Q18.

Is there evidence that the country’s defence institutions have controlling or financial interests in businesses associated with the country’s natural resource exploitation and, if so, are these interests publicly stated and subject to scrutiny?

18a. Legal framework

Score

SCORE: 0/100

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18b. Defence institutions: Financial or controlling interests in practice

Score

SCORE: 75/100

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18c. Individual defence personnel: Financial or controlling interests in practice

Score

SCORE: 100/100

Assessor Explanation

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18d. Transparency

Score

SCORE: 0/100

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18e. Scrutiny

Score

SCORE: 0/100

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Relevant comparisons

A review of the legislation on armed forces and of the legislation that regulates various natural resource sectors shows that there are no specific restrictions or prohibitions for defence and security institutions regarding the exploitation of natural resources [1, 2, 3].
Some laws govern various resource sectors such as the hydrocarbons, mineral sector, water resources, by defining ministerial responsibilities [4, 5], but there is no overarching legislation that guarantees the exclusion of the MoD from the involvement in natural resource exploitation. The areas of responsibility the ministries have are defined by the Council of Ministers when new governments are formed [6, 7], while the definition in the laws of “responsible ministry” means that the government has the formal authority to decide the allocation of responsibilities to the MoD.

Although there is no explicit legal ban, there are no cases of the defence and security institutions being involved in businesses related to the exploitation of Albania’s natural resources [1, 2]. Except for a brief period in the late 1980s, when the defence sector was involved in the exploitation of chromium ore and medicinal plants, this has not been the case in Albania, the practice lasted for only two to three years and was terminated with the collapse of communism [1]. As a result, there is no body of legislation or practice on the scrutiny and control of this type of activity by the defence and security sector.

There is no evidence that proves the engagement of individual defence personnel in businesses related to the country’s natural resource exploitation.

This indicator has been marked Not Applicable. There are no cases of the defence and security institutions being involved in businesses related to the exploitation of Albania’s natural resources [1, 2].

This indicator has been marked Not Applicable. There are no cases of the defence and security institutions being involved in businesses related to the exploitation of Albania’s natural resources [1, 2].

There is evidence that individuals of the armed forces are prohibited from having control over or financial interests in businesses associated with the country’s natural exploitation. However, the legal restriction refers to businesses in general and not natural resources specifically. Art. 34 of the Statute of Military Personnel states that it is prohibited for military members to engage in any private gainful activity in any capacity and of any kind (1).

The armed forces are formally involved in the energy policy of the country. The Minister of Defence is present at the National Energy Council, which is the supreme body on energy strategy and headed by the President of the Republic (2). Even though it should meet periodically, the Council has not been active for years (3).

Defence institutions are likely to have financial and controlling interests in businesses associated with Algeria’s natural resources and considering the answer to question 18A, it seems to be illicit (see the country’s last assessment, 5). Algeria is rich in oil and gas reserves, which are vital to the state. For example, revenues of the biggest African oil company Sonatrach amounts to 95% of Algeria’s external revenues and 60% of the budget. The company, therefore, belongs to the pillars of power (1). It is very difficult to find information on this issue and to distinguish between institutional and individual interests. Reports suggest that the DRS influences the appointment process of Sonatrach (2) (5). In the past (2009 and 2010), corruption scandals linked to Sonatrach also were interpreted as turf battles between official and the intelligence services (4, p. 3), suggesting that the intelligence service has a controlling interest in the company. Moreover, Algeria’s elite, including the military, reportedly profits from incomes of the energy sector. The former Vice-President of Sonatrach wrote that at least 5 to 6 billion dollars (some even speak of 10) of the energy sector, go into the pockets of the members of the nomenklatura annually (3).

As has been outlined in the country’s last assessment (4) and in the answers to question 18A and 18B, financial and controlling interests of individual defence personnel are likely widespread and illicit. It is however very difficult to find information about it. The national intelligence agency is reportedly involved in the appointment process of the state energy company Sonatrach (1). The current CEO of the company is considered to be a protégé of the DRS (2). Former Vice-President of Sonatrach Hocine Malti noted that at least 5 to 6 billion dollars, maybe even 10 billion dollars, of the energy sector go into the pockets of the members of the nomenklatura annually (3).

No evidence could be found that interests of the defence institution and individuals are publicly declared and transparent. Information found on the economic activities of the armed forces did not include the energy sector (1). An article published by the armed forces on energy issues did not mention any interests (2).

No evidence could be found that either parliament (1) (2) or the Court of Auditors (3) scrutinize these interests.

There do not appear to be formal restrictions for defence institutions to engage in or benefit from private businesses. The Public Probity Law prohibits individual public servants from engaging in private business activities that may constitute a conflict of interest, though the involvement of senior officials of the military and the presidency (SBP) in private businesses have been the norm. These businesses include exploration of natural resources, such as diamonds and oil, and presumably other natural resources (such as timber, gold and other precious metals) (1), (2), (3).

There is little evidence of direct involvement of defence institutions in natural resource exploration; however, that does not mean it does not exist. A 2017 Maka Angola report states, “the State Intelligence and Security Service (SINSE) sent the head of state information on illegal mining activities in the Cosse areas on the banks of the Luembe River, in the Nzagi district of Lunda Norte province, which involves the Military Intelligence and Security (SISM). For some time now, General Zé Maria has dedicated efforts to the creation of a cooperative for the exploitation of diamonds, in order to generate income parallel to the General State Budget for the SISM working capital. In Cabinda, General Zé Maria has engaged the SISM in the wood exploitation as part of its business efforts to maintain the said working capital without recourse to the OGE” (1).

There is evidence, though, of the involvement of individual senior military officials in natural resources exploration businesses. The involvement of senior military officials in diamond exploration has been well-documented since the 1990s. A recent example, according to Maka Angola, António José Maria, aka “Zé Maria”, the former head of the Military Intelligence and Security Services (SISM), who was forced to retire by President Lourenço in November 2017, had introduced SISM to timber and diamond exploration to give the services more financial autonomy (1), (2), (3), (4).

The involvement of individual senior officials from the Angolan military and the presidency in businesses relating to the country’s oil exploration has been well documented since the civil war and was confirmed again in recent investigative work on the Panama Papers (1), (2), (3), (4), (5).

Private business interests of senior officials are rarely publicly declared and commonly
concealed using little known employees or family members who appear in the business ownership declaration in the official gazette, or shell companies [1]. Ironically, in an unprecedented ruling in May, the Supreme Court ruled that Pedro Januário Macamba, an acquaintance of the former chief of the President’s Civil Bureau José Leitão, was the legitimate owner of the GEMA group, a powerful Angolan business holding company. Pedro Januário Macamba had filed a lawsuit against the group, claiming his signature had been falsified in company documents [1].

Private business interests of senior military officials have been subject to public scrutiny mainly by Angolan investigative journalists, though until recently without a response from the judiciary. Parliamentary scrutiny has been weak, due to its limited powers and its domination by the ruling party (1), (2), (3), (4), (5).

Currently, there is no evidence that Armenia’s defence institutions have controlling or financial interests in businesses associated with the country’s natural resource exploitation [1]. The Law on Defence does not provide restrictions on defence institutions to have controlling or financial interests in businesses associated with the country’s natural resource exploitation [2]. From 2001 to 2010 the Ministry of Defence (MoD) controlled the shares of “Dzorahek” water-power plant, which was illegally privatized [3].

Currently, there is no evidence that Armenia’s defence institutions have controlling or financial interests in businesses associated with the country’s natural resource exploitation [1]. However, from 2001 to 2010 the MoD controlled the shares of “Dzorahek” water-power plant, which was illegally privatized [2].

There is no evidence that individual defence personnel have controlling or financial interests in businesses associated with the country’s natural resource exploitation [1]. According to the Law on the Military Service and the Status of Servicemen (Article 8, clause 7), servicemen cannot personally engage in entrepreneurial activity [2].

This indicator has been scored Not Applicable. There is no evidence that Armenia’s defence institutions or personnel have controlling or financial interests in businesses associated with the country’s natural resource exploitation [1].

This indicator has been scored Not Applicable. There is no evidence that Armenia’s defence institutions or personnel have controlling or financial interests in businesses associated with the country’s natural resource exploitation [1].

There are legal restrictions on defence institutions and individuals having controlling or financial interests in businesses. According to the Law on the Status of Military Servants (Article 23.v), military servants are prohibited from engaging in private entrepreneurial activity, salaried staff positions in cooperatives engaged in production and mediation activities (1).
According to experts, the current legislation in the country prohibits officials from engaging in business. Lawyer Alimammad Nuriyev told Sputnik Azerbaijan that an official cannot deal in business, because of the country’s legislation, it is forbidden (2). However, in practice, many security and defence officials engage in business activities through people who are either close to them or their family members and there is no safeguard provision in the legislation which can prevent the officials from engaging in business activities (3). Various types of control and management systems used in the oil and gas industry are also produced at enterprises operating within the Ministry of Defence’s umbrella (4).

