary Fund, 2010; International Budget Partnership, 2011), and there is no evidence that such expenditures are exceptional and well controlled. Expenditures occurring outside of the budget process are usually made with the payment coming from another government, or quasi-government agency such as the SNH (IHS Jane’s Defence Weekly, 2015; International Monetary Fund, 2010). Budgetary adjustments are supposed to be made after the fact to account for these transactions, although whether such adjustments are in fact made (and made correctly) cannot be known, as this process falls outside of any budgetary oversight mechanisms. As a result, it is not known how much of these expenditures are directed towards the defence and security institutions. Furthermore, there is no legislative oversight of off-budget military expenditures, as the executive does not provide this information to the legislature, and off-budget funds are not subject to audit (International Budget Partnership, 2011).

Researcher + Peer Reviewer3885: Off budget military expenditures are not publicly known, as they are not subject to parliamentary oversight or audit (International Budget Partnership, 2011). However, the United States embassy in Cameroon has identified off-budget spending as a concern in the past, and stated that, although it is not aware of any specific instances, it has reason to believe it is still occurring (WikiLeaks, 2010). It is unknown whether such off-budget spending involves illicit economic activity, and there is no evidence of speculation by the media or civil society of off-budget military expenditures.

Researcher + Peer Reviewer3885: Thorough research did not identify any information regarding the classification process for items related to national security. Considering that most items related to national defence are considered confidential and are not subject to any scrutiny or oversight (International Budget Partnership, 2011; Halleson & Simo, 2009; Constitution, Article 35), one might conclude that the classification process would also be confidential and removed from scrutiny and oversight.

There is also considerable evidence of individuals or agencies persistently being able to influence decisions regarding defence and security. For example, numerous agencies are involved in the collection of intelligence, without any central control, and the president has the ability to set the assignments for the intelligence services (Bagayoko-Penone, p.61). The United States State Department expresses concern over the strong presidential control of defence and security institutions, some of whom report directly into the Office of the President. As a result, a reasonable assumption can be made that information is classified at the discretion of the individuals, parties, or groups in power with no specific or clearly defined legal basis.

Researcher + Peer Reviewer3885: It is difficult to know the extent of the involvement of Cameroon’s defence institutions in commercial businesses. No information could be found as to whether defence and security institutions are removed from such ownership in legislation. However, according to an IMF review of the country’s fiscal transparency, “the extent of government holdings in the commercial sector is significant” and these holdings are detailed in an annex to the budget law; however, this annex is not made public. No further recent publicly available evidence was found to comment on this matter. Score 2 has been selected on the basis that there is a risk such businesses may exist but no clear evidence that they do.

Researcher + Peer Reviewer3885: The IMF has noted that while government holdings in corporations are significant, “their public disclosure is limited.” This suggests that independent scrutiny is limited, as it is not possible to effectively examine such holdings without being able to obtain any information about them.

A 2013 report from the Natural Resource Governance Institute suggested that transparency continues to be a concern. While the report does not address military-owned businesses specifically, it suggests that in regards to the government's holdings in the extractive sector, scrutiny is severely curtailed with little being known about the management and expenditures of the companies, and concerns about information accuracy and completeness in the limited reporting that is done by these companies.

Although it is not known if any military-held businesses exist, if they do it is unlikely they would be subject to any kind of oversight as the defence and security establishment is not audited in Cameroon (International Budget Partnership, 2011). Score 2 has been selected on the basis that there is a risk such businesses may exist but no clear evidence that they do.

Researcher + Peer Reviewer3885: There is no evidence of legislation or a policy that prohibits or regulates private enterprise by the military or other defence ministry employees, and in fact unauthorized private enterprise by individuals from the security and defence establishment is extensive and well documented in Cameroon. State assets such as fuel are often stolen for personal use, or for sale on the market (Interviewee 1, 2014; Bagayoko-Penone, 2008); border personnel have been known to traffic in visas (Business Anti-Corruption Portal, 2014; Bagayoko-Penone, 2008); and concerns have been raised about the involvement of military personnel in money laundering through the operation of casinos and illegal gaming houses (Bagayoko-Penone, 2008). Ventures such as these have proved very profitable for members of the defence and security establishment, and “a number of colonels are said to be almost as rich as the generals, and to own plantations and buildings” across the country (Bagayoko-Penone, p.45). In addition, there is evidence that the Cameroonian armed forces have been used to provide security for private oil companies. The United States Embassy in Yaoundé observed that a meeting took place around 2009 between the Executive General Manager of the SNH, the Minister of Defence and numerous oil company executives “to discuss how to prevent piracy and improve security,” and about the possibility of the oil companies helping to fix the Cameroon navy’s broken down vessels (Wikileaks, 2009).

No further publicly available information was found.

Researcher + Peer Reviewer3885: The President (who serves as the head of armed forces) has commented in the past on the importance of anti-corruption, established the National Anti-Corruption Commission (CONAC) and launched Operation Epervier to tackle the issue, although these initiatives have been directed towards the public sector as a whole and not specifically the armed forces and defence sector. These efforts have been widely viewed as superficial attempts to mollify international donors; concerns have also been raised that the President has used these initiatives to incapacitate those he views as a political threat (Business Anti-Corruption Portal, 2014).

Other senior figures in the Ministry of Defence and the armed forces seldom participate in public debate or give speeches, but on occasion they have mentioned anti-corruption initiatives, although these commitments are also seen as disingenuous. As Interviewee #1 points out, after giving a public speech addressing illegal extortion, these officials make their way back to their offices in Yaoundé and they will inevitably pass through numerous police and gendarmes checkpoints where the officers are illegally extorting the motorists who pass through, yet they will do nothing to stop it&quoute; (Interviewee 1, 2014; Gbetnkom, 2012).

