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32.

Are military-owned businesses subject to transparent independent scrutiny at a recognised international standard?

32a. Independent scrutiny

Score

SCORE: 100/100

Assessor Explanation

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32b. Transparency

Score

SCORE: NA/100

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There are no military-owned businesses. The law provides only for the various army corps: the Air Force, the Army, the Navy and the National Guard [1]. In practice, it has not been possible to identify a company run by the army. No press report or academic article mentions the existence of military-owned businesses. And the interviews we conducted confirmed this [2][3]. In Benin, even military training hospitals are under the supervision of the Ministry of Health [4]. There is a separation between military responsibilities and economic or commercial activities, which helps to limit the risks of conflicts of interest in the management of public and military resources.

There are no military-owned businesses so this indicator is marked Not Applicable [1] [2] [3][4]

As mentioned above, the affairs of the military institution are managed transparently. These are generally the bars known as officers’ messes or non-commissioned officers’ messes which are regularly and rigorously inspected by the Ministry of Defence’s Inspectorate General. However, these army businesses are placed under the responsibility of individuals and are not controlled in the same way as those remaining in the hands of the army. This is because these individuals are very powerful and hinder the work and independence of the Inspectorate General of the Ministry of Defence. [1] [2]

Details of the audits carried out on these commercial businesses run by the military are not made available to the public .[1] [2] But if for any other reason an individual needs these details, he or she writes a request to the Minister of Defence, who reserves the right to accept or refuse access. [1] [2]

In Cameroon, military-owned businesses lack transparency and accountability. Operating in sectors such as construction, logistics, and extractive industries, these businesses are rarely audited or subjected to independent scrutiny. The absence of publicly accessible audits adhering to recognised international standards further obscures their financial and operational processes, making it challenging to assess their compliance with ethical and legal norms. There is no evidence to suggest that independent audits are routinely carried out or published for these businesses. The limited enforcement of transparency regulations allows military enterprises to bypass oversight mechanisms applicable to civilian entities. While certain reforms have been introduced in public procurement, military businesses are often exempted under the pretext of national security, reducing transparency efforts. The lack of independent monitoring and non-publication of financial data considerably heightens the risks of mismanagement and corruption. Without detailed audit reports, civil society and oversight bodies are unable to hold these enterprises accountable. This perpetuates an environment where military-owned businesses operate with minimal external oversight and weak accountability structures.[1][2]

In Cameroon, the publication of audit results for military-owned businesses is almost non-existent. These enterprises, which operate in key sectors such as logistics and telecommunications, function in a highly opaque environment with no evidence of publicly available audits. The lack of independent and publicly accessible audit results arises from weak governance mechanisms and legal frameworks regulating these businesses. As a result, there is no publicly available information that could provide insights into their financial activities or operational integrity.

Furthermore, exemptions granted to military enterprises under the guise of national security prevent external oversight and the publication of audits[1]. This insulation from public scrutiny allows these entities to operate outside the transparency standards expected of civilian organisations. The absence of audit publication reinforces a system where mismanagement and corruption can persist unchecked, undermining accountability and governance principles.[2]

The army does not own any commercial enterprises, except for a new hotel, which opened in February 2025. The real estate it uses for commercial purposes is managed by the Armed Forces Commissariat Directorate [1, 2, 3].

The army does not own any commercial enterprises, except for a new hotel, which opened in February 2025. No trace of an audit or audit report for this activity has been found since its opening [1, 2, 3].