There is not enough informtion to score this indicator. Azerbaijan’s natural resources, and its protection, play an important role in the development of several military institutions in the country. For example, the State Border Service has grown significantly in recent years and has been reinforced in terms of staffing and technical support. The reason for this is the protection of oil and gas deposits in the Caspian Sea (2). State Border Service and the Navy’s military personnel sometimes conducting military training in the Caspian Sea.However, this training or similar ones are undertaken as part of their duties and are unconnected to having financial interests in businesses associated with the country’s natural resource exploitation.

There is not enough information to score this indicator. This is because it’s currently difficult to ascertain whether there are MoD personnel involved in natural resource exploitation activities. Years ago the media occasionally published articles on the participation of senior officials of the Defence Ministry and other military structures in various businesses. But in recently, information on this topic has dropped considerably. The main reason for this is increased pressure on media and limited research opportunities (1).
For this reason it is difficult to directly ascertain whether there are defence personnel involved in natural resource exploitation activities; there are widespread reports about corruption issues, but there is a lack of reporting about military involvement or business interest in natural resource exploitation. There may or may not be isolated cases of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation.

According to the law, officials from the Defence Institutions cannot engage in business activities (1). At the same time, there is no transparency in this direction. Military structures have not made any statement on this issue. However, the public is well aware of the fact that most of the people in the defence institutions are engaged in business activities (2). At the same time, there is no information on the involvement of state bodies in business activities related to the exploitation of natural resources (3).

The issue of “involvement of defence agencies in the businesses relating to the country‘s natural resource exploitation” is not discussed either by the parliament or by the public (1). This topic is very closed and it is almost impossible to get information about it. The parliament has not yet carried out any investigations or scrutiny on this issue (2).

Article 13 of the Law on Defence of Bosnia and Herzegovina prescribes all the competences of the Ministry of Defence and accordingly to the listed Article, no provisions authorise the MoD to have any kind of control or financial interests in businesses associated with the country’s natural resource exploitation [1, 2].

Article 13 of the Law on Defence of Bosnia and Herzegovina prescribes all the competences of the Ministry of Defence and accordingly to the listed Article, no provisions authorise the MoD to have any kind of control or financial interests in businesses associated with the country’s natural resource exploitation [1, 2].
There are no known cases of defence institutions engaging in businesses relating to natural resource exploitation.

As explained in 18A, there is no legal basis for military personnel to be involved in any kind of control or exploitation of natural resources [1]. As such, military personnel cannot be active within the field of control or exploitation of natural resources in any capacity. There are also no known cases of individual defence personnel to be involved in businesses relating to natural resource exploitation.

This indicator has been marked Not Applicable. Article 13 of the Law on Defence of Bosnia and Herzegovina prescribes all the competences of the Ministry of Defence and accordingly to the listed Article, no provisions authorise the MoD to have any kind of control or financial interests in businesses associated with the country’s natural resource exploitation [1, 2].

This indicator has been marked Not Applicable. Article 13 of the Law on Defence of Bosnia and Herzegovina prescribes all the competences of the Ministry of Defence and accordingly to the listed Article, no provisions authorise the MoD to have any kind of control or financial interests in businesses associated with the country’s natural resource exploitation [1, 2].

Defence institutions are by law prohibited from having a controlling or financial interest in business associated with natural resource exploitation. According to Article 33 of the Law N° 038 (2016) does not allow personnel to have interests in a private enterprise, nor hold a position or a private lucrative activity whatsoever for themselves or through people with other denomination. Also, Article 40 and 156 of the Law N° 081 (2015) prohibits holding any commercial interest in private companies.

There is no evidence connecting the country’s defence institutions to financial interests in businesses related to the country’s natural resources exploitation. However, given the high level of corruption in the country and the long-serving past regime, chances are great that some defence institution had some degree of control and financial interests in business associated with the exploitation of the natural resources of the country. Burkina Faso is known for being the fourth gold exporter country, after Ghana, South Africa and Mali (1), with about “US$2.5 billion worth of goods around the globe in 2016” (2). In the absence of evidence, this widespread gold exploitation could have driven defence institutions’ controlling and financial interest in business associated with the exploitation of natural resources. In addition to gold, the other natural resources of the country constitute zinc in exploitation at Perkoa, and manganese at Tambao. To mitigate the risk of widespread corruption the country acquire status with the Extractive Industries Transparency Initiative (EITI) since 2018. ITIE is known as an internal standard of good governance in extractive industries; it monitors the revenues that the government collects with each of existing gold companies across the territory (3).

The law prohibits any involvement of individual defence personnel in business relating to the country’s natural resource exploitation (1), (2). Complying with the military code of conduct and discipline is required in the defence institutions; any violation causes serious sanctions (3). Controlling or having financial interests in businesses associated with natural resource exploitation, is incompatible with the military, which is, by nature impartial, seeking common interests instead. As such, there is no evidence of involvement of defence personnel in businesses related to the country’s natural resource exploitation, and it would be considered illegal according to the law.

If there are some isolated cases of interests of the defence personnel in the country’s natural resource exploitation, these interests are not publicly declared, as they generate from illicit activities. The law on the status of the defence personnel prevents personnel from engaging in any commercial activity. Any personnel found guilty are immediately prosecuted and sent to prison and/or subject to payment of a considerable fine. When prosecution results in a penal sanction, it could result in a dismissal from the armed forces, if the sentence is more than 45 days (1). According to Burkina Faso’s penal code, funds resulting from illicit activities are not transparent and are more likely to nurture money laundry. Since defence personnel’s interests in natural resources exploitation do not comply with the law, the funds generated from having an interest in natural resource exploitation consequently become non-transparent (2), (3), (4).

There evidence found for scrutinizing the MoD or its personnel for involvement in the natural resource business. The Constitution grants power and legitimacy to the Court of Accounts and the Higher State Supervisory Authority/Fight Again Corruption (ASCE-LC) to scrutinize the national budget allocated to government institutions for their activities (1), (2). Therefore, interests resulting from businesses related to natural resource exploitation do not fall under any work of scrutiny. Further, as law enforcement institutions, the Court of Accounts and the ASCE-LC, would more likely apply sanctions for having such interests gained out of any legitimacy rather than seeking to scrutinize them (1),(3), (4), (5).

There is no evidence of any law that prohibits defence institutions from getting involved in any business transaction.

According to the Japan Times, “The local press says the Cameroonian elite — including generals, colonels, lawmakers, ministers and a nephew of President Paul Biya — hold mining permits, but it is impossible to confirm the information … ‘The army protects the Chinese at all their mining sites to the detriment of nearby communities and it participates in intimidating them and racketeering,’ said one activist, who asked not to be named” [1].

The Extractive Industries Transparency Initiative states that “Cameroon published its beneficial ownership roadmap on 22 November 2016. Of the 17 companies in its 2015 EITI Report, six were either state-owned or publicly listed. Of the remaining eleven companies, five disclosed comprehensive information on their beneficial owners” [2] [3] [4].

According to the Japan Times, “The local press says the Cameroonian elite — including generals, colonels, lawmakers, ministers and a nephew of President Paul Biya — hold mining permits, but it is impossible to confirm the information … ‘The army protects the Chinese at all their mining sites to the detriment of nearby communities and it participates in intimidating them and racketeering,’ said one activist, who asked not to be named” [1].

According to the Japan Times, “The local press says the Cameroonian elite — including generals, colonels, lawmakers, ministers and a nephew of President Paul Biya — hold mining permits, but it is impossible to confirm the information” [1], meaning mining ownership is not transparent.

There are no mechanisms put in place to scrutinise such interests [1] [2].

There is no evidence of any legal prohibition against defence institutions (MoD structures) or individuals having financial interests in natural resources or extractive industries.

Illicit trafficking in natural resources and commodities (minerals, coffee/cocoa, timber, cotton, cashews and petroleum) is being carried out by former rebel leaders of the Forces Nouvelles (FN) and is completely non-transparent. However, this does not mean that defence institutions themselves have controlling or financial interests in such trafficking flows. It is individual members of the armed forces, including some residing in Abidjan, who have such controlling stakes.

