Researcher4732: Given the secrecy that surrounds the military establishment in Sudan, there is no public knowledge about the procedures of military asset disposal, and no financial or other information made available on disposal sales. While formally the Contracting and Purchasing Department (CPD) at the Ministry of Finance is responsible for the orderly disposal of government assets, as mandated by the Public Procurement, Contracting and Disposal of Public Assets Act, 2010, there is no evidence that the CPD is active in the defence sector.

This Act does state that notice of all assets to be disposed of should be published in a minimum of two newspapers, but there is no evidence that this has taken place for security sector assets. Widespread continued conflict in Sudan makes discussion of military asset disposal an unlikely subject for public debate. General procurement and asset disposal policies in place in Sudan makes no specific reference to the defence and security sector. The Armed Forces Act is silent on the question of asset disposal.

Researcher4732: There is no public disclosure of asset disposals from the military establishment, and no evidence that asset disposals are scrutinised by an oversight body of any form. Neither the General Audit Chamber nor the authorities established under the Public Procurement, Contracting and Disposal of Public Assets Act, 2010, have indicated any such scrutiny.

Researcher4732: It is impossible to determine the percentage of defence and security expenditure dedicated to spending on the national security and the intelligence services, the operations of which are entirely secret. A 2009 World Bank analysis found that nearly one fifth of the national budget was allocated to 'miscellaneous functions', and that more than sixty percent of the budget was allocated to defence and security spending. In 2012, no specific figure was provided for the NISS budget, which formed part of the security chapter of the presented budget.

Researcher4732: The executive of government and NISS directly determine the budget of the intelligence services, without reference or influence from the legislature. Military intelligence budgets are not disaggregated from the general defence budget.

To my knowledge, there is no information on secret programmes provided to the legislature.

Researcher4732: Secret programs are not audited, and by law the national audit authorities of Sudan do not audit the activities of the intelligence services. There is no evidence that the military has been audited in recent years, judging by the auditor-general's reports to the National Assembly. In October 2010, the auditor-general reported that many government agencies failed to provide his office with access to the necessary files to properly conduct the audit.

Response to peer reviewer 2: There is no evidence that the budget was actually cut in reaction to the auditor-general's recommendations, but in any event no information of this type has gone to the legislature.

Researcher4732: Off-budget military expenditures are permitted by law, and are not reported on, although they are estimated by external analysts and experts to comprise a significant, if not the majority, of military expenditure.

There is no official confirmation of off-budget military expenditures, which are not subject to legal scrutiny. During the CPA period (2005-11), Sudanese defence spending was, in theory, internationally monitored, and restrictions were in place on Sudanese re-armament. During this period, off-budget spending was used to mask the true nature of the defence budget.

For more than a decade and continuing today, Sudan has been subject to rigorous international arms embargoes imposed by the United Nations, US and EU, and off-budget military expenditure has again been used as a tactic to hide transactions that would otherwise attract the scrutiny of the sanctions regimes.

Researcher4732: There are substantial off-budget military expenditures - they may even account for the majority of arms acquisitions made by the Sudanese military, as de Waal and Lewis suggest. At least some arms acquisitions made have been in violation of international law, primarily the UN arms embargo in place on Sudan with respect to Darfur, as the UN Panel of Experts have repeatedly documented.

As Leff and Lebrun document with respect to acquisitions from China from 2011 onwards, some arms acquisitions have been made in violation of end-user agreements with suppliers.

Researcher4732: Neither the National Security Act nor the Emergency and Public Safety Protection Act provide for clearly defined legal bases for the classification of information on the grounds of protecting of national security. Whether information is classified is determined by the individual agency, usually NISS, as it sees fit, at the discretion of the individuals, parties, or groups in power with no specific or clearly defined legal basis.

While there is no publicly available information on the procedures employed by the intelligence services to classify information, human rights groups have documented a pattern of arbitrary and extra-judicial behaviour in the operations of NISS.

Researcher4732: Both NISS and SAF are widely believed to have commercial interests in the financial, services, resource extraction and property sectors. One estimate suggests that at least 160 registered companies are linked, owned or controlled by the military, security and police services, although this is not publicly declared or acknowledged by the government.