As a Limited Liability Company incorporated under the Company Act of 1963 (Act 179) (Repealed), (1) DIHOC is subject to oversight by the Registrar General’s Department (RGD) as regards the maintenance of records and enforcement of compliance with the Companies Act. With the new Act (2) making it possible to identify the beneficial owners of companies, the RGD is critical to identifying the beneficial owners of the various ventures under DIHOC and ensuring that filings relating to the company’s financial status, shareholding, and directorship are up-to-date and transparent. (3)

The Audit records of DIHOC and the various ventures under it are not publicly available. (1)(2)

The Auditor General undertakes audits of the military-owned businesses as provided by Article 229 of the Constitution, the Public Finance Management Act, 2012 and the Public Audit Act, 2015 [1, 2, 3]. Evidence from recent Auditor-General reports indicates that this mandate is exercised in practice. For example, the Auditor-General’s Consolidated National Government Audit Report (2022/2023) includes coverage of defence-related accounts and highlights that the Ministry of Defence and its affiliated enterprises recorded significant outstanding payments and contract liabilities [4].

The Auditor General report for 18 months period ending June 2023 established the following regarding the National Defence University Kenya: Use of unapproved Human Resource Policy Instruments. The University was using draft human resource policy instruments which were yet to be approved by the State Corporations Advisory Committee (SCAC). This was in contravention of OP/SCAC.9/21/1/1 of 11 March 2020 which provide that Board of Directors of state corporations had to implement approved Human Resource Policy Instruments at all times. The institution lacked a financial management system. The University was using Microsoft Excel to maintain the organisation records and a manual system to manage its financial, procurement, human resource and students’ records. They also had issues such as staff under establishment, operating with 121 members of staff facing a deficit of 79 staff members, a lack of internal audit function, and failure for council meetings threshold [1].
Shipyard audit report of year ending June 2023 revealed they lacked a Board Charter and Workplan in addition to failing to meet Board meeting threshold [2]. The Kenya Ordinance Factories Corporation ending June 2021 received qualified opinions for June 2021 and June 2022. Some of the issues raised by the Auditor General included unexplained inconsistencies in the financial statements, budgetary control and performance, unresolved prior years matters. The June 2022 audit raised significant audit queries on non-compliance with financial reporting template, lack of approved human resources instruments, missing workplan among many other issues [3]. The Space Agency audit report revealed lack of internal audit function, Board Members lapsed terms of service, lack of staff recruitment despite approvals having been made among other issues [4].

On the question of military-owned businesses, the research made two pertinent findings. One, as already explained in 31A, there are no military-owned business. The National Defense Act of 2008 and the Code of Conduct for Public Official prohibit this level of enterprise. Two, the research found that ex-military and security personnel are engaged in private sector ventures but not on behalf of the defence and security sector. [1][2][3]

This indicator is not applicable since there are no military-owned businesses and the government of Liberia is the sole provider of revenue and financing for all security and defence activity.[1][2][3]

The Malagasy armed forces do not have any companies. Soldiers own them privately but their companies do not engage the state institution. Moreover, several soldiers work in private companies but this is a private commitment and these activities do not always have an impact on their military status. [1] [2] [3]

The Malagasy armed forces do not have any companies. Soldiers own them privately but their companies do not engage the state institution. Moreover, several soldiers work in private companies but this is a private commitment and these activities do not always have an impact on their military status. [1] [2]

The army does not own a company, the law formally prohibits it.[1][2]

The army does not own a company, the law formally prohibits it.[1][2] This indicator is marked Not Applicable.

The military-owned companies, such as Monte Binga Company, are subject to some scrutiny and even publish their apparent financial statements in newspapers, but such processes are known to lack independence or reliability, because of the sensitive issues linked to the defence sector with which they deal and which are classified as secret [1,2]. However, during interaction with the staff of the Parliamentary Committee on Defence, Security and Public Order, for the purpose of collecting data, no evidence was found that these companies are subject to independent and transparent scrutiny according to a recognised international standard, a fact confirmed by the Staff Member of this Committee who was interviewed during the data collection in Parliament [3].

Although information is available, the audit details may be incomplete or abbreviated, as these companies have ties to the Defence and Security Sector, where activities related to operations are classified [1]. For example, Monte Binga Security Companies Limited has published its financial reports in newspapers, in compliance with Article 17 of its Articles of Association, which mandates the presentation of the Balance Sheet at the General Meeting [2]. However, this requirement is in conflict with Article 12, which restricts the disclosure of certain information [3].
Although some aspects of their operations may be classified as State secrets, these companies are still governed by the Commercial Code, which requires them to publish their annual balance sheets and provide financial accounts to their partners, ensuring some level of transparency through newspaper publications [4].