According to a September 2017 report by the French-based OFPRA (Office français de protection des réfugiés et apatrides), UN experts calculated that up to 10% of the cocoa production around the towns of Man, Séguél and Vavoua were exported through Togo and sold to multinationals via the Port of Lomé. This production was controlled by local warlords. After the post-electoral crisis of 2010-2011, the COMZONES switched from trafficking in cocoa to trafficking in gold and diamonds (1). Citing a later UN expert study on natural resources trafficking in Côte d’Ivoire, the OFPRA report states that the chain of command in the illicit trade of gold, diamonds and cocoa (and of their involvement in artisanal mining) led to high-ranking members of the armed forces who were not only local warlords but also residing in the economic capital of Abidjan (1). In its April 2015 report, the UN Panel of Experts noted that trafficking in gold, diamonds and cocoa has remained active since the end of the crisis. The UN Panel has gathered information from multiple reliable sources indicating that the chain of command authorizing the artisanal and illegal mining of gold leads to important members of the security forces of Côte d’Ivoire in Abidjan. These individuals or their associates have set up a gold trade mechanism that includes the concession of land allotments for the purpose of the exploitation and sale of gold.

It is important to point out that defence institutions (MoD) are not directly involved in this kind of illicit activity. The government is attempting to put an end to this practice, in part via juicy early retirement schemes destined to high-ranking military officers foreseen by the current Loi de Programmation Militaire (LPM 2016-2020). According to the September 2017 report by the French-based OFPRA, half of the reforms that Côte d’Ivoire committed to in the process known as the Réformes du Secteur de Sécurité (RSS, DDR), which began in 2013, have not been honoured, including the reintegration of former rebels. Many of them are involved in illicit commodity trade that provides them and their troops with significant annuities. The OFPRA report names the COMZONES and the areas under their control. (1)
They include the following high-ranking officers: Morou Ouattra (known as Atchengué), Hervé Toure (known as Vetchio), Ousmane Cherif, Tuo Fozie, Messamba Kone, Zoumana Ouattara, Issiaka Ouattara (known as Wattao), Losséni Fofana, Daouda Doumbia, Ousmane Coulibaly, Gaoussou Kone, Martin Fofie and Zakaria Kone.

The natural resources controlled locally by COMZONES not only provide a supplementary income but also allow the former rebel leaders to perpetuate internal conflict, as occurred in January and May 2017 with the soldier uprisings in Bouaké and other towns. The sale of minerals (gold, diamonds) and the local management of trade in cocoa and coffee beans, as well as cotton and timber, even extends to the petroleum sector:

“Since the beginning of the political-military crisis in Côte d’Ivoire, the control of raw materials – and in particular the management of the coffee and cocoa sectors – has served to finance armed groups and militias of the rebellion as well as the central government. The same level of opacity exists for revenues from the exploitation of oil. The rebel leaders enriched themselves considerably during the ten years of crisis. They benefited from the exploitation of cocoa, coffee, wood, cotton, gold and diamonds. They also took over control of companies, collected high taxes on road networks and via utilities, and they admit to having done these things.”

A March 2016 IFRI report by Aline Leboeuf addresses the trafficking practices of Issiaka Ouattara (known as Wattao) in the region of Séguéla:

“While few COMZONES have been sanctioned by the UN Security Council, and none are currently being pursued by the International Criminal Court, the reports by the UN Panel of Experts on Côte d’Ivoire established in application of § 27 of Resolution 2153 (2014) exposed the types of informal parallel economy that some COMZONES managed to put in place in order to exploit the Ivorian resources to their ends…The last report, issued on 13 April 2015 by the Security Council, stresses that “the influence that some former zone commanders exert on the state security apparatus remains problematic”, and again highlights the involvement of Wattao in the trafficking of gold and diamonds and in the illegal taxation of the transportation network” (2).

Jeune Afrique has also carried regular news pieces about regional military warlords and the non-central government income they receive from operating an illicit parallel economy (3).

The interests of the COMZONES in the illicit trafficking of commodities and natural resources are not publicly declared and are entirely non-transparent. The government has sought to filter out the former rebel leaders via early retirement and retraining schemes. According to Jeune Afrique, the reason for tolerating the illicit trafficking by COMZONES is the threat they pose to political stability. Though they are pointed out by international media as guilty of trafficking in gold, coffee/cocoa, as well as of money laundering activities, they are perceived as judicially immune by the public and the MoD. Jeune Afrique cites the case of Martin Fofie in the northern region of Savanes (1). “Master of the capital of Savannah until January 2017, [FOFIE] has since been transferred to Daloa but continues to visit his stronghold of the North on a regular basis. This has led experts to suspect him of laundering money from the gold traffic in the region” (1).

In a separate article, Jeune Afrique cites the case of Issaka Outtara (known as Wattao and with 1,500 troops under his command), who was sent to Morocco for training at the Royal Military Academy of Meknes in 2018 to earn a certificate in security studies in a government attempt to neutralize him (2). “For the second time in less than three years, Wattao has been sent to Morocco, where, in the calm of the prestigious Royal Military Academy in Meknes, he is doing a six-month internship and from where he will return in late May with a degree in security and defense policy. Is it a punitive measure to keep him far away or a rewarding opportunity for training? A bit of both” (2).

Details that prove the opacity of the financial interests of COMZONES in natural resources in Côte d’Ivoire can be obtained from the OFPRA report (3).

The interests of former rebel leaders (COMZONES) in commodities and natural resources are not subject to any kind of public scrutiny due to political sensitivity and the power wielded by local warlords at the regional level. Though their involvement in illicit trafficking and money laundering activities has been reported by international institutions and media, intimidation and the threat of violence stand in the way of heightened public scrutiny of the COMZONES (1), (2), (3), (4).

Our sources have confirmed that the army has an extraordinary monopoly over many of the country’s economic and natural resources. From land, oil, to the sea (fishing) and the use of natural resources (investment in the natural resources) (1), (2), (3). The land is the natural resource where the army has complete control over and widely exploits to their economic and financial benefit. First, the Ministry of Defence can claim any “public” land by declaring it a military or strategic zone (4), (5). In the last few years, there have been many instances where land was granted at no cost to the Armed Forces for commercial purposes. For example, Presidential Decree no. 114 of 2018 allocated about two million square metres in the Fayoum governorate to the military’s National Service Project Organization (NSPO) to be used for animal production (7). Additionally, Prime Minister Decree no. 2428 of 2017 (8) allocated 6000 square metres in the Sohag governorate to the MOD to establish a Wataniya fuelling station. Moreover, Presidential Decree no. 424 of 2017 allocated 8000 feddans to the Armed Forces’ Land Projects Authority (AFLPA) to build modern greenhouses for agricultural purposes (6). These examples are believed to have been pervasive in the last few years despite the lack of aggregate figures on how much land has been given for MOD commercial activities. Other than land the Military also has companies working in the exploitation of bentonite, glass sand, talcum powder, marble, gypsum, sand cauline, limestone, and black sand (9).

The involvement of the armed forces in business activities related to natural resource exploitation, namely land, is pervasive but usually happens legally from laws and decrees issued by the president, prime minister and the minister of defence (1). However, these laws and decrees have mostly been established and issued by military-controlled governments and parliaments, and its “legality” could be considered a clear sign of the capture of state institutions rather than the respect of law (2), (3), (4), (5), (6), (7).

The armed forces as an institution is highly involved in businesses related to natural resource exploitation, there is no evidence, however that defence personnel have financial or controlling interests in their personal capacity as individuals.

According to our sources, the economic interests of the army and its personnel in the natural resources of the country are not usually declared officially (some are). None of the interests are clear. The interests of the army and its personnel are usually declared if there is public attention, but other people (relatives) are used as shadow managers/owners while the real owner is the military or the intelligence services (1), (2), (3), (4). Some of these interests are publicly declared on the websites of the relevant authorities, or through land allocation decrees like those mentioned in 18A, there is little to no information available about their operations, size and profits. The lack of information regarding the degree of involvement of the armed forces in business activity in general and natural resource exploitation, in particular, increases speculation regarding the size of such involvement.

The interests of the military in the economy and natural resources of the country are not subject to any mechanisms of scrutiny or oversight. The head of state, who is the head of the army has the authority to undermine, along with the senior members of the army, any kind of scrutiny or oversight (1), (2), (3), (4). The government, including the current president, have repeatedly asserted that all military economic activity is subject to scrutiny by the supreme audit institution the CAA. The reports and findings of the CAA are not made available to the public. However, in 2014 al-Sisi passed a law to allow himself to remove the directors of supervisory authorities including that of the CAA. Many commentators believed the law was passed specifically to “handle” the then CAA director Hisham Geneina. Geneina was removed from his post after speaking in the media about the size and scale of government corruption and began facing trial for “spreading false news” (5), (6). He also faces a military trial for “defaming the Armed Forces” after supporting the presidential candidacy of Sami Anan against al-Sisi. After Anan was arrested, Geniena threatened to expose top-secrets about the military’s involvement in causing social unrest following the 2011 revolution (7).