As the company's own publicity and displays at arms shows have made clear, the Government of Sudan has declared ownership of MIC, an arms, vehicles and ammunition manufacturer near Khartoum. However, details of the business and its commercial dealings are not disclosed and are wholly non-transparent.

Article 49 of the Armed Forces Act explicitly allows the SAF to establish &quoute;any economic or investment projects&quoute; it deems fit, under the direct supervision of the Minister of Defence.

Response to peer reviewer 2: it is an exaggeration that 90% of independent media are owned by NISS - there are plenty of newspapers owned by NCP and Islamist individuals who don't necessarily have NISS connections - but the point on media ownership is there: both SAF and NISS have media interests (SAF has a radio station and a newspaper); NISS has controlling stakes in a tv network and newspapers (and probably some commercial radio too)

Researcher4732: Since the existence of military owned businesses is mostly unverified and highly secretive, there is no independent scrutiny of military-owned businesses, and no known auditing of such businesses conducted.

With respect to the Military Industry Corporation (MIC), there is no apparent independent scrutiny of its operations. The Armed Forces Act, which permits the military to operate commercial enterprises, does not require military-owned businesses to be subject to scrutiny or audit.

Researcher4732: Unauthorised private enterprise by military personnel has been alleged in the gold mining industry, as Tubiana describes. The government has publicly discouraged such activity but in practice has little ability to stop the involvement of military and allied personnel in such endeavours, and may well benefit from such activity, as Kumar suggests.

The Armed Forces Act, which allows the military to operate commercial enterprises, does not specifically outlaw private enterprise conducted under the umbrella of the state defence institutions, and there are no apparent regulations in place to govern such possible activity.

The business activities of senior members of the military and security services are not likely to come under scrutiny unless the individual in question falls out of favour with the president or other senior members of the regime.

Response to peer reviewer 2: I agree, and have integrated this into the answer above.

Researcher4732: There are no recorded public commitments by the Minister of Defence or senior service chiefs to tackle corruption. On the contrary, the senior officials of the defence establishment are the ones popularly thought to be implicated in corrupt activities. In 2012, amongst the grievances formally put forward from serving officers to senior SAF leadership, including the then Minister of Defence, was corruption in procurement and its effect on military capability. This complaint resulted in no known response.

In the most recent reshuffle of the military leadership in June 2015, the president appointed known loyalists who are unlikely to publicly challenge or comment on the performance of the armed forces. To do so would be an implicit criticism of the executive and the president.

Response to peer reviewer 2: I have amended my answer to reflect the military reshuffle, which occurred after the original answer was drafted.

Researcher4732: There are no known measures in place for military personnel implicated in bribery or corruption, and there is no public record of any action being taken against personnel despite widespread suggestions of bribery and corruption in the defence sector.

The Armed Forces Act is silent on corruption, and the Sudanese penal code does not apply, in practice, to defence personnel.

Researcher4732: Sources vary on the existence of legal protections available to whistle-blowers. The US State Department states that no whistle-blower protection is in place. The Anti-Corruption Resource Centre states that there are legal protections in place for civil servants who report malpractice. In practice, there is no culture of actively encouraging corruption reporting, and there are no practical safeguards in place to protect whistle-blowers.

In a case in 2013, a whistle-blower who attempted to report corruption in the police services was tried and convicted of damaging the reputation of the police, and sentenced to prison. The 2013 case is exceptional - there have been very few cases where whistleblowers have come forward.

In June 2015, President Bashir announced the establishment of a new Transparency and Anti-Corruption Commission and suggested that those that came forward with relevant information would not face repercussions if disclosure was in the national interest.

Researcher4732: Very limited information is available on recruitment and human resources management in the military generally, and no information is available that is specifically relevant to procurement, contracting and related positions.

Response to peer reviewer 1: I agree with the comment, but it's hard to determine the rationale of the military leadership in the absence of any public sources.This is not the kind of thing that people can openly talk about if they want to able to continue publishing.

Researcher4732: Establishing the size of the SAF, PDF, RSF and associated forces is extremely difficult, and there are no official figures available from the government. Analysts differ in their estimates of the sizes of the various forces active in Sudan. Some recent estimates by UN and other international analysts suggest SAF has approximately 110,000 troops, but this figure does not include civilian personnel, or members of the RSF, PDF or other pro-government forces.

