Are there regular assessments of the areas of greatest corruption risk for ministry and armed forces personnel, and are the findings used as inputs to the anti-corruption policy?
Are there regular assessments of the areas of greatest corruption risk for ministry and armed forces personnel, and are the findings used as inputs to the anti-corruption policy?
10a. Risk assessments
Score
SCORE: 100/100
Rubric
Madagascar score: 100/100
Score: 0/100
No defence-specific assessment of corruption risk has been commissioned or taken place in the last 2-3 years.
Score: 25/100
There is some awareness regarding risk areas, but an official risk assessment has not been conducted for the ministry or armed force as a whole, or within individual departments. The government may have commissioned or taken part in ad hoc assessments done by external parties or agencies.
Score: 50/100
There has been a partial assessment of corruption risks, but it does not clearly articulate risks for the ministry or armed forces.
Score: 75/100
Corruption risks are clearly identified, but risk assessments are conducted on the ministry or armed force as a whole, rather than with focus on individual departments.
Score: 100/100
Corruption risks are clearly identified. Individual departments conduct their own risk assessments in a process that reflects "business-as usual," whereby corruption risk assessment is a regular practice.
Assessor Explanation
The Internal Anti-Corruption Policy of the MOD applies to the military administration which includes, in particular, the central services of the Ministry of National Defence, the armies as well as the organizations attached to the Ministry of National Defence.[1]. All departments of the ministry are therefore subject to risk assessment. Furthermore, the Ministry of defence has clearly identified the sectors at high risk in terms of corruption (particularly with regard to recruitment). [2].
Assessor Sources
1.Ministère de la Défense Nationale, “Politique Interne de Lutte contre la Corruption” [“Internal Anti-Corruption Policy”], May 2022, available at https://siigac.csi.gov.mg:8888/fichier/19283456619145/Contenu%20PILCC%20(VF%20avec%20couverture)%2007.12.2022.pdf
2. “Ministère de la Défense Nationale : La Direction des Affaires Juridiques lutte contre la corruption” [“Ministry of National Defense: The Directorate of Legal Affairs fights against corruption”], Moov.mg, une 6, 2023, https://www.moov.mg/article/76121-ministere-de-la-defense-nationale-la-direction-des-affaires-juridiques-lutte-contre-la-corruption#body2
10b. Regularity
Score
SCORE: 100/100
Rubric
Madagascar score: 100/100
Score: 0/100
There is no regular schedule for risk assessments.
Score: 50/100
There is a schedule for risk assessments, but they are conducted on a less-than-annual basis.
Score: 100/100
Risk assessments are conducted on an annual basis or more frequently.
Assessor Explanation
According to its “Internal Anti-Corruption Policy” Plan, the Ministry of Defense plans periodic reports and in particular an annual report on the implementation of its anti-corruption action plan in the defense sector [ 1]. It is therefore up to senior officials and military executives, at all levels of military administration, to be guarantors of management that extremely reduces the possibilities of corruption. They have particular responsibility for identifying the nature and level of risks to which activities and resources are exposed. Thus, the annual report on the fight against corruption is supposed to have a risk assessment [2].
Assessor Sources
1. Ministère de la Défense Nationale, “Politique Interne de Lutte contre la Corruption” [“Internal Anti-Corruption Policy”], May 2022, available at https://siigac.csi.gov.mg:8888/fichier/19283456619145/Contenu%20PILCC%20(VF%20avec%20couverture)%2007.12.2022.pdf
2. Ministère de la Défense Nationale, “Politique Interne de Lutte contre la Corruption” [“Internal Anti-Corruption Policy”], May 2002, available at https://siigac.csi.gov.mg:8888/fichier/19283456619145/Contenu%20PILCC%20(VF%20avec%20couverture)%2007.12.2022.pdf
10c. Inputs to anti-corruption policy
Score
SCORE: 100/100
Rubric
Madagascar score: 100/100
Score: 0/100
Risk assessment findings are not used to inform anti-corruption policy or practice.
Score: 50/100
Risk assessment findings may be used to develop an anti-corruption policy or action plan, but they are not used to regularly update either policy or practice.
Score: 100/100
Risk assessment findings are used to develop and regularly update the anti-corruption policy and institutional action plans.