Following the military coup of July 26, 2023, and the dissolution of the Constitution, there is no clear legal framework explicitly restricting military ownership of commercial enterprises. While the pre-coup legal framework prohibited defense institutions from owning businesses [1], the lack of oversight in the current military-led administration raises concerns about potential military involvement in commercial activities.
Moreover, there is no evidence that any existing or potential military-owned businesses are subject to independent external auditing based on international standards. Given the secrecy surrounding military expenditures, as reinforced by the February 2024 presidential decree, there are no known scrutiny mechanisms in place to assess military-affiliated financial activities.[2]

There is no public evidence that military-owned businesses, if they exist, are subject to external audits or financial scrutiny. Following the military coup of July 26, 2023, and the dissolution of the Constitution, any potential military-affiliated financial activities operate without oversight or disclosure [1]. Additionally, the February 2024 decree exempted military expenditures from public procurement and financial accountability [2], further reinforcing the lack of transparency.

Despite history of corruption in the defence sector, there is no evidence to suggest that military owned businesses have been subjected to an independent scrutiny. [1] Without doubt, these commercial ventures were established with funding from defence budgets and ought to be thoroughly scrutinised. [2]

There is no evidence of detailed audit availability to the public.(1) (2) Therefore, this indicator is scored Not Applicable.

It is challenging to determine if a military-owned business is subject to independent scrutiny, as there is no legislative identification concerning businesses owned by security forces in Senegal. The State provides them with all the financial and material resources they need to ensure public safety. Military institutions are not supposed to do business, since they provide a public service and, what’s more, public safety [1] . All serving officers are also prohibited from engaging in any private or profit-making activity of any kind whatsoever. Exceptional exceptions to this prohibition may be made under conditions to be laid down by decree of the Council of Ministers. [2]

There are no officially recognised and legally constituted companies belonging to military institutions in Senegal so this indicator is marked Not Applicable. [1] [2]

The Department of Defence does not have beneficial ownership in any known commercial businesses of significance. The DoD operations are limited to statutory understate-owned bodies like Armscor, which is fully government-owned and does not involve private shareholding [1].
These entities are bound by the Public Finance Management Act, with legally mandated annual reporting and auditing of financial and performance information. According to the PFMA, annual reports must be tabled in Parliament within six months, confirming formal oversight mechanisms are in place via proper financial governance [2].

The Department of Defence does not have beneficial ownership in any known commercial businesses of significance.

Defence and security sector owned businesses like other government institutions in South Sudan are supposed to be subjected to scrutiny. The National Audit Chamber, the National Legislative Assembly and other oversight agencies are supposed to oversight financial and commercial activities of public entities [1] [2]. However, there are some limitations in establishing whether there is independent scrutiny since the legislature and its subcommittees are dominated by members of the ruling party, similarly audit reports on defence and security agencies are equally very brief and inaccessible. Furthermore, the Committee of TNL has limitation on the extent of the scrutiny of businesses owned by the military and security agencies. This is due to the fact that the current TNL is not elected by the people but appointed by the parties to the R-ARCSS. The risk associated with being very critical of processes relates to being recalled and replaced by the nominating parties to the R-ARCSS.[3]

Auditing public institutions in South Sudan has generally faced obstacles from inadequate finances, lack of human resource and huge backlogs from overdue audits [1]. This means that current audit reports are not produced timely and when they are, members of the public find it difficult to access the reports [2].