The Government of Sudan doesn't issue press releases or information on the numbers of its personnel. There is also no information provided on civilian personnel.

Researcher4732: No reliable information is available about salaries for military and civilian personnel. Pay rates are not openly published. Information on allowances is not openly published, although in 2013, there were unsubstantiated media reports that SAF personnel would receive an 'operations allowance' of 450 - 600 Sudanese pounds (US$75-$100), at 2013 exchange rates.

Researcher4732: The system of payment in SAF is not well-established and details of the system are not published. Historically, there are often significant delays in payment, particularly amongst the irregular forces (PDF, Border Guards, RSF) located in conflict areas such as Darfur and South Kordofan.

Delays in payment are often cause for mutiny and discontent amongst military personnel, as documented for the PDF and Border Guards in Darfur by the Small Arms Survey and Human Rights Watch, and historically throughout the North-South civil war. Ad-hoc payments, such as the $3 million paid to a pro-government militia in February 2014, as reported by Radio Dabanga, are alleged to be common occurrences.

There is no evidence that basic pay is subject to discretionary adjustments, but it is likely given rates of inflation.

Researcher4732: The established system for appointments that once was a feature of Sudan's professional armed forces has been undermined by the reliance on personal and family connections and individual loyalties for promotion and advancement, as demonstrated by the purge of officers conducted by the present regime on its coming to power in 1989 and the 1990s.

More recently, Article 21 of the Armed Forces Act, 2007 for example, reserves the power to promote officers exclusively to the President. The Act is otherwise silent on criteria and systems for the appointment of military personnel, although it states that regulations should be in place for a system of appointments.

As evidence of non-meritocratic appointments, Bashir promoted the janjaweed leader, Mohamed Hamdan Daglo, also known as Hemeti, to the rank of brigadier, despite the fact that he did not attend military college or receive any formal education. He now holds a senior rank in the security services and speaks on matters of state.

Some specialized positions (medical officers, for example) do have formal, objective job descriptions but these are a minority of positions at middle management level.

Researcher4732: Formal processes for promotion are in place in the SAF, as confirmed by MoD officials in recent interviews, but these are not publicly declared. It is unknown if there are formal processes in place in the PDF, RSF, border guards or other government forces, and there is no transparency in the internal organization of these forces.

Promotion processes are not independent of the chain of command, as the Armed Forces Act, 2007, specifies that 'promotions of officers shall be made by decision of President of the Republic&quoute;. Consequently, political interference in promotion is likely to be common, and formal processes (above mid-level officer rank) are subservient to political calculations.

Researcher4732: Although the Sudanese parliament passed legislation in 2013 permitting the minister of defence to call on all citizens between the ages of 18-60 to join the military reserves, it is unclear whether the legislation was promulgated by the president. In any event, the law was not implemented, and Sudan does not have in place any active policy of conscription.

Researcher4732: Neither compulsory nor voluntary conscription are currently in place in Sudan. Although the Sudanese parliament passed legislation in 2013 permitting the minister of defence to call on all citizens between the ages of 18-60 to join the military reserves, it is unclear whether the legislation was promulgated by the president. In any event, the law was not implemented, and Sudan does not have in place any active policy of conscription.

Researcher4732: There is no firm evidence of ghost soldiers on the SAF payroll in the past five years, and since determining the true size of the SAF is not possible, there is no firm evidence of ghost soldiers existing. However, the multitude of armed forces, militias, and proxy groups on the government payroll (SAF, PDF, RSF, etc.) complicates the administration of payment systems, which are unlikely to have the accountability necessary to determine whether all names on the payroll actually exist, or whether there are duplications in names between different forces.

The verification of the LJM forces in Darfur is an example of the difficulty in ensuring accountability of numbers of forces. The LJM signed a peace agreement with the Government of Sudan over the conflict in Sudan, after which its forces were to be integrated in the SAF. The LJM claimed a far greater number of troops than were likely to actually exist on its own rosters, but because of the political necessity of maintaining the LJM's participation in the Darfur peace process it was difficult to conclusively dispute the numbers claimed. The UN was asked to verify the number of LJM forces, but was unable to complete the process in a timely manner.