Researcher + Peer Reviewer3885: Numerous anti-corruption initiatives have been launched over the years, including the introduction of laws and the creation of investigative and oversight institutions. These initiatives include 1) Operation Epervier - aka Operation Sparrow Hawk - a broad anti-corruption initiative intended to root out corruption within the public service (Business Anti-Corruption Portal, 2014); 2) the National Financial Crimes Investigation Agency (ANIF), which is responsible for investigating financial crimes; 3) the Finance and Budget Disciplinary Council (CDBF) which investigates cases dealing with a public finance manager; 4) the Audit Bench of the Supreme Court (also known as the Chamber of Accounts/Cour des Comptes) which is a national public audit institution responsible for investigating cases of corruption in public accounts; and 5) the National Anti-Corruption Agency (CONAC) which receives and investigates complaints from the public (Business Anti-Corruption Portal, 2014).

In addition to these developments, a range of legal and administrative measures exist to sanction those found to have taken part in the misappropriation or embezzlement of public funds, corruption, bribery, favouritism and influence peddling. The penal code allows for the prosecution and imprisonment of those found guilty of such crimes. In addition, legislation on the responsibility of managers of public funds, as well as administrative actions proscribe sanctions including fines (from 200,000 CAF to 2 million CAF); asset seizure and a requirement to reimburse the State for the loss caused; suspension from the public service and a prohibition on holding a public position that includes the management of public funds for 5 years, or from holding any post related to the management of public entities for a period of 5 to 10 years (Business Anti-Corruption Portal, 2015).

While such sanctions are occasionally enforced, the law is often not implemented effectively and corruption is pervasive through the entire government (State Department, 2015; Business Anti-Corruption Portal, 2015). In addition the sanctions imposed for violations are not sufficient to deter such activity. For example, according to the Business Anti-Corruption Portal and leaked United States diplomatic cables, charges can be withdrawn and any sanctions that have been imposed can be reversed if the accused repays the money they stole, although there is no evidence that this provision has been applied in defence-related corruption cases.

Despite allegations against some high profile individuals within the defence and security institutions, sanctions are rarely imposed. For example, a retired Colonel was sentenced to 15 years in prison, though his sentence overruled by the Supreme Court; former Minister of Defence Remy Ze Meka was arrested in 2008 on corruption related charges (Bonaberi.com, 2008), however as of August 2015, no information as to a subsequent trial or conviction could be found. In 2011, allegations of corruption and money laundering were made against the current Minister of Defence, Edgar Alain Mebe Ngo'o, according to media reports the ANIF launched an investigation into the origin of funds used by his family to build various commercial enterprises (Kongassa.Fr, 2011). Despite these allegations, however, he was retained in his post in a new government announced by President Biya in December 2011 (Juompan-Yakam, 2011) and continued to serve as Minister of defence until 2015, which a number of commentators found surprising given the seriousness of the allegations made.

In addition, a 2013 State Department Report provides a summary of the charges brought against members of the defence and security institutions for the respective year, none of the charges involved corruption related offences. The 2012 State Department Report indicated that during the previous year, hundreds of government employees were charged with corruption, although it did not indicate how many of these employees worked in the defence and security institutions. It is difficult to answer this questions accurately as suggestions have been made that prosecutions that do occur are political, and used as a tool to sideline those that present a threat to the President.

Researcher + Peer Reviewer3885: Whistleblowing is not encouraged by the government and there is no overarching law protecting whistleblowers, meaning that “neither civil servants nor private sector employees are legally or practically protected from recrimination or other negative consequences when they report cases of corruption” (Mua Kingsley, 2015; Business Anti-Corruption Portal, 2014; United States Department of State, 2013).
Government jobs are highly sought after in Cameroon and internal whistleblowers risk losing these privileged positions if they speak out about any wrongdoing they encounter (Interviewee 1, 2014). There is also the risk of trumped up criminal charges being used to intimidate or penalize whistleblowers (Transparency International, 2014; 2015).

However, whistleblowing does occur through human rights organizations and other NGOs, or through the press, where disclosures are often made anonymously to prevent retaliation. It should also be noted that one of CONAC’s purposes is to accept and investigate reports of corruption, and the presidential decree establishing CONAC mandates that it must protect its sources from retaliation if information is provided in good faith (Decree No. 2006/088, 2006). CONAC has generally implemented this provision and has established a hotline for individuals to report cases of corruption (State Department, 2013; Business Anti-Corruption Portal, 2014). However, while CONAC can be considered to be an institutionalised mechanisms to facilitate reporting of corruption, its effectiveness as such an institution is hindered by the fact that it can only investigate cases, not prosecute them (State Department, 2014; Business Anti-Corruption Portal, 2014). No documented cases of whistleblowing in defence and security institutions could be found.

Researcher + Peer Reviewer3885: The Ministry of Public Contracts is responsible for all public procurement (“The New Government Procurement Rules Become Effective”). In regards to defence and security procurement, all contracts are negotiated as mutual agreement contracts (Procurement Code, Articles 30 & 31), often with input from the Presidency (U.S. State Department).