The independence and reliability of the scrutiny applied to military businesses by the Office of the Auditor General and the Public Procurement and Disposal of Assets (PPDA) authority are crucial for ensuring accountability. Their independence is established by their legal mandate to conduct audits and reviews without direct interference from the entities they scrutinise. For example, the Auditor General operates as an independent constitutional office, tasked with examining the financial accounts of the government, including those of military enterprises. This separation of powers is fundamental to their ability to conduct impartial assessments. Similarly, the PPDA operates with a mandate to ensure compliance with procurement and disposal regulations, providing an independent check on the financial activities of these businesses. They pinpoint specific gaps in financial management and operational efficiency, identifying the responsible units or individuals. This level of detail, combined with concrete recommendations for corrective action, demonstrates a thorough and systematic approach. [1][2]

However, the fact that most recommendations are not followed does not invalidate the independence or reliability of the auditing process. Rather, it highlights a critical implementation gap. The audits effectively identify problems and propose solutions, but the lack of follow-through by the audited entities points to a broader challenge of enforcement and accountability. The audits themselves remain independent and reliable, providing valuable insights into the financial health and operational efficiency of military businesses. The challenge lies in ensuring that these insights translate into meaningful action and improved governance.

The Uganda People’s Defence Force (UPDF) engages in several business ventures, most notably through the National Enterprise Corporation (NEC), which acts as its commercial arm, producing goods and services for both military and civilian use. Additionally, the Wazalendo Savings and Credit Cooperative Society (WSACCO) provides financial services to UPDF personnel, and the military also pursues self-sustainability through agricultural and other productive projects. These ventures aim to support the UPDF’s logistical needs and contribute to the national economy, though their operations vary in transparency.[3]

The transparency surrounding the financial operations of military-owned businesses in Uganda is supported by statutory audit processes conducted by the Office of the Auditor General (OAG) and oversight from the Public Procurement and Disposal of Public Assets Authority (PPDA). These institutions produce annual reports that are submitted to Parliament and made publicly accessible, reinforcing a formal accountability mechanism. For example, the OAG’s 2023 Consolidated Report includes observations on various Ministries, Departments, and Agencies, including the Ministry of Defence and Veteran Affairs (MoDVA), which oversees military-owned businesses [1].
Similarly, the PPDA’s 2022–2023 Annual Report highlights procurement compliance issues and general disposal practices within the public sector, including the security sector. However, due to the sensitive nature of military operations, the audit details related to defence commercial entities are summarised or presented in aggregated form. These reports may note the existence of financial irregularities or audit findings, but do not disaggregate revenues, expenditures, or ownership structures of military-owned enterprises in detail [2].

Although audit results are made publicly available and contribute to oversight, the level of detail is typically incomplete or abbreviated, particularly regarding defence-owned businesses. This limits the ability of civil society and the broader public to conduct full independent scrutiny of financial activities in the military sector.

The military owned businesses are not subject to transparent independent scrutiny to any recognised international standard. [1] There is no evidence that the military owned businesses are subjected to transparent independent scrutiny. [2]

The military business which includes mining deals, does not publicly publish their auditing reports to the public [1]. There is no law which obligates them to publish their internal audit reports to the public [2].

Country Sort by Country 32a. Independent scrutiny Sort By Subindicator 32b. Transparency Sort By Subindicator
Benin 100 / 100 NA
Burundi 50 / 100 0 / 100
Cameroon 0 / 100 0 / 100
Cote d'Ivoire 50 / 100 0 / 100
Ghana 50 / 100 0 / 100
Kenya 100 / 100 100 / 100
Liberia 100 / 100 NA
Madagascar 100 / 100 NA
Mali 100 / 100 NA
Mozambique 0 / 100 50 / 100
Niger 0 / 100 0 / 100
Nigeria 0 / 100 NA
Senegal 100 / 100 NA
South Africa 100 / 100 NA
South Sudan 50 / 100 0 / 100
Uganda 75 / 100 50 / 100
Zimbabwe 0 / 100 0 / 100

With thanks for support from the Dutch Ministry of Foreign Affairs who have contributed to the Government Defence Integrity Index.

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