No LJM forces were added to the payroll before verification, and the final number of LJM names added was the result of a negotiated settlement between the Government of Sudan and the LJM. It is difficult to establish if any of these names are fictitious and constitute ghost soldiers. In sum, since the LJM forces were not immediately added to the payroll before they were verified, and the final verification was never fully completed and solved by negotiation, it is difficult to know if any 'ghost soldiers' were ever added to the payroll.

There has been no information found in the media on ghost soldiers.

Researcher4732: Sudan's defence establishment lacks professionalism, and for many, salaries and allowances are considered part of the chain of command's right to dispense as it sees fit. Withholding dues from serving personnel is a common phenomenon in the defence establishment, and has been a repeated cause of problems in the military forces deployed in South Kordofan, Darfur, and in the past civil war with Southern Sudan, with direct operational impact.

For example, in November 2013, Nuba reports documented that budget austerity measures in Sudan had affected the disbursement of salaries of SAF officers, and resulted in a loss of morale amongst officers. The chain of command was responsible for the delivery of salaries to these forces.

Researcher4732: There is no evidence of a Code of Conduct for military and civilian personnel that covers conduct with respect to corruption, and it is very unlikely there is one. The National Security Act does specify standards of conduct for personnel of the intelligence service, but this is not applicable to members of the armed forces. The National Security Act grants broad immunities to NISS personnel, and provides the director of NISS with broad discretion on the applicability of conduct standards to serving personnel.

The Sudan Armed Forces Act does briefly outline general principles for the appropriate conduct of armed forces personnel, but does not cover conduct with respect to corruption:

7 (1) Personnel of the Armed Forces of all ranks , during exercising the functions of their posts, shall fully comply with the following :-
(a) the values of the pure religion, and respect all the heavenly religions, and good beliefs ;
(b) the Human Rights Bill prescribed in the Constitution;
(c) principles of the international humanitarian law, included into the ratified agreements;
(d) respect of the Constitution;
(e)abidance by moralities of combat, and war customs prescribed in the heavenly religions, and international covenants.
(2) The personnel, during discharge of their duties, or missions in general, shall be guided by the following :-
(a) promotion of the spirit of justice and equality among subordinates;
(b) spreading morality and sublime values;
(c) fostering community and endeavouring to promote the same, within the limits of the law;
(d) creating a spirit of co-operation and harmony, and enshrining the unity of objectives with the other disciplined forces;
(e) grafting the spirit of patriotism and national unity among the personnel;
(f) giving due regard to the enshrined local customs , and entrenchment of respecting the same, within the limits of the law.

The Penal Code doesn't say anything about gifts or hospitality, conflicts of interest or post-separation activities, nor does it apply to defence personnel.

Reply to peer reviewer 2: with the CPA commitments having expired in 2011, they are not necessarily relevant to contemporary South Sudan.

Researcher4732: There is no evidence of a Code of Conduct for defence and security personnel that covers conduct with respect to corruption, and the general principles outlined in the Sudan Armed Forces Act have not resulted in any known disciplinary action against SAF or associated personnel, such as those from the RSF.

Although conduct standards for personnel of NISS are specified in the National Security Act, there is no evidence that breaches of these conduct standards have resulted in disciplinary action against NISS personnel, and there are no known prosecutions of NISS personnel for malpractice.

Researcher4732: As part of a broader programme of international humanitarian law and military obligations towards civilians, some anti-corruption training for selected officers has taken place under the auspices of international donor funded military cooperation programmes, but is not a part of the training provided to all serving military personnel. A Western defence official based in Khartoum confirmed that several dozen SAF officers has received training that touched on this subject, at a conceptual level.

Researcher4732: There is no evidence of a policy to make public outcomes of the prosecution of defence personnel for corrupt activities, and there are no examples of prosecutions of military personnel for corruption in recent years. It is likely that the judicial authorities, which are not independent of the executive, would not investigate military personnel unless specifically directed to do so. Although individual government officials have periodically said that anti-corruption activity will be stepped up, this has not been in specific reference to the defence sector, and the government has typically criticised any international criticism, reporting or documentation of allegations of malfeasance by SAF or RSF personnel, rather than investigating the allegations further.