Assessor Explanation
In its “Internal Anti-Corruption Policy” Plan, the Ministry of Defense expects to capitalize on experiences in the fight against corruption [1]. Any act of corruption is thus recorded and a report is sent to higher military authorities and the Anti-Corruption Unit. Reports relating to acts of corruption are analyzed and recommendations can be issued. It is the responsibility of the Monitoring and Evaluation Division to prepare an annual report on corruption presenting the results of activities in the area as well as any proposals for improvement in this area [2].
Assessor Sources
1. Ministère de la Défense Nationale, “Politique Interne de Lutte contre la Corruption” [“Internal Anti-Corruption Policy”], May 2002, available at https://siigac.csi.gov.mg:8888/fichier/19283456619145/Contenu%20PILCC%20(VF%20avec%20couverture)%2007.12.2022.pdf
2. Ministère de la Défense Nationale, “Direction des Affaires Juridiques” [“Legal Affairs Department”], accessed June 10, 2024, https://www.defense.gov.mg/daj/
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Country
10a. Risk assessments
10b. Regularity
10c. Inputs to anti-corruption policy
Benin
The Ministerial Committee for Risk Management (CMMR) draws up a risk map [1], including those related to corruption. The development of the mapping follows a holistic approach to risk mitigation for the entire ministry. The process of developing the risk mapping follows several stages: training sessions on risk management and the development or updating of the risk mapping; dissemination of a risk mapping model to all directorates; appointment of a team to support and monitor the directorates in the development/updating of this mapping, composed of a representative of the CMMR and the directorate’s “internal control” focal point [2]. In practice, the risk map is updated every year following those stages provided [3]. However, the content of the risk map is for internal use, not open to the public [4].
75 / 100
The risk map is updated every year. This update is carried out by each directorate by the end of September each year at the latest [1]. The evolution of the level of risk is proposed according to the analysis of the results of internal controls and internal or external audits carried out during the year. The update of the mapping (or lack thereof, as the case may be) is validated during the last session of the CMMR year [2].
100 / 100
The risk map is updated every year [1] and this is used to improve the anti-corruption practices in the ministry [2]. Base on the risk map, the Ministerial Committee for Internal Audit and the Ministerial Committee for Risk Management indicate what are necessary to be improved in the anti-corruption policy [2]. Improvements over the previous two years are not possible, since the CMMR and CMA were installed in 2022 , as part of the reforms on the fight against corruption in all ministries including the Ministry of Defense [1]. But in 2023, for example, the defense CMMR risk map made it possible to emphasize the need to strengthen internal control mechanisms to monitor risky activities and guarantee transparency. Furthermore, from the elements of the risk map, the importance of placing emphasis in the training and activities of the ministry on the culture of integrity and responsibility within the Armed Forces was highlighted. And this need is entirely met by the CMMR, which is increasing its number of tours for this purpose [4].
100 / 100
Burundi
Every year, the Anti-Corruption Unit and the Court of Auditors carry out missions in the defence sector to ensure that there are no corrupt practices. However, officials from both institutions complain that they are always given answers that show they are not allowed to ask questions on certain issues. [1] [2] The pretext of defence secrecy means that the assessment of corruption risks in the defence sector remains limited.The work therefore remains partial. For instance, the supply of clothing to the military is a market that has been at the centre of scandals in the country; it is one of the most vulnerable areas to corruption in Burundi’s defence sector. Yet it is not considered in the risk assessments as no mitigation measure has been implemented (e.g. debarment list) [3].
25 / 100
The Anti-Corruption Brigade conducts corruption risk assessments within the Defence sector quite frequently. As for the Court of Auditors, its assessment is annual. [1][2].
100 / 100
The results of the various evaluations are not used to develop anti-corruption policies in the Defence sector in order to change practices [1] [2]. Many interesting reports are produced by evaluation institutions but are shelved without further action.