According to the Public Procurement Code, defence and security contracts are considered to of a special nature (Articles 30 and 31) and their details are not disclosed. Thorough research did not uncover any information regarding the attention paid to the selection, time in post, and oversight of personnel in sensitive positions, including officials and personnel in defence procurement, contracting, financial management, and commercial management. There is no evidence of recognition that certain positions may be more open to corruption opportunities than others, demonstrated by the fact that corruption is rampant through every step of the public procurement process (U.S. State Department; Business Anti-Corruption Portal).

Researcher + Peer Reviewer3885: The defence and security sectors do not make it a practice to disclose this information (Interviewee 1, 2014) and no information from government sources could be found. Independent estimates of these figures vary greatly by source. For example, the army is estimated to have between 20,000 - 23 000 personnel, the navy 1,100 – 1,500 personnel, the air force 600 – 1,800 personnel, and the gendarme is thought to have about 9,000 personnel (Defence Web, 2013). In terms of civilian personnel, one source estimates that they represent about 5-7% of the total military personnel (Bagayoko-Penone, p.41). The accuracy of these figures is unknown.

Researcher + Peer Reviewer3885: Research indicates that the salaries of defence and security personnel are determined through a fixed index, which are the same for both military and civilian personnel. Each grade on the index allows for special bonuses and allowances; however the details of this index (i.e. salary and bonuses per grade) are difficult to find. Both interviewee 1 and interviewee 2 state that this is not publicly available information and no further information could be found through the research.

Researcher + Peer Reviewer3885: Existing research shows the salaries of defence and security personnel are determined through a fixed index (Bagayoko-Penone, p. 47), although the payment system is not published. Personnel receive the correct pay on time as they have been prioritized in order to ensure their continued support for the regime (Interviewee 2; Bagayoko-Penone, p. 48, International Crisis Group, p. 8).

Despite enjoying beneficial treatment in comparison to the rest of the civil service, tensions still exist in the security forces regarding pay and benefits. For example, the gendarmes salaries and benefits are lower than those received by other security personnel, such as the armed forces, and there have been indications that the food, fuel and housing allowances of lower ranking officers have at times been withheld by higher ranking officials (Bagayoko-Penone, p.50-51).

Researcher + Peer Reviewer3885: The assessor could find no information regarding an established appointment system for the selection of military personnel at middle and top management level.

The top personnel in the military and defence department are appointed by the President of the Republic through decree, with no oversight (Bagayoko-Penone, 2008; Cameroon Concord, 2015; Presidency of the Republic, 2015), and the International Crisis Group observes that the President appears to favour his own ethnic group for promotions within the armed forces. Furthermore, due to very little available information on human resources management, the qualifications of many in the armed forces are not known publicly. The defence website does not include a biography of the current Minister of Defence. There does not appear to be any use of objective job descriptions or objective assessment processes.

There is also no evidence of an established system for the appointment of mid-level personnel. The International Crisis Group points out that there are irregularities in the selection process for personnel in the lower levels of the defence and security establishment, and that nepotism, favouritism and bribery sometimes affect candidate selection. Interviewee 2 supports this observation by noting that although all personnel are required to take an exam to enter the armed forces or civil service, it is common for pressure to be applied on the authorities administering the tests to ensure the test is not difficult for certain selected individuals.

Researcher + Peer Reviewer3885: There is very limited transparency in the promotion system in Cameroon and there is no indication of any formal processes, boards or oversight of the promotions process. Rampant favouritism and nepotism appear to ensure that many personnel hold positions they are unqualified for (International Crisis Group, 2010; Interviewee 2, 2014); existing research indicates instructions come from the top to produce conditions favourable for the promotion of certain individuals. During the years 1993-2003, for example, every soldier was promoted to deputy officer. This resulted in an unbalanced hierarchy as there was no further recruitment during this time, with no one on the bottom. Recruitment has been initiated again with the aim of restoring this balance (Bagayoko-Penone, 2008, p.41).

The endemic levels of favouritism and nepotism during military training in Cameroon also mean only high level, well-connected personnel have access to proper training. This has meant that an objective promotion system is not possible as a result.

Researcher + Peer Reviewer3885: There is no conscription in Cameroon.

Researcher + Peer Reviewer3885: Cameroon does not have a conscription system, as indicated in the previous question.

It is nonetheless difficult to gain preferred postings through bribery in the Cameroonian armed forces because the military has adopted a policy of ‘regional balance’ to ensure a multi-ethnic national force. In order to accomplish this policy, new staff are not permitted to be posted to their region of origin. Interviewee #2 observed that there is no evidence that this policy has been disregarded as a result of bribery, as the military is generally deployed where they are needed, and personnel are therefore required to go where they are deployed.

Researcher + Peer Reviewer3885: The Cameroonian armed forces and civil service has experienced problems with ghost solders and workers on its payroll, specifically with personnel who are retired or deceased but whose full pay is still being released (Interviewee 2, 2014). Operation Epervier has included efforts to eliminate these names by conducting a full census in 2006 of the armed forces and civil service to remove those who are no longer eligible from the payroll. The initiative resulted in the identification of 13,000 ghost workers across the civil service (including within the defence and security institutions), and the recovery of FCFA 5 billion (Cameroon Web, 2015).

No information is available to suggest that appropriate controls have been put in place to prevent ghost soldiers since the 2006 census, and another census was launched in February 2015 to again clear the civil service payroll of ghost workers (Voice of America, 2014).

In August 2015, the Minister of Public Service and Administrative Reforms published a list of 10,000 names suspected to be ghost workers, and is currently in the process of confirming if any individuals on the list are legitimate workers before finalizing the numbers and removing them from the payroll (AllAfrica, 2015). There is no indication how many of these individuals, if any, are part of the defence and security establishment. It has been noted that the current suspected ghost workers were identified despite the fact that all state workers are now managed through an automated integrated management system (AllAfrica, 2015), which suggests that the controls in place to prevent such a reoccurrence are insufficient.