Response to peer reviewer 2: agree and I have added to my answer accordingly.

Researcher4732: Bribery is a criminal offence under the Penal Code, 2003. The Public Procurement, Contracting and Disposal of Public Assets Act, 2010 describes facilitation payments as illegal acts, but there are ambiguities in the language of the legislation, which could be clearer and more thorough in its description of offences. This Act provides for the state to punish corrupt practices by disbarring bidders and suppliers from future competition for up to 10 years, the possible loss of any existing contract and possible criminal penalties of up to 3 months imprisonment and/or a fine of up to 10,000 Sudanese pounds.

There is no evidence, however, that any application of these measures has been made in Sudan, and given the lack of transparency in the security sector and covert procurement practices made to circumvent UN and other sanctions restrictions on Sudan, it is unlikely that facilitation payments made to secure required material are priorities for prosecution. Studies of corruption in Sudan suggest that bribes and facilitation payments are common in Sudan's public service more generally. Surveying of citizens by Hamilton and Hudson and Transparency International suggests the security sector is no different in this regard.

Researcher4732: There is no military doctrine in the defence and security services of Sudan that is known to deal directly with corruption as a strategic issue, and past complaints raised by rank and file officers to senior commanders have not produced a public policy shift. However, in June 2015 President Bashir announced a cross-government effort to tackle corruption, and the formation of a new Anti-Corruption commission with responsibility for all government departments; whether the new institution will actually address the security sector remains to be seen.

Reply to peer reviewer 2: the RSF are not primarily controlled by militia leaders, despite the obfuscation of the regime. They are part of the chain of command although there is purposeful rivalry between NISS and SAF over their control. They should be considered as part of the armed forces.

Researcher4732: There is no known training in corruption issues for commanding officers. Troops deployed in Darfur have been implicated in significant corruption and criminality, which is almost certain to have taken place with the awareness, and in some cases, agreement of commanding officers. This has been documented by human rights groups and the UN Panel of Experts on Sudan, although it is difficult to accurately determine the frequency of such occurrences.

Researcher4732: Most recently, Sudanese forces have been deployed to Libya and Yemen, but it is unlikely that corruption monitors were deployed with combat forces.

Response to peer reviewer 1: It is unlikely that corruption monitors even exist in most SAF units, and there is no evidence surrounding the composition of Sudanese forces deployed abroad; that sort of information would be considered a state secret. The score is maintained given the strong likelihood that monitors are not deployed, considering there is no evidence of recognition of corruption as a strategic issue in operations, or of anti-corruption training.

Researcher4732: No Sudanese forces are deployed on peacekeeping operations.

Most recently, Sudanese military forces have been active in conflicts in Libya and Yemen, but little is known about the operational guidelines with which these troops were deployed. Given the suddenness of deployment in both cases, and the active combat in which troops engaged, it is unlikely that there was any specific training or guidelines in place relevant to corruption risks.

Researcher4732: Given the size of the military, the number of military institutions, government-aligned militias and other proxy forces active in Sudan, there is little apparent need for and no evidence that Sudan employs PMCs. However, there is no evidence of regulations in place to ban the use of PMCs.

If we include the UN PKOs, UN agencies, humanitarian operations, foreign oil companies, then things become a bit more complicated. DynCorp and PAE are two PMCs that were present as logistics contractors for the UN, during the time when UNAMID bases were being constructed across Darfur. However, these would be subject to oversight and scrutiny by their contracting partners, not by the Sudanese government.

There are also reports that suggest that Chinese security companies were engaged to rescue their abducted personnel on an ad-hoc basis. However, there is no evidence that there are Chinese private security firms permanently present in Sudan.

Response to peer reviewers: a top score cannot be selected (even if there is no evidence of the state employing PMCs) unless there is some regulation in place to scrutinise their use and sanction misbehaviour. Militias are generally not private military contractors. However, if militias (or members within them) form organised companies to provide security services that the government, companies, or individuals contract with, this may be relevant. Nevertheless, this does not appear to be the case in Sudan.