In sum, even if formal mechanisms and institutions exist, the type of scrutiny exercised by them is deemed ineffective given the broad mandate and powers of the president and the military courts to restrict these institutions and hunt down their officials. As for the Parliament, it is formally entrusted with “exercising oversight over the actions of the executive power” according to Article 101 of the Constitution, these formal powers are restricted by law which gives the defence sector extensive autonomy in managing its own affairs. The National Defence Council (NDC), for example, led by the president and senior military and security officials must be “consulted” on any law that is related to the Armed Forces or national security, and they are the entity mandated to discuss and develop defence policies, which could be interpreted to include the Armed Forces’ commercial activities (8).

There is no law that specifically states that having controlling or financial interests in businesses associated with the country’s natural resource exploitation is prohibited. The topic is not covered in Estonia at all. One of the reasons could be that the number of state-owned companies is relatively low in Estonia – the state had shares in only 29 companies in 2018, none of them under the Ministry of Defence. [1] There is only one law that overlaps environment with the defence sector: according to the Nature Conservation Act, [2] it is prohibited to engage in economic activities and start new construction works in conservation zones. However, this law has exceptions for the defence sector. For “national defence purposes” construction of a road, utility works or non-production construction works are allowed. The same act stipulates another exception for the defence sector: the building ban near shores and riverbanks do not apply to construction works for national defence. With some exceptions for defence, exploitation of natural resources is an illegal activity under the Constitution. According to the State Assets Act, state assets must be administered sustainably and prudently. An administrator of state assets must carry out any transactions with state assets in conformity with the legislation and in a transparent and verifiable manner. [3]

According to an expert’s analysis (Merili Vipper has both worked in as well as written her thesis on the field), the biggest risk to Estonia’s natural resources from the Defence Forces is their activities in the exercise fields. If the environmental requirements are not strictly followed, their activities can cause pollution, destroy vegetation and contaminate soil and groundwater. [1]
On the other hand, Estonia’s defence sector does not have financial or controlling interests in businesses associated with the country’s natural resource exploitation. In 2017 there were no companies that belonged to the Ministry of Defence. As exceptions, there were two foundations: Riigikaitse Edendamise SA and SA Rahvusvaheline Kaitseuuringute Keskus. The first supplies defence institutions with information technology and know-how, the second is a leading think-tank. [2] The latest example of a company operating under the Ministry of Defence was OÜ E-Arsenal, closed in 2013. It was created as a defence industry export organisation. [3]
Based on the analysis of different Ministry of Defence’s ownerships, it can be concluded that there is no exploitation of natural resources. Reports on state ownership identify no such cases either. [4]

Until July 2018 active public servants were not allowed to conduct business activities in Estonia. [1] However, the situation is different with the Defence League, because this military organisation’s membership is voluntary. This means that the members come with different backgrounds and interests, including business. At the same time, the members’ names are not made public, so it is not possible to determine whether they have financial or controlling interests in natural resource exploitation. [2]
In terms of natural resources, for example, chopping wood in exercise fields is one of the grey areas, but the legislation makes exceptions for defence personnel when it comes to wood, and thus, cutting wood in the exercise fields is a legal act. [3] Finally, there is no evidence of the defence personnel having any financial or controlling interests when it comes to natural resources. [4]
There have been no court cases involving military or ex-military personnel and the exploitation of natural resources in the past three years. [5]
The use of natural resources is being scrutinised by the environmental department at the Centre for Defence Investment under the Ministry of Defence and the Environmental Inspectorate under the Ministry of Environment. [6]

This indicator has been marked Not Applicable. As there have not been any cases identified, this question does not apply to Estonia’s current situation.

This indicator has been scored “Not Applicable” as there are no cases of defence institutions being involved in businesses related to natural resources exploitation.

If such interests were to appear, there is an oversight procedure in place. The Ministry of Finance exercises oversight of state assets. [1] General principles of managing state assets are regulated by the State Assets Act, [2] which stipulates that each year, reports must be submitted to the Ministry of Finance concerning attainment of the aims set to the foundation and the exercise of the founder’s rights. In addition, the Ministry of Finance is entitled to request information and documents concerning acquisition of assets and acceptance of assets for state use, and concerning administration of state assets. The government is allowed to conduct on-site inspections in order to check the accuracy of the information. When infringements are discovered, the Ministry of Finance can make recommendations concerning elimination of those infringements or the performance of other necessary operations. However, environmental issues and overseeing that the correct procedure is in place when it comes to environment protection seem to be less important in the defence field. In 2016, the environmental protection specialist position was eliminated from the Estonian Defence Forces. [3]

Having an interest in businesses associated with the exploitation of natural resources is prohibited by the Constitution [1]. Moreover, there is no evidence in the media or reported by NGO’s of resource exploitation. The Supreme Audit Office (SAO) and the Group of Confidence (GC) monitor these issues, but there is no indication of controlling businesses of natural resources exploitation by the Ministry of Defence (MoD) [2, 3].

There are no cases of defence institutions being involved in businesses relating to the country’s natural resource exploitation reported in the media or NGO reports. The SAO and GC monitor these issues, but there is no indication of controlling businesses of natural resources exploitation by the MoD [1, 2].

Cases of involving MoD personnel in businesses related to natural resource exploitation has not observed in the media or NGO reports. The SAO and the GC monitor these issues, but there is no indication of controlling businesses of natural resources exploitation by MoD personnel [1, 2].

This indicator has been scored “Not Applicable” as there are no cases of defence institutions being involved in businesses relating to the country’s natural resource exploitation.

Declaration of financial and property issues, including engagement in the business, are regulated, but the law [1] and top and middle MoD managers are obliged to annually declare their financial or property information, including information related to their family members’ assets. The CSB has the mandate and competence of monitoring the process of asset declaration [2, 3, 4].

This indicator has been scored “Not Applicable” as there are no cases of defence institutions being involved in businesses relating to the country’s natural resource exploitation.

Monitoring interests are subject to SAO, GC and Civil Service Bureau (CSB) scrutiny that explicitly analyses the potential for impropriety. The relevant laws ensure the transparency of this process [1, 2, 3, 4].

There are no restrictions on defence institutions having control or interests in businesses associated with the country’s natural resource exploitation (1), (2), (3). Art. 210 (3) of the Constitution allows the armed forces to perform “other functions for the development of Ghana as the President may determine” (4).

There is no evidence that defence institutions have financial stakes in natural resource extraction. They protect mining sites within the framework of military operating procedures. These sites are considered areas of strategic national importance, and therefore often have military, as well as private, protection.

Defence institutions are involved in several other businesses through the “Industry of Defence Industries Holding Company (DIHOC) Limited,” but none of these activities are related to the country’s natural resource exploitation (1), (2).

Following research into the mainstream Ghanaian media (Modern Ghana, Myjoyonline, GhanaWeb, Ghana News Agency, Graphic Online) no evidence of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation was found. To reduce risks of corruption in the natural resource exploitation industry, Ghana established the Public Interest and Accountability Committee (PIAC). The PIAC is an independent body mandated to promote transparency and accountability in the management of petroleum revenues in Ghana. The PIAC did not denounce, in its annual reports, defence personnel’s involvement in businesses relating to Ghana’s natural resource exploitation (1).

However, there are unverified suspicions that some military personnel assigned to protect mining sites are involved in natural resource exploitation for illegal or unofficial pecuniary benefits, which involves both individual commanders and to some extent the institution (2), (3), (4), (5).

There is no evidence of the involvement of the armed forces in the country’s natural resource exploitation (1), (2), (3), (4). As a result, this indicator is marked Not Applicable.

Defence institutions’ involvement in businesses is channelled through the DIHOC, which publicly declares its areas of intervention. However, detail on sources of income, operations, and expenditures are not publicly available. For instance, the DIHOC has a website (5), but it does not contain this information nor is it frequently updated.

The PSCDI has broad powers of scrutiny over the defence sector (the committee “shall examine all questions relating to defence and internal affairs”) including investigating the potential for impropriety within the defence sector (1). The EOCO, CHRAJ, BNI and other entities involved in fighting corruption in Ghana can also scrutinise cases of impropriety in the defence institutions (2), (3), (4).

Hungary does not have these resources (the country has very limited natural resources that can be exploited), but the law prohibits any such business action executed by public or defence officials. The Law on the Status of the Defence Forces Personnel (Law CCV./2012) prescribes that defence forces personnel can conduct any business-related activities only with the permission of their superiors [1]. The law specifically states that permission will not be granted if the given business activity would endanger the professionalism, neutrality and impartiality of the defence forces. High-ranking military leaders and Ministry of Defence (MoD) officials are categorically prohibited from conducting these activities. Consequently, armed forces personnel are legally prohibited from conducting any business activities related to the country’s natural resources.