0 / 100
Cameroon
There is a partial assessment of the risks of corruption overall and accross all areas of public and private life in Cameroon, but no specific assessments are conducted for the defence sector. The only risk assessment available pertains to measuring the regional action plans aimed combating corruption in the 10 regions of Cameroon. This indicates whether corruption has decreased or increased in Cameroon’s regions after one year. The report on the State of the Fight against Corruption in Cameroon in 2023, published on 3 October 2024 by the Cameroon Anti-Corruption Commission (CONAC), states that 7,548 denunciations of corrupt practices were received by the institution. These led to 35 rapid intervention actions and 16 investigations involving CFAF 69 billion. Similarly, the Special Criminal Court issued 23 judgements involving CFAF 38.5 billion. The Budgetary and Financial Disciplinary Council, an administrative authority established by the Prime Minister through decree no. 2008/028 of 17 January 2008 to sanction mismanagement by revenue and expenditure authorising officers, handed down 20 decisions involving CFAF 14.9 billion. In the area of public procurement, 43 companies were excluded. Regarding financial intelligence, the Agence Nationale d’Investigation Financière (ANIF) forwarded 447 reports to the relevant courts and authorities concerning suspicious movements of funds amounting to CFAF 1,665 billion. Finally, the CONAC 2023 Report also listed 9,925 public officials sanctioned [1]. Concerning the Ministry of Defence, risks are not particularly considered in this area. Therefore, in the 2022 CONAC report (the most recent), the activities of the Ministry of Defence are absent. Nonetheless, some sovereign ministries such as the General Delegation for National Security (DGSN), the Ministry of Justice (MINJUSTICE) and the Ministry of External Relations (MINEREX)[2] have submitted summaries of their antcorruption activities to CONAC.
0 / 100
There are no specific corruption risks assessments in the MINDEF, so this indicator is marked as Not Applicable.[1]
NA
There are no specific corruption risk assessments in the MINDEF, so this indicator is marked as Not Applicable.
In the country, majority of colonels and generals continue to be millionaires (in pounds), despite their official salaries being less than 2000 pounds per month. Therefore, it is clear that the results of the corruption risks assessment are not genuinely taken into account. It seems Cameroon has produced formal documents, undertaken activities and established institutions against corruption solely to meet international requirements, but with no real political will to implement them. It appearss to be moreabout aligning with international standards rather than genuinely overhauling its internal systems to combat corruption.[1] As far as the Ministry of Defence is concerned, its core responsibilities contributes to a lack of consideration for anti-corruption mechanisms, especially given its minimal participation in this body. The charges against former Defence Minister Alain Mebe Ngo’o, namely corruption, aggravated money laundering and taking an interest, have been widely publicised in the media and reflect the large scale misappropriation of public funds. This major corruption case, which also seems to be political, is fraught with multiple issues. The former defence minister was sentenced before the Special Criminal Court to 30 years in prison in 2019; his wife Bernadette Mebe Ngo’o to 10 years; Maxime Leonard Mbangue, Treasury inspector and former technical adviser to the Ministry of Defence, and Colonel Elie Mboutou, a former close associate of Mebe Ngo’o, were sentenced to 25 years.[2] CONAC’s role is limited to making proposals and cannot fully address sensitive state issues.[1][2]
NA
Cote d'Ivoire
There is no information to indicate that corruption risk assessments are carried out within the Ministry of Defence [1] [2].
0 / 100
No risk assessment has been carried out, so this indicator is marked as not applicable. [1] [2]
NA
No risk assessment has been carried out, so this indicator is marked as not applicable. [1] [2]
NA
Ghana
The GAF’s Department of the Inspector General is responsible for conducting risk assessments pertaining to the armed forces. The Chief of Defence Staff (CDS) hold the mandate to direct the Department of the Inspector General to conduct probes into human rights abuses, fraud, corrupt practices, and administrative infractions within the various units and departments of the GAF, as part of its core mandate. The work of the Department of the Inspector General is, however, restricted to the consumption of senior-level military operatives and the MOD. There is particular emphasis on the Army by the Office of the Inspector General while that of the MOD is governed by overral government oversight institutions. (1) (2) (3)
75 / 100
There are no fixed periods for the conduct of risk assessment by the office of the Inspector General’s Department of GAF; the frequency of the conduct of risk assessment may be dependent on the interest of the CDS, while other compelling issues that require risk assessment as a result of administrative and civil infractions may lead to a call for risk assessment of a particular department or unit within the GAF. (1) (2) (3)
0 / 100
There is a restriction on the outcomes of risk assessments, which makes it difficult to determine if these assessments contribute to the formulation of anti-corruption policies. Furthermore, GAF does not have any significant anti-corruption policies that an assessment could potentially influence. (1) (2) (3)
0 / 100
Kenya
EACC has developed a comprehensive Corruption Risk Assessment (CRA) methodology for public entities. This methodology promotes integrity, transparency, and accountability in institutional operations by preventing corrupt practices through efficient work methods. EACC supports public entities by providing templates for bribery and corruption risk assessment and mitigation plans [2, 3].