Researcher4732: There is no legislation in Sudan that specifically addresses defence and security procurement. In theory, the Public Procurement, Contracting and Disposal of Public Assets Act, 2010, would apply to the defence sector, but there are no publicly available sources to confirm that the defence sector applies this law. There is weak enforcement of the law in even non-sensitive areas of state expenditure.

The National Security Act, 2010, allows NISS to determine its own regulations for procurement and expenditure, but there is no transparency in any potential regulations. The legislation does not have clauses specific to corruption risks.

Researcher4732: Defence procurement is extremely secretive, and while there are likely to be internal formal procedures, there is no evidence that these are disclosed to the public, or even widely known within the government.

Formally, the Contracting and Purchasing Department (CPD) at the Ministry of Finance is responsible for the orderly disposal of government assets, as mandated by the Public Procurement, Contracting and Disposal of Public Assets Act, 2010, which applies to all state assets, but there is no evidence that the CPD is active in the defence sector.

There is no other public information available about the defence procurement cycle in Sudan.

Response to peer reviewers: Agreed. Score lowered from 1 to 0.

Researcher4732: Formal procurement oversight mechanisms in the former of tender committees are provided for in the Public Procurement, Contracting and Disposal of Public Assets Act, 2010. However, there is no evidence available to comment on their effectiveness, and no evidence that these mechanisms are active with respect to the defence sector. There is a complete lack of transparency in this area.

Researcher4732: Defence purchases are not publicized. As a matter of national security, information on military procurement is not publicly disclosed, given the ongoing civil conflicts in Darfur, South Kordofan and Blue Nile.

Furthermore, as Sudan is subject to arms embargoes from the United Nations, United States and European Union, and there is substantial evidence to suggest that Sudan is in violation of UN embargoes, as recorded by the UN Panel of Experts, defence acquisitions are treated as state secrets and not publicly acknowledged or confirmed.

In 2013 and 2014, for example, the Panel documented the use of air to surface missiles in combat, and confirmed that while they had been legally exported to Sudan, there had been no official declaration of their procurement by the Sudanese government.

Researcher4732: Most military procurement conducted by Sudan is from companies based in countries that lack transparency: China, Russia, Ukraine and other ex-Soviet bloc countries, as well as Iran and Qatar. The details of contracts for military procurement are not disclosed, but Sudan has limited options for its procurement, given the UN arms embargo under which the country is placed, so it is unlikely that there are any requirements for anti-corruption compliance in the terms of such contracts.

Researcher4732: Procurement in the defence sector is extremely secretive, and there is no transparent national strategy to guide the formulation of military procurement requirements. Given restrictions on Sudan's ability to acquire military assets because of international arms embargos from the UN, US and EU, procurement is guided by the availability and willingness of suppliers and consequently will likely demonstrate an opportunistic element, as demonstrated by the acquisition of second hand military aircraft from Ukraine, Belarus and Russia.

Researcher4732: The directorate of supply within the general command of the SAF has formal procedures to define purchase requirements, as indicated by interviewees from the Ministry of Defence. However, there is probably wide latitude and political interference in military acquisitions, and the actions of the directorate of supply are subject to the directives of more senior officials.

Given the secrecy that surrounds the military establishment, there is no public knowledge about the procedures of military asset acquisition. There is no legislation in Sudan that specifically addresses defence and security procurement.

In theory, the Public Procurement, Contracting and Disposal of Public Assets Act, 2010, would apply to the defence sector, but there is no evidence that this has been the case.

Researcher4732: Most defence procurement is conducted in secret, and not conducted as open competition. There does not appear to be any legislation prohibiting single sourcing. Sudan does not disclose details of its military procurement tenders, and a large number of all defence contracts are likely to be single-sourced, given the relatively limited number of suppliers willing to risk exposure to Sudanese arms embargoes, and the wide exemptions applicable to defence procurement in the Public Procurement, Contracting and Disposal of Public Assets Act.

Researcher4732: Procurement in the defence sector is extremely secretive. It is quite likely that Sudan does not conduct competitive tenders for most military procurement. It is unknown if tender boards are used in military procurement, but given the politically orientated manner in which military procurement is conducted, primarily from amongst Sudan's foreign allies in the former Soviet bloc, China, and the Middle East, this would seem unlikely.