Due to the reasons above no single case was revealed in the modern history of the country. The Law on the Status of the Defence Forces Personnel (Law CCV./2012) states that defence forces personnel can conduct any business-related activities only with the permission of their superiors [1]. The law specifically prescribes that no permission can be granted if the given business activity would endanger the professionalism, neutrality and impartiality of the defence forces. High-ranking military leaders and MoD officials are categorically prohibited from conducting any such activities. Consequently, armed forces personnel are legally prohibited from conducting any business activities related to the country’s natural resources.

No case has been found, as the country has almost no natural resources.

This indicator has been marked Not Applicable, as no evidence of such interests has been found. Top officials and military leaders have to declare their wealth on an annual basis [1], that is public and subject of internal and public scrutiny. However, it is not related to natural resource exploitation.

This indicator has been marked Not Applicable, as no evidence of such interests has been found. Public institutions have the right to investigate the income of members of the armed forces. The State Audit Office is the legitimate body to investigate the income of the leaders of the ministry [1]. Watchdog institutions have access to the personal wealth declarations, prepared on an annual basis [2].

A thorough look at legislation and constitutional law show an overemphasis on the exploitation of oil (1). It stipulates that Iraq’s oil belongs to its people and should be invested in, to “the highest benefit of the Iraqi people” (Article 112). While its obligations are clear, Baghdad has over-promised and under-delivered (2), (3), (4), (5). The petroleum law passed by parliament in 2018 (6) echoes similar concerns over oil management. Another relevant law which encourages the active participation of the MoD in natural resource management is Law No. 27 for the Protection and Improvement of the Environment (7). In Article 3, the framework calls for the establishment of an inter-ministerial committee to scrutinise cases and laws associated with natural resources, but it lacks force over the matter of defence-linked businesses associated with highly marketable commodities, beyond oil and gas. The potential sale of hydrocarbon resources has been debated in recent years, but as media searches make clear, discussions thus far have emphasised a foreign investment framework while comparatively little has been said about the financial or controlling interests of security actors or associated business that exploit Iraq’s natural resources. The lack of consensus among fractious lawmakers over Iraq’s hydrocarbon law has stood in the way of the establishment of a legal framework that criminalises businesses tied to exploitative enterprises/businesses. Evidence, across press and business reports, points to devastating mismanagement of oil owing to corruption and miss optimization of resource-generated revenues. Malfeasance is highly probable within this sector. Evidence of this was difficult to track but an important example concerning Iraq’s long-neglected mining sector. One report found that the GoI is offering [Iranian] companies a 10-year tax break “with the possibility of this being extended to 15 years” which an Iraqi lawyer interviewed for this assessment described as “a scam that will harm Iraq’s economy under the guise of joint project development” (8). In direct response to the question, Iraq has yet to formulate laws that lay insistence on the prohibition of defence-tied business/and individuals associated with natural resource exploitation.

While verifiable information is hard to find, allegations circulating online offer evidence that state-back armed forces in the paramilitary and officials are benefitting from illicit oil sales and kickbacks. A recent article discusses evidence that identifies militia groups as participants in oil-smuggling rings (1). Militias are accessing oil fields in eastern Kirkuk, in absence of official ministerial approval. The sale of this oil is unlawful by these militia groups whose connection to unrivalled power political factions grants them immunity from the law (1). Reinforcing these reports was the response of a source interviewed by Transparency International. “There are militias connected to Al Hakim [Ammar al Hakim] that are trucking oil out of Qurna oil fields, to Umm Qasr and load it onto terminals they have confiscated within Umm Qasr port” (2). Other sources have stressed that militias’ backed by the military has illicit business activities in the natural resources of Iraq (3,4).

There are weak legal constraints against natural resource exploitation. However, media coverage lacks details, but a critical article reported on the exploitation of oil supplies cheaply sold as aviation fuel to foreign airlines (1). Our sources confirm that Individual defence personnel involvement in businesses relating to the country’s natural resource exploitation is widespread and mostly illicit (2,3).

These interests are not publicly declared and as one interviewee noted; “you won’t find much as the case involves powerful actors such as Ameri. No one can talk comfortably about the redirection of Iraqi fuel or any of Iraq’s natural resource exploitation for that matter” (1). The influence of militia groups under the state-sanctioned PMF-umbrella force and outside it has grown steadily, filling the security vacuum in areas formerly occupied by the ISG, often without any pushback (2).

Scrutiny of businesses associated with natural resource exploitation (from oil to hydrocarbons) falls under the Law on Combating the Smuggling of Oil and Natural Resources No. 41 of 2008. In the absence of official authorization for the Ministry of Oil or the respective regional authority, the law stipulates that the without ministerial authorisation, it is illegal to transport oil or its derivatives “by land, sea or river” (1). The state reserves the right to seize illicitly extracted resources, yet the ability of top officials to evade prosecution limits opportunities for scrutiny. The law address oil smuggling but says nothing about controlling financial interests/businesses. There is no evidence of cases in which oil smugglers tied to security institutions have been prosecuted under Law No. 41. Important trade routes through which oil could be smuggled are guarded and patrolled by Iraqi Police Forces and border guards who are widely accused of corruption, which can hinder counter-smuggling efforts (2,3).

There are no restrictions on defence institutions having financial interests in businesses associated with the country’s natural resources. According to the official website of the Jordanian Armed Forces, under the Developmental Role section, the Armed Forces lists several entities and companies that provide income to the defence sector in Jordan, and those include business related to natural resources [1]. The Armed Forces have a vested business interest in King Abdullah II Design and Development Bureau (KADDB) and King Abdullah II Special Operations Training Centre (KASOTC) [2], which were built by the US on land donated by King Abdullah. Operating under the umbrella of KADDB Investment Group, KADDB owns several other companies, which are also associated with the country’s natural resources such as JLVM, JORDANAMCO, JMSS, JADARA, JORAMMO, and ARM [1, 3, 4]. Furthermore, there are no laws restricting the armed forces’ involvement in businesses associated with the country’s natural resources.

There are no legal restrictions on the Armed Forces or the Defence Sector’s involvement in businesses relating to the country’s natural resources, and the Jordanian Government, not limited to the defence sector, is involved in many businesses related to the countries natural resources [1]. The fact that such interest and involvement in businesses by the Defence Sector in Jordan is somewhat declared on the Armed Forces official webpage, demonstrates that it is not only legal but also commonly acceptable. The fact that the land was granted by King Abdullah II to build the King Abdullah II Design and Development Bureau is evidence that these activities are considered legal [2,3].

There are interest and exploitation of natural resources with huge revenues such as the dead sea chemics, however the government has taken no action [1]. There are no controls at all in relation to the defence sector’s involvement in businesses associated with Jordan’s natural resources (including personnel). Based on our sources, there are no restrictions on military personnel owning bussiness [2].

The Jordanian defence sector is transparent only in relation to declaring business and investment interests in the country’s natural resources [1], however, none of the expenditures, profit, or operations details of these ventures are declared [2,3,4].

Despite the fact that the Jordanian Armed Forces partially declares the investments and businesses it runs [1], none of these enterprises have been audited by Audit Bureau, as they do not appear on the list of audited entities [2]. Desk-based research into these enterprises in Arabic and English, particularly those listed on the Armed Forces official webpage, shows that none of them has come under public scrutiny in the past three years. There were some accusations around corruption in handling the retired military personnel fund managed by the Armed Forces, to which the Armed Forces issued a response denying such accusations [3]. Following that, there were no further investigations or interrogations, which demonstrated that entities affiliated to the Armed Forces do not receive much scrutiny.

Legislation in Kosovo regarding the Ministry of Defence [1] and the Kosovo Security Forces [2, 3] does not specify any legal provision for controlling financial interests in businesses associated with Kosovo’s natural resource exploitation. However, in a state of emergency or special situations, the Kosovo Security Forces has the authority to use state and private assets to fulfil its constitutional and legal duties [2], although natural resources are not mentioned in this regard [2].

There is no evidence that defence institutions in Kosovo (namely the Ministry of Defence and the Kosovo Security Forces) have been involved in businesses related to natural resource exploitation within the country [1].

There is no evidence that personnel within defence institutions in Kosovo (namely the Ministry of Defence and the Kosovo Security Forces) have been involved in businesses related to natural resource exploitation within the country [1].

There is no evidence that defence institutions in Kosovo (namely the Ministry of Defence and the Kosovo Security Forces) have been involved in businesses related to natural resource exploitation within the country [1].

There is no evidence that defence institutions in Kosovo (namely the Ministry of Defence and the Kosovo Security Forces) have been involved in businesses related to natural resource exploitation within the country [1].

Both the constitution and the laws of the police and Defence Ministry (1, 2 and 3) lack articles that forbid these institutions from having controlling shares in businesses associated with the country’s natural resources, but officials and activists say that these institutions are not involved in such activities (4, 5, 6, 7, 8 and 9). There are no media reports to suggest otherwise but, as discussed earlier, the laws of the police and the Defence Ministry allow them to do whatever they please with the funds of the institutions and the SAB and the Finance Ministry do not breakdown all their revenues and spending, so these institutions may be secretly involved in these activities. But the fact that the institutions are not involved in these activities is irrelevant as the question is about the legal framework, which is in this case quite defficient.