Researcher + Peer Reviewer3885: For the military, chains of command are separate from chains of payment as the Ministry of Finance is responsible for managing the salaries, while the Minister of Defence and top military personnel direct the chain of command (Bagayoko-Penone, p 47). No further information could be found regarding the Ministry of Defence's management of the these salaries. In regards to the security institutions that fall under the control of the President, there does not appear to be any separation in the chains of payment from chains of command, as the President has the ability to set the assignments for these forces, and these forces are funded through the budget of the Office of the Presidency (International Crisis Group, p.9; US State Department, p. 6).

There is also evidence of benefits and allowances being manipulated within the gendarmerie through the chain of command. For example, previous research from 2008 (Bagayoko-Penone) indicates that many lower ranking gendarmes have complained they are often swindled out of their food and fuel allowances as well as their housing subsidies by higher ranking officers.

Researcher + Peer Reviewer3885: A general discipline code for the military exists however it makes no mention of bribery, gifts and hospitality, conflicts of interest and post-separation activities, and no evidence could be found that a separate code exists to address these issues. While evidence could not be found of a code of conduct covering corruption related issues, the country’s “penal code punishes a range of graft-related offences including: embezzlement of public funds, soliciting of giving bribes, influence-peddling, and favouritism” (Halleson et al., p.3).

There is no evidence that a separate code of conduct exists for civilian personnel, such as Ministry of Defence officials. However, according to Halleson et al., legislation exists covering corruption-related issues that apply to civilian personnel, including legislation regarding the responsibility of managers of public funds (which includes fines and asset seizure powers), and administrative policies are also in place (which provide for sanctions including suspension from the public service for rule violations).

In practice most of these measures are not consistently and objectively enforced, which is demonstrated by the fact that many of these laws have been in place for decades, but have only been used sporadically, as well as the fact that rampant corruption remains entrenched across the defence and security establishment (see International Crisis Group). A 2010 Global report suggests that such regulations exist only to reassure international donor agencies.

Researcher + Peer Reviewer3885: While there is no evidence of the existence of a code of conduct that covers conduct with respect to corruption, there are legal and administrative frameworks which cover some corruption-related issues. Among the measures available within this framework are the penal code (criminal prosecution), legislation on the declaration of assets and property, and administrative actions (i.e. suspension from the public service). Sanctions for violations of legal and administrative rules include fines (from 200,000 CAF to 2 million CAF); a requirement to reimburse the State for the loss caused; and a prohibition on holding a public position that includes the management of public funds for 5 years, or from holding any post related to management of public entities for a period of 5 to 10 years (Business Anti-Corruption Portal, 2015). However, these sanctions have not proven much of a deterrent as the law allows officials to be spared prosecution or have their conviction overturned if they pay back any money obtained illegally (Business Anti-Corruption Portal, 2015). Regardless, there have been examples of violations being addressed and of the results being reported in the press. For example, the former Board Chair of the National Ports Authority and former Energy Minister was sentenced to life imprisonment for embezzlement; a retired Colonel was prosecuted and sentenced to 15 years in prison (although this sentence was later overruled by the Supreme Court); and former Minister of Defence Remy Ze Meka was arrested on corruption related charges, however as of August 2015, though information as to a subsequent trial or conviction could not be found. He continues to serve in the Cabinet.

Despite such high profile arrests and prosecutions, it is clear that such corruption-related conduct is not consistently, comprehensively and effectively addressed. Generally speaking, the punishment imposed for such crimes is not proportionate; for example, after embezzling 14 million CFA in 2008, a colonel was suspended for one month, after which he was reinstated (Bagayoko-Penone, 2008). It is also noteworthy that in the cases of very senior political figures sanctions were ultimately not imposed. The loyalty of the armed forces to the President is well documented, and this loyalty has been essential to the survival of the regime. Insisting on accountability among the armed forces might sow dissent among its members. Since the current regime has a “strong vested interest in maintaining the status quo, they are inclined to adopt a lukewarm approach to the democratic accountability of the police/military” (Ebai, p.26).

Researcher + Peer Reviewer3885: SEMIL is responsible for most training of military staff, and once recruited, personnel go through 24-36 months of training at the country’s military schools. Topics covered in training include law, geography, politics, military history and information technologies; however there is no mention of anti-corruption training in the available sources (Bagayoko-Penone, 2008). According to the United States State Department, training is also provided by foreign military personnel, private companies and NGOs who cover topics such as civil-military relations, including rules of engagement, escalation of force, and human rights. More recently, the United States and other countries have provided targeted training in logistics and explosives disposal in support of the Cameroon military and its conflict with Boko Harem. There is no suggestion however that such initiatives involve anti-corruption training (Ham, 2015; Kindzeka, 2014; Schmitt, 2015), and in fact United States officials have admitted that their training of militaries in the region were deficient in that they focused too much on tactics and equipment and not enough on values and ethics.

According to Bagayoko-Penone, training for defence and security personnel in Cameroon is not prioritized - it is not uncommon for trainees to attend one course in order to get a diploma which would be helpful to career advancement; otherwise training is not considered to have very much value and continuing military education is virtually non-existent. The International Crisis Group points out those training initiatives suffer from a lack of resources. One approach that has been adopted to make up for the lack of resources is a ‘train-the trainer’ method, however it has not been successful as very few trainees go on to train their units after.