Researcher4732: The Public Procurement, Contracting and Disposal of Public Assets Act, 2010, outlaws collusion in procurement, but is not specific to the defence sector. There is no evidence of enforcement of measures provided for in the Act. The Act punishes corrupt practices by disbarment of bidders and suppliers for up to 10 years, and loss of any existing contract.

The World Bank reports that suspected collusion between bidders in the public sector has resulted in inflated bid prices, although this is not specific to the defence sector, and there was no reported punishment in these cases.

There are no known examples of bidders being disqualified for violations of the Act. There is no hard evidence of collusion in the defence sector, or it being reported in the press, but there are unsubstantiated rumours; this is normally a &quoute;red-line area&quoute; for media reporting.

Researcher4732: The SAF general headquarters includes a directorate of supply, which is formally charged with procurement activity. However, all appointments in the SAF are subject to regime and internal organisational politics, and any professional judgement is likely to be subject to influence by superiors within the military establishment.

There is no evidence available of staff shortages. The lack of transparency means that it is not possible to determine the size of the procurement section of SAF.

Researcher4732: Chapters 12 and 13 of the Public Procurement, Contracting and Disposal of Public Assets Act of the Republic of Sudan, 2010, provide for aggrieved parties, ie. potential suppliers, to challenge procurement decisions. There is no specific exemption for the defence sector in this regard.

There are no specific provisions in the Act to formally protect companies from discrimination if these mechanisms are used. There is no evidence that these mechanisms have ever been used and, given the general lack of transparency in the sector, it is unlikely to be advantageous for a potential supplier to raise a formal complaint.

Researcher4732: The Public Procurement, Contracting and Disposal of Public Assets Act, 2010, provides for penalties against corrupt activities in procurement generally, but there is no specific evidence that these have been applied in practice to the defence sector.

The Act provides for a supplier found responsible for corrupt practices to have their contract terminated and/or be debarred as a supplier for up to ten years, and subject to criminal penalties of up to 3 months imprisonment and/or a fine of up to 10,000 Sudanese pounds.

Researcher4732: It is unknown whether Sudan has negotiated offset contracts, but military procurement is highly secretive and there is limited disclosure of the terms of any military acquisition. Suppliers to Sudan are not transparent about arms sales given international sanctions regime.

Researcher4732: It is unknown whether Sudan has negotiated or participated in offset contracts. The score has been selected given an inability to determine whether there is a government policy on offsets.

Researcher4732: It is unknown whether Sudan has negotiated offset contracts, but military procurement is highly secretive and there is no official public disclosure of the terms of any military acquisition.

Researcher4732: Military procurement is highly secretive, and there is no evidence publicly available to suggest that the government of Sudan imposes restrictions on the use of agents and intermediaries in the procurement cycle.

There is some evidence of Sudan employing brokers to facilitate arms trade in violation of UN arms embargoes, as suggested by the UN Panel of Experts on Sudan.

Researcher4732: No details of arms deals, including financing packages, are publicly disclosed in advance of contracts being signed. In arms deals that have been subsequently disclosed, financial arrangements have not been made public.

Researcher4732: Commercial relations with defence contractors are highly secretive. There is no evidence available to suggest that the government of Sudan requires its main contractors or their subsidiaries to adopt anti-corruption programmes. Given Sudan's limited opportunities to acquire military services given the stringent arms embargo it is subject to, it is unlikely that Sudan is in a position to impose such conditions on any military service contracts, even if it did desire to do so.

Researcher4732: Sudan, engaged in two civil wars, does regularly attempt to defend its spending on the security sector by referring to military imperative and national sovereignty, as demonstrated by statements by senior government officials. Its good relations with China make it the military provider of choice; however, numerous acquisitions (transport and attack aircraft, missiles, light and heavy weapons, ground vehicles) have been made from Russia, Ukraine, Belarus and other ex-Soviet bloc countries, as well as Iran, as documented by SIPRI and other observers.

It is more likely that, being constrained in participating in the open market for military procurement given financial limitations and the international sanctions regime it faces, Sudan seeks the best deals it can with the least onerous conditions possible, from whichever supplier will agree to provide the desired goods and services, rather than basing its acquisitions on a desire to please seller nations.