However, there is limited evidence of recent corruption risk assessments. While the Ethics and Anti-Corruption Commission and Ministry of Defence have held several meetings about recruitment-related corruption, this has not included the publication of a sector-specific risk assessment in the past 2–3 years [1].
0 / 100
There exists a document “Public Sector Risk Management Guidelines” in Kenya, specifying that risk management (including risk assessment) should be integrated into entity planning budgets [1]. These are generic, entity‐agnostic guidelines, not specific to MoD or military operations. Moreover, the classified status of these evaluations means that access to this information is strictly controlled and limited to authorised personnel with appropriate security clearances [2, 3].
While the Ethics and Anti-Corruption Commission and Ministry of Defence have held several meetings about recruitment-related corruption, this has not included the publication of a sector-specific risk assessment in the past 2–3 years [3]. Therefore, this indicator is marked Not Applicable.
NA
Kenya’s broader anti-corruption framework, as outlined in the 2024 EACC Guidelines on Corruption Risk Assessment & Management, requires public entities to identify and map bribery and corruption risks to design mitigation plans [1]. The Ethics and Anti-Corruption Commission’s public call for inputs and the companion “Practical Guide” confirm that CRA findings must be built into institution-wide plans, with top-management oversight, defined responsibilities, budgets, and continuous feedback mechanisms [2].
However, the guideline is not defence-sector specific, and it does not show that the Ministry of Defence has used that guideline in a recent CRA publication. There is neither public, recent, defence-sector specific published risk assessment nor available documents confirming these as inputs into anti-corruption policy development [2]. Therefore, this indicator is marked Not Applicable.
NA
Liberia
There are no regular assessments carried out in the defence sector.[1] Concerns about national security have been used to circumvent the process of audits and assessments. Also, the lack of proper understanding of the law has also inhibited adequate assessment of the sector.[2] For example, early in 2024, after the Unity Party-led government came to power, the President called for the audit of the National Security Agency. The decision to audit the NSA was later rescinded. The President’s decision to rescind the audit of the NSA was interrupted as an attempt to protect a few individuals. However, an interview conducted revealed that the law establishing the NSA prohibits the General Auditing Commission from auditing the NSA without the Inspector General of the NSA, as explained above, by conducting an initial round of assessment.[3][4]
0 / 100
Risk assessments are not conducted; this sub-indicator is marked Not Applicable.[1][2][3][4]
NA
Risk assessments are not conducted; this sub-indicator is marked Not Applicable.[1)][2][3][4]
NA
Madagascar
The Internal Anti-Corruption Policy of the MOD applies to the military administration which includes, in particular, the central services of the Ministry of National Defence, the armies as well as the organizations attached to the Ministry of National Defence.[1]. All departments of the ministry are therefore subject to risk assessment. Furthermore, the Ministry of defence has clearly identified the sectors at high risk in terms of corruption (particularly with regard to recruitment). [2].
100 / 100
According to its “Internal Anti-Corruption Policy” Plan, the Ministry of Defense plans periodic reports and in particular an annual report on the implementation of its anti-corruption action plan in the defense sector [ 1]. It is therefore up to senior officials and military executives, at all levels of military administration, to be guarantors of management that extremely reduces the possibilities of corruption. They have particular responsibility for identifying the nature and level of risks to which activities and resources are exposed. Thus, the annual report on the fight against corruption is supposed to have a risk assessment [2].
100 / 100
In its “Internal Anti-Corruption Policy” Plan, the Ministry of Defense expects to capitalize on experiences in the fight against corruption [1]. Any act of corruption is thus recorded and a report is sent to higher military authorities and the Anti-Corruption Unit. Reports relating to acts of corruption are analyzed and recommendations can be issued. It is the responsibility of the Monitoring and Evaluation Division to prepare an annual report on corruption presenting the results of activities in the area as well as any proposals for improvement in this area [2].