Furthermore, Bagayoko-Penone suggests that the limited training that is available is plagued by favouritism and nepotism. Often only high level personnel with the right connections have access to proper training, including in foreign military academies. Extensive research of media, governmental, non-governmental and academic sources did not identify evidence that anti-corruption training is taking place for defence and security personnel.

Researcher + Peer Reviewer3885: There does not appear to be a policy in place to make public outcomes of the prosecution of defence services personnel for corrupt activities, and despite allegations against some high profile individuals within the defence and security institutions, effective sanctions are rarely imposed. For example, a retired Colonel and former president of the supervisory board of the Port Authority of Douala was sentenced to 15 years in prison, only to have his sentence overruled by the Supreme Court (Journal Du Cameroun, 2014); former Minister of Defence Remy Ze Meka was arrested in 2008 on corruption related charges and subject to a travel ban by the USA (Bonaberi.com, 2008), however as of September 2015, information as to a subsequent trial or conviction could not be found; and in 2011, allegations of corruption and money laundering were leveled at the current Minister of Defence, Edgar Alain Mebe Ngo'o, with the ANIF apparently launching an investigation into the origin of funds used by his family to build various commercial enterprises (Kongassa.Fr, 2011). Despite these allegations, however, he was retained in his post in a new government announced by President Biya in December 2011 (Juompan-Yakam, 2011) and continues to serve as Minister of defence.

In addition, a 2013 State Department Report provides a summary of the charges brought against members of the defence and security institutions for the respective year, and none of the charges involved corruption related offences. The 2012 State Department Report indicated that during that year, hundreds of government employees were charged with corruption, although it did not indicate how many of these employees worked in the defence and security institutions. Finally, suggestions have been made (see Wikileaks) that any prosecutions that do occur are political, and used as a tool to sideline those that present a threat to the President.

Researcher + Peer Reviewer3885: Cameroon’s Penal Code criminalizes corruption, bribery and extortion, and allows for prison terms of five years to life as well as fines and asset seizures for violations. While facilitation payments are not specifically mentioned in the Cameroon Penal Code (Business Anti-Corruption Portal, 2015; Penal Code, 1967), it appears that one some of the provisions of the Penal Code may cover facilitation payments as the Penal Code prohibits any employee, without the permission of his or her boss, to receive funds to carry out, or refrain from carrying out, a service (Article 312, Penal Code, 1967). Facilitation payments are not addressed in any other legislation (Business Anti-Corruption Portal, 2015).

Facilitation payments are widespread across the public and private sectors (Business Anti-Corruption Portal, 2015; Gbetnkom, 2012) Most companies report having to pay facilitation payments when dealing with tax and customs officials (Business Anti-Corruption Portal, 2015), and according to in one study, nearly 90% of firms surveyed declared that they have experienced pressure to provide facilitation payments to ensure the delivery of services (Gbetnkom, 2012).

In regards to the institutions of defence and security, the gendarmes regularly collect small bribes from the public for the delivery of their services, and have been known to carry out arrests (despite the individual’s guilt or innocence), release individuals from prison and facilitate passage through police checkpoints, in return for a fee (Gbetnkom, 2012; Interviewee 1, 2014; United States State Department, 2013).

Researcher + Peer Reviewer3885: Thorough research did not find any evidence of a specific doctrine addressing corruption risk while on operations and it is not known whether one exists.

However, considering that previous research did not reveal any regular assessments by the defence ministry or other government agencies of corruption risk, and the lack of effective implementation of controls to deal with corruption related activities (i.e. personnel training, financial disclosure or a Code of Conduct), it can be concluded that that a specific doctrine addressing corruption risk on operations is not likely to exist.

Researcher + Peer Reviewer3885: There was no mention of anti-corruption training in any of the literature examined. Previous research indicates that in general, training for defence and security personnel in Cameroon is not prioritized and suffers from a lack of resources, while continuing military education is virtually non-existent. In addition, the limited training that is available is beset with favouritism and nepotism, where only personnel with the right connections have access to proper training (Bagayoko-Penone, 2008).

In addition, there is evidence that officers engage in, or turn a blind eye, to corrupt activities, demonstrated by the fact that armed forces personnel regularly embezzle from the budget, extort citizens and steal departmental resources for personal use (Bagayoko-Penone, 2008) that rampant corruption remains entrenched across the defence and security establishment (see International Crisis Group, 2010).

Researcher + Peer Reviewer3885: Thorough research did not find any evidence that trained professionals are regularly deployed to monitor corruption risk in the field.

However, considering that previous research did not reveal any regular assessments by the defence ministry or other government agencies of corruption, and taking into account the lack of oversight that plagues the defence and security sector in general, a conclusion can be drawn that corruption risk in the field is not a priority, and trained professionals are not likely to be monitoring the risk.

Researcher + Peer Reviewer3885: It is not known whether the military has any guidelines or provides any training specific to corruption risk in operations, and thorough research did not uncover any evidence that this is the case.

Also, anti-corruption controls such as training and the existence of a Code of Conduct are lacking for defence and security personnel, which strongly suggests that specific guidelines and training related to corruption risk in operations is probably non-existent.

Researcher + Peer Reviewer3885: Private security companies are regulated in Cameroon and they are prohibited from participating in any of the activities of the public security bodies, including law enforcement and national security. (Decree 2005/031; Bagayoko-Penone, 2008). Accordingly, score 4 has been selected.