Article 14 of the military law (3) and 15 of the police law (2) forbids officers from getting involved in any kind of commerce or profiteering from their work in any way. The KNG’s law does not include a similar article but military law applies to them, according to article 9 of Law no. 136 of 1992 (10).

There are no cases of defence institutions being involved in businesses that exploit the country’s natural resources, but the defence minister, Sheikh Nasser Sabah al-Ahmed al-Sabah, is also the head of Kuwait’s Northern International Economic Zone’s board of trustees (1), so he is officially involved in business. But, so far, no evidence has emerged to suggest that he involved the Ministry in any business activity related to this.

There are no cases of individual defence personnel being involved in businesses that exploit the country’s natural resources, officials, analysts and journalists said. (1, 2, 3, 4, 5, 6, and 7). There are no media reports suggesting otherwise.

This sub-indicator has been marked Not Applicable because there appears to be no such activities or interests to be transparent about.

This sub-indicator has been marked Not Applicable because there appears to be no such activities or interests to be subjected to scrutiny.

The Ministry of Defence must comply with all laws regarding natural resources exploitation and nature protection [1] [2]. None of the relevant laws has any exception regarding defence and security. The MOD does not have any business asssociated with the expoitation of natural resourses except maintainance of its real estate properties.

There is no specific legal framework defining Latvia’s defence institutions’ right to have controlling or financial interests associated with natural resource exploitation, because there are no such cases.[3] There is no need of a law if there are no pre-conditions for the emergence of such a situation. Latvia has no considerable natural resources except for forests, water, peat, etc.
Institutions of the defence sector are not allowed to engage in commercial activity [4] [5] [6].

There are no cases of defence institutions involvement in businesses relating to the country’s natural resource exploitation [1].

There is no evidence of individual defence personnel involvement in businesses relating to the country’s natural resource exploitation. It must be noted that there are no pre-conditions for the emergence of such a situation, as Latvia has no considerable natural resources except for forests, water, peat, etc. Further, defence institutions are also not allowed to engage in commercial activity [1] [2] [3].

This indicator is marked Not Applicable as there are no natural resources in the country of interest to defence industry.

This indicator is marked Not Applicable as there are no natural resources in the country of interest to defence industry.

No evidence was found on the restrictions on defence institutions or individuals having controlling or financial interests in businesses associated with the country’s natural resource exploitation (1).

There are no cases of defence institutions being involved in businesses relating to the country’s natural resource exploitation (1). An interviewed source disregarded, in general, the existence of businesses linked to the defence sector (2). Furthermore, LAF naval forces are being trained and strengthened to protect the countries’ maritime borders and secure oil and gas exploration (3).

No evidence was found of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation (1).

No evidence was found of defense sector interest in natural resource exploitation, thus this sub-indicator has been marked Not Applicablee (1).

This sub-indicator has been marked Not Applicable because no evidence of defence sector interest in natural resource exploitation was found. In this regard, scrutiny of interests will not apply. (1).

There is no regulation or policy which regulates, allows or forbids national security system institutions to participate in the exploitation of natural resources. Moreover, there is no publicly available information or evidence that national security system institutions are engaged in the exploitation of natural resources [1,2,3].

There are no cases of defence institutions being involved in business related to the country’s exploitation of natural resources. What is more, defence institutions are not indebted to nor do they control any companies. There is one exception where the Ministry of Defence, at the beginning of 2018, acquired ownership rights and obligations of the business company “Infostruktūra” (the owner of the company is the Lithuanian state). “Infostruktūra” is responsible for ensuring appropriate and safe national data transfers between institutions [1]. This company does not deal with the country’s exploitation of natural resources.

There is no evidence or publicly known cases of individual defence personnel being involved in businesses relating to the country’s exploitation of natural resources [1,2,3]. As such, this indicator is scored Not Applicable.

There is no evidence or publicly known cases of defence institutions and individual defence personnel being involved in businesses relating to the country’s exploitation of natural resources [1,2,3]. As such, this indicator is scored Not Applicable.

There is no evidence or publicly known cases of defence institutions and individual defence personnel being involved in businesses relating to the country’s exploitation of natural resources [1,2,3]. As such, this indicator is scored Not Applicable.

The assessor finds no legislation that explicitly outlaws military personnel from holding financial interests in natural resources exploitation. However, the 1961 Penal Code (amended in 2001) provides for conflict of interest and mentions all civil service employees (including military personnel) in Article 130.¹ Mali is Africa’s third largest gold producer, after South Africa and Ghana. Gold is by far Mali’s most important export, comprising nearly 70% of total exports in 2016.² Yet, there is no mention of military personnel being prohibited from participating in the sector in the Mining Code.³ As a member of the Extractive Industries Transparency Initiative, the Malian authorities are working towards the full disclosure (scheduled for 2020) of the beneficial owners of companies active in the country’s extractives industries.⁵

There is evidence that the armed forces generate revenues from commercial activities, but these do not include the exploitation of natural resources.¹ The armed and security forces have a statutory duty to participate in public works as part of their contribution to the economic and social development of the country. The armed forces undertake their developmental mission through activities requested by the government, public administrations or territorial collectives. These activities take place mainly in sectors that are not considered to be cost-effective for profit-driven private companies; nonetheless, they serve as revenue-generating ventures for the military.
Furthermore, there is no mention of military involvement in the extractives sector in EITI’s latest annual report in December 2017.²
Nevertheless, there is clear evidence that, in 2012, French aviation giant Airbus purchased shares in the Kodieran gold mine. The company bought the stake by moving EUR15 million from an internal fund through a series of entities in the British Virgin Islands, Luxembourg, Switzerland and Germany. The company later sold the shares at a substantial loss in 2014, two years before the company delivered two helicopters to the Malian army.³
While there is no evidence suggesting that military officials have controlling or financial interests in firms operating in the extractives sector, there are no identifiable laws governing such interests.
Although there is no evidence of cases of defence institutions being involved in businesses relating to the country’s natural resource exploitation, there is no unit within the national police force to deal with corruption within the armed forces, including natural resource exploitation-related issues. This may explain the lack of investigations and therefore, lack of evidence.

The assessor finds no legislation that explicitly outlaws military personnel from holding financial interests in natural resources exploitation. There is no mention of military personnel being prohibited from participating in the sector in the mining code or in the general statutes of the police and army.³ ⁴
Although there is no evidence of cases of personnel in defence institutions being involved in businesses relating to the country’s natural resource exploitation, there is no unit within the national police force to deal with corruption within the armed forces, including natural resource exploitation-related issues. This may explain the lack of investigations and therefore, lack of evidence.

The absence of any legal framework relating to the potential financial involvement of defence institutions or security personnel in the extractives sector renders any such interests wholly non-transparent.

The absence of any legal framework relating to the potential financial involvement of defence institutions or security personnel in the extractives sector means that any such interests are not subject to any scrutiny.

There are no restrictions on defence institutions or individuals having controlling or financial interests in businesses associated with the country’s natural resource exploitation. [1][2]

There are no cases of defence institutions being involved in businesses relating to the country’s natural resource exploitation. [1][2][3][4][5]

No cases of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation were recorded in major media outlets. [1][2][3][4][5]

There are no cases of defence institutions being involved in businesses relating to the country’s natural resource exploitation. [1][2][3][4][5] As such, this indicator is scored Not Applicable.

There are no cases of defence institutions being involved in businesses relating to the country’s natural resource exploitation. [1][2][3][4][5] As such, this indicator is scored Not Applicable.

There are no legal restrictions on defence institutions or individuals having controlling or financial interests in businesses associated with the country’s natural resource exploitation (1)(2)(3)(4)(5)(6)(7)

In particular, Articles from 248 to 256 Section IV of the Moroccan Penal Code entitled Corruption and Influence Meddling (De la corruption et du traffic d’influence) that refer to acts of corruption and influence meddling committed by public agents do not refer in particular to military personnel and/or controlling or financial interests in businesses associated with the country’s natural resource exploitation.

The Moroccan armed forces have been stationed in Western Sahara since the beginning of the war in 1974 (1)This region is rich in phosphates (particularly around in the Boucraâ-Laâyoune area), which represents – along with other minerals – 25% of Morocco’s exports (2).