100 / 100
Mali
There is no record of any specific corruption risk assessment that has been commissioned or conducted in the past 2-3 years. Worse, the environment appears to make control, audit, or evaluation of the defence and security sectors nearly impossible, due to the exclusion of almost all sector expenditure from the standard framework for considering of confidentiality or protecting national interests.[1][2]
0 / 100
No risk assessment is carried out, this sub-indicator is marked as not applicable.[1][2]
NA
No risk assessment is carried out, this sub-indicator is marked as not applicable.[1][2]
NA
Mozambique
The assessments of the General Inspectorate of Defence have focused on the inspection of Human Resources; Inspection of Material Resources; Inspection of Financial Resources; and Operational Inspection [1]. In recent years, there has been no inspection focused on risks of corruption in the Armed Forces [2]. In 2022, the Chief of Staff of the Armed Forces, Admiral Mangrasse, interrupted a military training course due to suspicions of corruption in the recruitment of young men, but the results and disciplinary proceedings have not been made known [3]. The inspection cases for corruption in the Defence and Security Sector, the results and respective disciplinary processes have not been in the public domain. The leaders of the Defence and Security Forces have spoken about corruption cases, but in interaction with the media.
0 / 100
No corruption risks assessment are conducted in the defence sector so this indicator is marked Non Applicable [1, 2, 3].
NA
No corruption risks assessment are conducted in the defence sector so this indicator is marked Non Applicable [1, 2, 3].
NA
Niger
No corruption risk assessments have been conducted in the Ministry of defence or the Ministry of Interior. [1][2]
0 / 100
Risk assessments were not conducted, the section is left as not applicable. [1][2]
NA
Risk assessments were not conducted, the section is left as not applicable [1][2]
NA
Nigeria
Nigeria National Anti-Corruption Strategy – NACS (2022-2026) provides a government-wide anti-corruption posture that should apply to Ministries Departments and Agencies (MDAs). It provides that a Strategy/Change Management Committee (SMC) should be established in each MDA to drive the implementation of provisions of the NACS [1]. Efforts at tackling corruption in the ministry of defence (MOD) is anchored by the Ministry’s Anti-Corruption and Transparency Unit (ACTU) [2]. There is no available record showing that ACTU has initiated any defence-specific assessment of corruption risk has been commissioned or taken place in the last 2-3 years despite requirement by the NACS that such assessments should be carried out. This could partly inform the recent call by the Independent Corrupt Practices and Other Related Offences Commission (ICPC) for proper synergy among armed forces and para-military agencies to the stem the tide of corruption in Nigeria [3].
0 / 100
Risk assessments are not considered by the ACTU, therefore, this indciator is scored Not Applicable.[1]
NA
Risk assessments are not considered by the ACTU, therefore, this indciator is scored Not Applicable.[1]
NA
Senegal
There are assessment of risks done by specialised institutions like OFNAC, however, the Ministry of Defence only does assessment when there are allegations of corruption within the security forces or in the defence area. The role of the Directorate of Military Justice is to assist the Minister in charge of the Armed Forces in the exercise of his prosecutorial powers in matters of military justice. [2] There have been general corruption risk assessments but no official defence-specific corruption risk assessments have been commissioned or carried out in recent years. [1]
0 / 100
There have been general corruption risk assessments but no official defence-specific corruption risk assessments have been commissioned or carried out in recent years so this indicator is marked as Non Applicable. [1] [2]
NA
There have been general corruption risk assessments but no official defence-specific corruption risk assessments have been commissioned or carried out in recent years so this indicator is marked as Non Applicable. [1] [2]
NA
South Africa
The Department of Defence identifies Enterprise Risks as part of its Annual Performance Plans with the prevalence of fraud and corruption identified as an ongoing risk along with mitigation measures including the implementation of the departmental Corruption and Fraud Prevention Plan and in the 2024 Annual Performance Plan, the preparation of a departmental Ethics Strategy. [1] Likewise the departmental Audit Action Plan identifies integrity risks and mitigation measures to strengthen the financial control environment. [2] Risks are, however, identified at the ministerial level rather than individual divisions.