More broadly, such companies are only used to provide security for private property (Interviewee 2, 2014). While there have been concerns in the past surrounding the activities of unlicensed private security companies in Cameroon, including criminal behaviour and the unauthorized possession of arms (People’s Daily Online, 2009), there is no recent evidence that this continues to be the case. In addition, there is no evidence to suggest that these companies are working with Cameroon’s law enforcement or national security bodies, which they are prohibited from doing. While the regulations governing private security companies in Cameroon do not mention corruption or any sanctions for corruption (Decree 2005/031), there is also no evidence of significant or widespread corrupt activities on the part of the PMCs.

Researcher + Peer Reviewer3885: While the 2004 Public Procurement Code addresses competitive bidding, transparency and oversight in public procurement (Business Anti-Corruption Portal, 2014; Halleson & Simo, 2009), items considered to be part of a 'special market' are removed from “the consideration of any public procurement commission under this Code” (Article 31, Decree No. 2004/275). Article 30 of the code identifies special markets as being those &quoute;relating to national defence, security and strategic interests of the State.&quoute; The 2004 Procurement Code does not contain any clauses specific to corruption risk and there is no evidence that exempt procurement is independently scrutinised.

There also exists a Permanent Committee for Public Contracts in Defence and Security, which was created in 1989 by Presidential Decree. However its independence is questionable as it is subject to strong presidential control and made up of members of the Executive and Presidential appointees. According to the founding decree, the committee meets when needed – at times to be determined by its president. There is no evidence this committee is currently active.

There is no other known legislation governing defence and security procurement.

Researcher + Peer Reviewer3885: The 2004 Public Procurement Code outlines the procurement process, beginning with a preliminary study to assess needs, identify requirements and assess costs; however exceptions exist for items of a special nature, including defence acquisitions, which are confidential (Decree No. 2004/275, 2009). As a result, the procurement cycle for defence and security acquisitions is unknown.

In addition, there also exists a Permanent Committee for Public Contracts in Defence and Security, which was created in 1989 by Presidential Decree. However its independence is questionable as it is subject to strong presidential control and made up of members of the Executive and Presidential appointees. According to the founding decree, the committee meets when needed – at times to be determined by its president (Decree No. 89/913, 1989). There is no evidence this committee is currently active.

The Procurement Code outlines the standard process for public procurement, which is to begin with a preliminary study by the tendering authority or the department in order to determine the project’s specifications, requirements and to develop cost estimates, after which the bids are to be publicised. The Code mandates that contracts are to be awarded to the bidder that meets the requirements of the tender while offering the most value for money (Decree No. 2004/275, 2004; Halleson & Simo, 2009).

It is unknown if the defence acquisition process follows this standard process in practice, especially given it is exempt from the Code, as discussed in Question 57.

Researcher + Peer Reviewer3885: The Public Contract Regulatory Agency (ARMP) was created in 2001 and “is the supervisor and facilitator of the public procurement system” (Business in Cameroon, June 26, 2013). The ARMP, which reports to the President, oversees the system itself, and not the awarding of contracts, which is the responsibility of the tender boards.

However, the 2004 Public Procurement Code states that items considered to be part of a 'special market' are removed from “the consideration of any public procurement commission under this Code” (Article 31, Decree No. 2004/275). Article 30 of the code identifies special markets as being those &quoute;relating to national defence, security and strategic interests of the State.&quoute; Therefore, while oversight mechanisms do exist, they do not appear to provide oversight of procurement related to defence and security.

Researcher + Peer Reviewer3885: In general, defence procurement in Cameroon is confidential and is not released to the public. Aggregate figures of defence purchases are not released. It is difficult to assess defence procurement spending based on the aggregate total defence spending figures available on SIPRI as defence and security spending is divided between the Office of the Presidency and the Ministry of Defence, and neither budget is transparent. There is no evidence that government purchases are verified through government audits.

While defence purchases are almost never made public by the government at the tender or bidding stage as the Procurement Code requires confidentiality around such purchases (Decree No. 2004/275, 2004, Articles 30 & 31), information is sometimes released into the public record through other sources such as the supplier companies or countries, as was the case when Cameroon reportedly finalised a deal with Airbus to buy a CN235 military transport aircraft in 2012. In addition, purchases or development of new equipment for Cameroon are also reported by the media, for instance when IHS Jane's reported that two new naval vessels were being built for Cameroon in China. This became clear when it was reported in the media that defence minister Edgar Alain Mebe Ngo'o inspected the work during a trip to the Chinese city of Qingdao in April 2014. Finally, the Cameroonian government has acknowledged some recent defence procurement, including the purchase of armoured vehicles from Canada and arms and equipment from Russia, which the government suggests is to be used in the escalating conflict against Boko Harem in the north of the country. However, there is no evidence that any specific details of these purchases have been made public by the Cameroonian government.

Researcher + Peer Reviewer3885: Under Cameroon’s procurement rules, any company found guilty of corruption is barred from bidding on government contracts for two years. However, many of the procurement rules have yet to be implemented, and those that have are irregularly and inconsistently enforced, meaning the effectiveness of such legislation is not known (Business Anti-Corruption Portal, 2014). In addition, due to the fact that defence procurement is confidential it is not possible to know the details of any procurement contracts related to defence and security, including any standards that may be placed on bidders. (Decree No. 2004/275).

Researcher + Peer Reviewer3885: There is no evidence of a standalone national defence policy in Cameroon.