The extraction, management and export of phosphates is supervised solely by the Cherriff’s Office of Phosphates – OCP (Office Chérifien des Phosphates) (3).The OCP is a public limited company, with 95% owned by the Moroccan state. Its board is composed of the Interior Minister, the Foreign Affairs Minister, the Economy and Finance Minister, the Industry and Trade Minister, the Energy and Environment Minister, the Governance Minister and the Agriculture Minister (4). Both interviewees claimed that some cases of some military men’s illicit involvement in businesses relating to the country’s natural resource exploitation had been reported to them, but were not able or willing to provide detailed information about it (5)(6). No other specific natural resources were found in relation to the armed forces.

Due to the absence of the Ministry of Defence among the members of the OCP board and the tight control of the state over phosphates resources, it is unlikely that the involvement of defence institutions is widespread. If there is any involvement, it occurs with the explicit or implicit authorization of civil high-ranking individuals within the government or the palace.

This indicator has not been assigned a score due to insufficient information or evidence.

These interests are not mentioned in the 2018 Budget law (1)(2). These interests are not taken into account by auditing and accounting public bodies such as the National Audit Office and the Royal Treasury. There interests were not reported as being publically declareed by the national and international press, nor by CSOs. (3)(4)(5)(6)(7)(8)(9)(10)(11)(12)(13).

Therefore it appears that these interests are not publicly declared and are wholly opaque.

These interests are not subject to scrutiny by auditing and accounting public bodies such as the National Audit Office and the Royal Treasury (1)(2). These interests are not subject to scrutiny by the legislature (3). These interests are not subject to scrutiny by civil society (4)(5)(6).

Based on these elements it appears that these interests are subject to no form of scrutiny.

Niger is currently the world’s fourth-largest uranium-producing country (1), with gold and oil being other important exports (2). No instrument directly prevents defence institutions from also controlling interests in the country’s natural resources. The Niger Miner Code does not provide for any explicit provisions regarding the matter (3). At the same time, the 2010 Constitution asks for full transparency with contracts for the exploration and extraction of natural resources (Article 150). It also provides for the sharing of revenues from mineral resources between the central government and local authorities (Article 152).
However, despite these provisions, the activity of defence institutions related to natural resource exploitation is not regulated. Art. 150 of the Constitution states that all revenues from the exploitation of natural resources should be transferred to the State and that companies must fully disclose such revenues. But, it does not explicitly exclude defence institutions from having controlling or financial interests in businesses associated with natural resources.
One peer reviewer provides a different interpretation of Articles 150 and 152 of the Constitution, by stating that “de jure it prevents defence institutions from controlling businesses involved in extractive industries (petroleum, uranium, gold and other minerals)”. However, such interpretation seems problematic: Art. 150 is mainly about the transparency of contracts and their publication in the Official Journal; whereas, Art. 152 addresses equal division of resources between the central government and local authorities. As mentioned above, nothing is explicitly stated about defence institutions in these articles.

The assessor found no cases of defence institutions involved with companies working in natural resource exploitation (1, 2). It should be noted that an absence of evidence does not imply the absence of activity. Additional investigative work beyond the scope of this research project would be required to establish that there is no illicit activity.

Based on interviews and media analysis, the assessor found no cases of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation. However, according to the Small Arms Survey report, some military and security personnel may be occasionally involved in the gold-mining industry in the north of Niger, in two principal goldfields, Djado (closed since 2017) (1), and Tchibarakaten (2). According to the study, some soldiers hire locals to search for gold or to impose “taxes” on minors through ransoming back seized equipment (2); others ensure the safe passage of convoys between Agadez and army bases in the region in Dirkou and Tchibarakaten (for example, protecting water trucks) (2). However, these cases were not confirmed by the original research and require further investigation.

Since there is no legal framework for defence and security institutions regarding declaration of interests in extractive industries, this indicator has been marked Not Applicable.

Since there is no legal framework for defence and security institutions regarding declaration of interests in extractive industries, this indicator has been marked Not Applicable.

Although defence institutions are not expressly excluded from having an interest in natural resources exploitation, the legal rules surrounding the ownership and control of the exploitation process makes it impossible for the defence institutions to be legally and directly involved in the exploitation process (1). However, in the Niger Delta region, military officials have been identified partaking in illegal oil ‘bunkering’ and aiding in the theft and sale of oil. There are strategic exit points from the oil region, and these have significant numbers of security checkpoints. It is alleged that the military uses these checkpoints to extract revenue from the illegal sale of oil because the oil “bunkerers” cannot facilitate the theft, and export of oil resources without the connivance of military officials given their strategic control of the region (2).

Corruption is systemic and nationwide (1). However, there is no evidence that the army, navy, air force have institutional interests in natural resource exploitation; though individual military personnel may have. Legislators often manipulate the appropriation process at the National Assembly to serve private business interests rather than benefit the armed forces as an institution (2).

Corruption is systemic and nationwide (1). However, there is no evidence that the army, navy, air force have institutional interests in natural resource exploitation; though individual military personnel may have. For example The legal and regulatory framework does not make it possible for military officials or institutions to have a direct interest in the extractive sector (1). However, hidden ownership do exist. For example, the Eagle online states “former presidents, top military officers, politicians and businessmen of northern origin own not less than 83 per cent of Nigeria’s oil blocks” says “the Chairman, Senate Committee on Rules and Business, Senator Ita Enang, disclosed this on Wednesday during the debate by the Senate on the controversial Petroleum Industry Bill” (2), (3). Many of the arrangements are also informal as military personnel provide security cover for oil bunkering activities (4).

The legal and regulatory framework does not make it possible for military officials or institutions to have a direct interest in the extractive sector [1]. However, hidden ownership do exist. For example The eagle online states “Former presidents, top military officers, politicians and businessmen of northern origin own not less than 83 per cent of Nigeria’s oil blocks” says “The Chairman, Senate Committee on Rules and Business, Senator Ita Enang, disclosed this on Wednesday during the debate by the Senate on the controversial Petroleum Industry Bill” [2,3]. Many of the arrangements are also informal as military personel provide security cover for oil bunkering activities [4].

As this is illegal activity, there is no form of scrutiny which takes place. The operations are shrouded in secrecy (1), (2).

Article 56 of the Constitution [1] and Articles 225, 226 and 234 of the Criminal Code [2] set the legal framework for the protection of nature and natural resources. In line with this, Article 20 of the Defence Law [3] tasks the Ministry of Defence with developing a Defence Plan to protect certain natural resources (oil, gold, cultural heritage) in case of war. According this Law, it is not possible for the MOD or any other defence institution to have any financial business associated with the exploitation of national resources. The use of natural resources for economic purpose is specifically regulated by the provisions of the Law on the Protection of Nature [4]. Relevant subjects for this purpose can be different private or public entities (article 135) or, in the case of natural parks, public agencies formed by the Government of the North Macedonia (article 136). The public agencies responsible for the management of the three main national parks (“Pelister,” “Mavrovo” and “Galicica”) were formed by the Government in 2006 [3].

Except for a small camping site (St. Naum) which is part of the Galicica national park, cases of the involvement of defence institutions in businesses relating to the country’s natural resource exploitation are not publicly known. The Ministry of Defence’s annual financial balance sheet discloses income from activities, such as the named camping site, but no other activities related to natural resources exploitation are named or illustrated in the balance sheet [1].

There is not enough information to score this indicator. There may or may not be cases of individual defence personnel involved in natural resource exploitation, but there is not sufficient evidence to establish such activity. It is worth noting that there are no restrictions on individuals in the defence sector having controlling or financial interests in businesses associated with the country’s natural resource exploitation.

This indicator has been marked Not Applicable, as there is no evidence of defence institutions having controlling or financial interests in businesses associated with the country’s natural resource exploitation.

This indicator has been marked Not Applicable, as there is no evidence of defence institutions having controlling or financial interests in businesses associated with the country’s natural resource exploitation.

Anti-corruption legislation lays out the consequences of bribery of government officials with up to ten years imprisonment (1). However according to GAN, a business anti-corruption portal: “Exemptions from public tenders are provided for all of Oman’s defence procurement, and military procurement contracts with suppliers do not include anti-corruption requirements” (2). There appears an exemption of restrictions for the defence sector. Over the last five years, there have been several high profile cases against corruption in the petroleum sector, the latest in 2016 involving former officials at the top of Al Maha Petroleum Company (3). 2014 saw two high profile ministers charged with corruption relating to natural resources due to efforts by the State Audit Institute (3). Inferences are made on Oman News to widespread corruption in this sector, “corruption in energy sector hard nut to crack: Oman Minister of Oil and Gas” (4). No minister or official prosecuted has any stated links to the defence or security sector, which is expected because the State Audit Institute does not appear to have the right to scrutinise the Ministry of Defence (5). Therefore, although anti-corruption legislation exists to restrict officials financial interests in natural resources, there exists no clear legislation restricting defence institutions or individuals controlling or financing interests in businesses associated with natural resources exploitation.