75 / 100
Under the Public Financial Management Act, South African departments are required to regularly conduct departmental risk assessments and prepare a risk management strategy. [1] The Department of Defence prepares an Entreprise Risk Management framework in each Annual Performance Plan and report on implementation of the framework in the Department’s Annual Report. [2]
100 / 100
As guided by the Public Financial Management Act, departmental risk management strategies must include a fraud prevention plan to direct internal audit efforts and corruption prevention. [1] The Department of Defence is likewise audited annually by the Auditor-General of South Africa and based on these findings, a departmental Audit Action Plan is prepared in consultation between the Auditor-General and the Department’s Internal Audit Unit. [2] Implementation of Audit Action Plans and the Corruption and Fraud Prevention Plans, however, fall short of their intended aims as evidenced by recurrent audit findings including inadequate record keeping and a lack of consequence management of transgressions of financial processes.
50 / 100
South Sudan
A review of media sources [1] and publicly available government reports, along with consultations with a scholar [2], an officer at the National Legislative Assembly [3], and an SPLM officer [4], did not identify any documented corruption risk assessment conducted within the defence sector in the past two to three years.
0 / 100
A review of media sources [1] and publicly available government reports, along with consultations with a scholar [2], an officer at the National Legislative Assembly [3], and an SPLM officer [4], did not identify any regular defence assessment for corruption risk conducted in the last two to three years. Thus, this indicator is marked as Not Applicable.
NA
A review of media sources [1] and publicly available government reports, along with consultations with a scholar [2], an officer at the National Legislative Assembly [3], and an SPLM officer [4], did not identify any defence sector corruption risk assessment conducted in the past two to three years. Additionally, there was no evidence indicating that findings from such an assessment, if conducted, were incorporated into an anti-corruption policy. Thus, this indicator is marked as Not Applicable.
NA
Uganda
The Office of the Auditor General (OAG) publishes annual audit reports on MoDVA, which identify financial irregularities such as unsupported expenditures, poor contract management, and failure to adhere to procurement procedures. For instance, the most recent OAG report for the financial year 2024 highlights several irregularities within the MoDVA such as: “1) The Ministry’s work plans and budgets were not appropriately quantified and costed to enable assessment of implementation of planned activities; 2) at the time of inspection in October 2024, which was four years after the expected completion date of the UPDF National Referral Hospital, the project was not complete, with stalled works in some areas”, among others [1]. However, these findings are framed within the context of financial compliance and do not constitute a full assessment of corruption risks.
While the Inspectorate of Government has a mandate to conduct corruption risk assessments, there is no public record of recent, systematic corruption risk assessments targeting MoDVA or the UPDF. Apart from government institutions, other non-state actors have been involved in carrying out corruption risk assessments. These are the Anti-Corruption Coalition of Uganda and the World Bank and other development partners [2]. While external oversight institutions have conducted partial assessments, they do not clearly articulate risks for the ministry or armed forces.
50 / 100
The Internal Audit Department of the Uganda People’s Defence Force (UPDF), the Office of the Auditor General, and the Public Procurement and Disposal of Public Assets Authority conduct risk assessments of the Ministry of Defence and Veterans Affairs (MoDVA) annually. A board of survey exercise is conducted annually by the office of the Accountant General.[1] The Department of Finance and Administration collaborates with internal and external auditors to review financial processes and identify areas for improvement. The Department of Finance and Administration provides oversight to ensure that procurement processes adhere to the necessary regulations and transparency standards.[2]
The Ministry of Finance website remains a valuable repository of publicly accessible information on financial management, administration, and policy guidelines. This broader context, while not directly addressing corruption risks within the defence sector, helps illustrate the financial mechanisms and oversight structures in place.
75 / 100
The UPDF’s Defence Policy provides guidelines for an efficient financial management system, which ensures appropriate control and oversight, in line with public sector procedures.[1] The Department of Finance and Administration within the Ministry of Defence and Veteran Affairs of the Republic of Uganda is a critical component responsible for the financial management and administrative functions of the ministry. This department plays a pivotal role in ensuring that financial resources are allocated efficiently and transparently to support the various defence and veteran affairs initiatives.[2]. However, it was not possible to establish whether or not the findings of the assessments were used to update the anti-corruption policies.
50 / 100
Zimbabwe
There is no risk assessment for the defence forces sector [1,2].
0 / 100
There is no risk assessment for the defence forces sector. Therefore, this indicators is marked Not Applicable.[1][2]
NA
No corruption risks assessment are conducted in the defence sector and there is no anti-corruption policy. Therefore, this indicators is marked Not Applicable.[1][2]