While there doesn’t appear to be a formal process in place to link the national defence and security strategy to defence and security procurement, evidence suggests that some procurement requirements are derived from the country’s national security strategy. Cameroon’s national security strategy is primarily defensive, meant to defend the country from aggression. According to Bagayoko-Penone “Cameroon’s military apparatus,’ and means, are essentially devoted to the preservation of the security and the integrity of national territory” (p.37). In this context, recent weapons purchases of armored vehicles from Canada and arms and equipment from Russia make sense in light of Cameroon’s escalating battle with Boko Haram in the north of the country.

However, it is difficult to know how opportunistic defence procurement is, as the defence and security strategy and related procurement is not open and not audited, and all defence and security procurement is confidential (Halleson & Simo, 2009; Decree No. 2004/275,2004).

The score could be between 0 and 1; however, as it is unclear whether there is a formal strategy in place and if there is a formalised procedure to derivation of procurement requirements from this strategy, score 0 has been selected.

Researcher + Peer Reviewer3885: Cameroonian defence procurement seems to be based - albeit on an ad hoc, reactive way - on national security priorities and threats. Specifically, the procurement drive for the acquisition of naval patrol assets amid rising rates of maritime piracy in the Gulf of Guinea (Martin, 2013), with new patrol vessels purchased and delivered from China and Spain since 2013 (Binnie, 2015; Martin, 2013).

However, there is evidence of opportunistic purchases as the government occasionally invests in technologies that are surplus to immediate requirements, for example the acquisition of an anti-aircraft missile system from Russia (Binnie, 2015) which seems strange given that the country does not face a conventional air threat and has a more urgent requirement for weapons and equipment for counter-insurgency operations in Far North province.

The 2004 Public Procurement Law outlines the process that should be followed to define and quantify the need for all significant purchases before the purchase procedure commences, beginning with a preliminary study to determine needs, identify requirements and assess costs. However due to the fact that defence and security procurement is confidential and the details are not publicly available, it is not known whether defence purchases follow this process (Decree No. 2004/275; Interviewee 2, 2014).

Response to Peer Reviewer 2: While this is indication of the existence of a formal process, there is not enough information to assess to what extent it is followed in practice. Score 1 maintained.

Researcher + Peer Reviewer3885: The 2004 Procurement Code mandates that government purchases must be made through a call for tenders and contracts, and the publication of these tenders ensures they are made public. However, the Code requires that items considered part of a 'special market,' which include items “relating to national defence, security and strategic interests of the State&quoute; are to be kept confidential (Article 30 & 31, Decree No. 2004/275). As a result, defence and security procurement, as a matter of national security, is conducted through mutual agreement contracts, which are not made public; the Business Anti-Corruption Portal reports that favouritism greatly influences the awarding of contracts across all government departments, and it is reasonable to assume this includes defence and security procurement as well.

Researcher + Peer Reviewer3885: Tender boards in Cameroon fall under the authority of the senior officials of the contracting departments and agencies, who, among other things, approve the operating budget for these boards. A 2006 study by the Public Procurement Regulatory Agency (ARMP) exposed the fact that the officials of the contracting departments or agencies have in the past prevented the tender boards from functioning by denying them an operating budget.

Tender board members are subject to training by the ARMP on topics such as the “structure of the system for the award of public contracts, procedures for the award and follow-up of the execution of public contracts, preparation of files for invitation to tender and application for quotation, bids analysis and techniques in awarding public contracts.” However, as mentioned earlier, defence procurement is conducted via mutual agreement contracts, not through tender boards.

Researcher + Peer Reviewer3885: Cameroon’s Competition Law expressly prohibits and punishes cartel behaviour, including the joint establishment of “conditions for submitting a bid without informing the person who made that bid” (BG Bowman Gilfillan Africa Group, 2012, however this law governs the national economy and competitive markets within Cameroon, not procurement by the state (Law N° 98/013, 1998). Sanctions available under this law are restricted to fines – the legislation does not impose criminal penalties (BG Bowman Gilfillan Africa Group, 2012).

In addition, the Public Procurement Code lays out sanctions for the violation of procurement rules by both bidders/suppliers and tendering authorities/tendering boards. Bidders/suppliers found to have violated the rules may be charged under the laws on the protection of State assets and any company found guilty of corruption is barred from bidding on government contracts for two years. However, many of the procurement rules have yet to be implemented, and those that have are irregularly and inconsistently enforced, meaning the effectiveness of such legislation is not known (Decree No. 2004/275, 2004; Business Anti-Corruption Portal, 2014).

Furthermore, the Procurement Code stipulates that items considered to be part of a 'special market' are removed from “the consideration of any public procurement commission under this Code” (Article 31, Decree No. 2004/275). Article 30 of the code identifies special markets as being those &quoute;relating to national defence, security and strategic interests of the State&quoute; meaning that procurement related to such items is confidential, and it is not known if and how the legislation is used in such cases. No evidence could be found of colluding companies in defence procurement.

Researcher + Peer Reviewer3885: Procurement staff and tender board members are subject to training by the ARMP on topics such as the “structure of the system for the award of public contracts, procedures for the award and follow-up of the execution of public contracts, preparation of files for invitation to tender and application for quotation, bids analysis and techniques in awarding public contracts.” However, defence and security procurement is confidential and not subject to ARMP, and no information could be found on the kind of training, if any, defence and security procurement personnel receive.

Researcher + Peer Reviewer3885: The 2004 Public Procurement Code provides for a dispute resolution mechanism to deal with perceived malpractice in procurement, and there exists an Executive authority in charge of Public Procurement who is responsible for mediating procurement related disputes. However, continuing high levels of corruption within the procurement process indicate that such mechanisms are limited in their effect. The Business Anti-Corruption Portal reports that “the decisions of government officials concerning contracts and policies frequently favour well-connected companies and individuals,” suggesting that companies would likely fear discrimination for complaining about perceived malpractice. No information could be found on the extent that these mechanisms are used by companies.

Researcher + Peer Reviewer3885: The Public Procurement Code outlines the sanctions for the violation of procurement rules by both bidders/suppliers and tendering authorities/tendering boards, and states that violations are “punishable under the laws in force” (Decree No. 2004/275, 2004), which, under the Penal Code, could include fines and imprisonment (Penal Code, 1967). Bidders/suppliers found to have violated the rules may be charged under the laws on the protection of State assets, and any company found guilty of corruption is barred from bidding on government contracts for two years. However, many of the procurement rules have yet to be implemented, and those that have are irregularly and inconsistently enforced, meaning the effectiveness of such legislation is not known (Decree No. 2004/275,2004; Business Anti-Corruption Portal, 2014).

Furthermore, the Procurement Code stipulates that items considered to be part of a 'special market' are removed from “the consideration of any public procurement commission under this Code” (Article 31, Decree No. 2004/275). Article 30 of the code identifies special markets as being those &quoute;relating to national defence, security and strategic interests of the State&quoute; meaning that procurement related to such items is confidential, and it is not known if and how the legislation is used in such cases.

Researcher + Peer Reviewer3885: The details of the government’s contracts with private companies are not made public. In addition, all procurement related to defence and security is confidential, and is therefore not subject to independent audit or oversight. As such, it cannot be assessed that appropriate due diligence or auditing requirements would be carried out on any offset contracts.

While it is not known with certainty whether Cameroon uses offset contracts, the evidence suggests that they do not. According to the 2014 Investment Climate Statement by the U.S Department of State, Cameroon “does not impose any specific obligations on foreign investors such as a requirement for national equity stake or an obligation to use local raw material for manufacturing,” although it usually offers incentives to do so (p.10).

Researcher + Peer Reviewer3885: The details of the government’s contracts with private companies are not made public. In addition, all procurement related to defence and security is confidential, and is not subject to audit or oversight.

It is not known with certainty whether Cameroon uses offset contracts (Interviewee 2, 2014) however the evidence suggests that they do not. According to the 2014 Investment Climate Statement by the U.S Department of State, Cameroon “does not impose any specific obligations on foreign investors such as a requirement for national equity stake or an obligation to use local raw material for manufacturing,” although it usually offers incentives to do so (p.10).

Researcher + Peer Reviewer3885: The details of the government’s contracts with private companies are not made public. In addition, all procurement related to defence and security is confidential, and is not subject to audit or oversight.

It is not known with certainty whether Cameroon uses offset contracts (Interviewee 2, 2014), however the evidence suggests that they do not. According to the 2014 Investment Climate Statement by the U.S Department of State, Cameroon “does not impose any specific obligations on foreign investors such as a requirement for national equity stake or an obligation to use local raw material for manufacturing,” although it usually offers incentives to do so (p.10). ). As a result, a score of N/A has been selected.

Researcher + Peer Reviewer3885: While the 2004 Procurement Code governs the use of sub-contractors in the procurement cycle (Decree No. 2004/275, 2004), the Procurement Code also places all defence and security related procurement outside of the normal procurement process and such procurement is confidential. As a result, it is not known how strongly the government controls a company's use of agents and intermediaries in the procurement cycle when dealing with defence and security related procurement. According to GunPolicy.Org, the activities of agents and intermediaries in regards to arms transfers are not regulated in Cameroon.

Researcher + Peer Reviewer3885: Defence and security procurement is not made public in Cameroon, as it falls into the category of ‘state secrets’ (Halleson & Simo, 2009; Interviewee 2, 2014). t

The Cameroonian government has acknowledged recent arms purchases, including armoured vehicles from Canada and arms and equipment from Russia, to assist Cameroon its escalating conflict against Boko Harem. However, there is no evidence that any details of these purchases have been made public, including whether or not a financing package exists (Interviewee 2, 2014).

Researcher + Peer Reviewer3885: It could not be determined whether or not the government formally requires the main contractor to ensure subsidiaries and sub-contractors adopt anti-corruption programmes because the details of the government’s contracts with private companies are not made public and other up to date information could not be found. In addition, all procurement related to defence and security is confidential, and is not subject to audit or oversight (Interviewee 2, 2014; Procurement Code, Article 30 & 31; Halleson & Simo, 2009).

Researcher + Peer Reviewer3885: The main supplier for Cameroon’s Defence acquisitions are France and Israel, and to a lesser extent, Russia and China. France is Cameroon’s primary supplier, and the military relationship between France and Cameroon, while historically focused on security and French military intervention, has recently shifted to prioritize “training and commercial sales” (Interviewee 1, 2014; WikiLeaks, 2009). In addition, France has numerous officials advising the Cameroonian government, including in the Ministry of Defence, the gendarme and within the President’s office, which suggests that “the French government is in a position to influence [President Paul] Biya’s political calculations.” As the President is the head of the armed forces and the executive, and exercises almost complete control over the political process in Cameroon, it is reasonable to conclude that France, as a major supplier of arms and related material to Cameroon, is also in a position to influence defence procurement decisions (Interviewee 1, 2014). It is also worth noting that Cameroon has experienced competing pressure from both France and Israel, which has resulted in issues such as the procurement of incompatible equipment (Bagayoko-Penone, p.50).

In addition, while defence acquisition in Cameroon has likely resulted from some political influence, recent purchases have been justified with reference to military need, specifically the ongoing and escalating offensive against Boko Haram.