No information is available setting out the links between the ministry of defence and natural resource extraction on the Ministry of Defence website (1). The sole example of defence investment in the natural resources sector comes from the MoD, the Ministry of Defence Pension Funds have a 4.3% share in the Oman Oil Marketing Company (2). The Oman News Agency website underlines, “the challenges facing investments of the MoD Pension Fund from oil price decline and how to benefit from the economic policies of the banks” (3), highlighting links between the MoD Pension Fund and oil shares. Apart from the two examples highlighted, there is a lack of transparency by the state about potential links between the two sectors as reported by Reuters, “the government does not disclose how much each fund is worth but each has extensive investments across the local stock market and in local real estate projects” (4). Reuters also reports that Omani ministries refused to comment on pension funds investments and shares (4). Though there is a real lack of transparency in defence investments and shares in this industry no legislation exists to curtail investments; one can assume it is “legal” (5), (6).

There are very few cases where individual defense personnel with very high-rank positions are involved in businesses relating to the country’s natural resource exploitation. These are common in areas of border areas / harbours or even regional network of natural resources, such as oil.

As discussed in sub-indicator 18B, the MoD routinely refuses to comment on shares and investments in the petroleum sector (1). Although the Oman News Agency referred to MoD’s reliance on oil prices (2), no direct link is made to MoD’s investment in oil companies. No mention is made on the Ministry of Defence website concerning defence investment in oil or natural resources (3). The Oman Oil Marketing company, which the MoD Pension Funds has shares in, mentions a Royal Air Force of Oman tender that was won in 2004, otherwise, no mention is made about the MoD or MoD pension funds on the website (4). On the Petroleum Development Oman website, recent trips to new development energy sites by MoD officials alongside members of the al-Shura, and MoD officials participation in workshops by the institute, demonstrating co-operation between the MoD and Petroleum Development Oman institutions (5), (6), (7). However, no explicit information detailing of Ministry of Defence interests in natural resources exploitation is publicly available.

As laid out in sub-indicators 13, 16 and 17, there is no internal or external auditing around defence expenditure or investment. The State Audit Institute lacks the mandate to oversee the Ministry of Defence (1). The al-Shura Council, the legislative body of government, also lacks the power to scrutinise defence and security issues (2). As stated in sub-indicators 4 and 15C public scrutiny is severely restrained, translating into a lack of accountability from the state. In the Oman Daily Observer, an article announces an internal review by the MoD pension fund, including the minister, in which an external audit was approved and financial statements reviewed (3). However, no details concerning the shares and investment in the petroleum industry, the date of the external audit, or the contents of the financial statements were released to the public. Though it is promising to see some form of an internal review, thorough scrutiny is lacking particularly concerning defence institutions’ investments in businesses associated with the country’s natural resources.

This indicator has been marked Not Applicable because the West Bank’s natural resources are under Israeli occupation, which prohibits PA personnel of agency involvement. Access to water also requires military permission from Israel (1), (2).

This indicator has been marked Not Applicable because the West Bank’s natural resources are under Israeli occupation, which prohibits PA personnel of agency involvement.

Neither the security agencies nor national forces are engaged in any financial interests related to natural resources (1). The natural resources of Palestine are under Israeli control (2).

As there is no business linked to the defence sector, there is no involvement of individuals from the national forces in businesses related to natural resources (1).

As there is no business linked to the defence sector, there is no related information available about natural resources and private bussinesses owned by the government or the PA (1).Thus, this sub-indicator is not applicable.

As there is no business linked to natural resources in Palestine, there are no enterprises owned or linked to the government (1). Thus, this sub-indicator is not applicable.

Under the Constitution of Poland, all public institutions operate within the law. As a result, all activities which are not explicitly enabled by the law are prohibited. There are no provisions in any legal acts that empower defence institutions to control or to have financial interests in businesses associated with the country’s natural resource exploitation; consequently, it is prohibited.
Additionally, there are direct prohibitions for individual defence personnel. Article 56 of the Professional Soldiers’ Military Service Act of 2003, generally forbids meaningful employment of the military personnel in private enterprises, as long as they remain on duty [1, 2].

There is no evidence that defence institutions have controlling or financial interests in businesses connected with the natural resources industry. Two of Poland’s most important resources are coal and gas, and there are no reports of the armed forces being involved in their exploitation [1]. Control mechanisms, including independent institutions (Supreme Audit Office), are used to prevent such situations [2].

Theoretically, there may be isolated cases of individual defence personnel being involved in businesses relating to the country’s natural resource exploitation. The Professional Soldiers’ Military Service Act of 2003, Article 56, generally forbids meaningful employment for the military personnel in private enterprises, as long as they remain on duty [1]. Though military personnel can hold additional posts if these do not conflict with the performance of their duties and provided that permission has been granted by the commanding officer of the unit [2, 3]. To summarize, there is no evidence nor reported cases of individual defence personnel being involved in the business of Poland’s natural resource exploitation.

There is no evidence that defence institutions have controlling or financial interests in businesses connected with the natural resources industry, as such this indicator is scored Not Applicable.

There is no evidence that defence institutions have controlling or financial interests in businesses connected with the natural resources industry, as such this indicator is scored Not Applicable.

The Qatari Constitution does not prevent members from the armed forces or the institutions of the armed forces to invest or have interests in the country’s natural resources [1]. As the Head of State and the Chief commander is the Emir himself, he has a monopoly on power. He, therefore, issues decrees that legally authorise military investment in any sector. [2,3,4]

The involvement of defence institutions in business concerning Qatar’s natural resource exploitation is minimal and regulated. According to our sources, there are instances where the armed forces and military institutions have invested and controlled some of the natural resources of the country, however, these activities are not illegal. They are regulated by Emiri decree and approved by the appropriate institutions [1,2,3].

There are few cases where individuals from the defence sector are involved in business related to the country’s natural resources, but these businesses are regulated and legal. If the individual follows the laws and regulations, they are permitted to have their own business. In many cases, such businesses are registered under the names of family members, but the real owners are military personnel. In general, there is control over such instances. [1,2,3].

There is a total lack of transparency. The interests of military personnel are not publicly declared, and information about such interests is not openly published. The Ministry of Defence and the armed forces have investments in businesses, but those are not declared by the government [1,2].

Defence institutions and personnel interests in businesses associated with the country’s natural resources are not subject to any form of scrutiny. This is because matters concerning security and defence are above the authority of independent scrutiny bodies such as the State’s Audit Bureau, and the ACTA [1,2,3].

According to our sources, there is no restriction or any legal framework that prohibits the military or the army from holding control over financial interest in businesses associated with the natural resources of the country (1), (2), (3). Another source, confirms that many of the royal family’s members who work in the army have financial assets and interest in many businesses within the sector of natural resources (4).

According to our sources, there are many individuals (i.e. royal family) who hold financial interests in the natural resources of the country (1),(2). However, these activities are considered legal as there is no legal framework that restricts such activities (1). According to a gulf-affairs expert, two parts of the government (defence institutions and natural resource exploitation businesses) have traditionally been kept separate (3).

According to our resources, senior commanders who are members of the royal family have a high level of involvement in businesses relating to the country’s natural resource. In other words, exploitation is common in areas with major revenue streams such as oil and gas (1), (2).

Interests of individual defence personnel or institutions in businesses associated with natural resource exploitation are not publicly stated. Royal family members and government officials are not required to publicly disclose their assets, although these have become subject to more scrutiny than under previous administrations from Crown Prince Mohammed bin Salman, who has sought to curtail the personal expenditure of royal family members in a bid to centralize power and authority and shore up state resources (1). According to a Gulf affairs expert, “should these interests exist, they would certainly not be transparent or subject to any form of official scrutiny” (2). According to other sources, such interests are not publicly available as the amounts of revenue s are huge and do not go to the general budget, rather to royal family members (3), (4).

The financial interests of defence establishment individuals in enterprises relating to natural resource exploitation are not subject to any form of scrutiny in Saudi Arabia (1). There is a higher level of central government control and scrutiny of the finances of Saudi royal family members and senior officials in general. However, there is no indication that this scrutiny is focused on defence officials’ interests in such enterprises. According to a Gulf affairs expert, “should these interests exist, they would certainly not be transparent or subject to any form of official scrutiny” (2).

There are no provisions within the existing legislation that would prohibit defence institutions from natural resource exploitation [1, 2, 3, 4, 5].

The Ministry of Defence owns hunting grounds and natural parks that can be regarded as “natural resource exploitation”. Namely MoD has ownership over the hunting grounds Karadjordjevo, organized as a military institution “Morovic” [1], as well as a military institution Tara, a tourist resort situated in the Tara National Park [2]. The storyline around hunting ground and land in Karađorđevo has caused controversy in the public. Namely, in 2013 Serbia and the United Arab Emirates signed an agreement, through which the Serbian government and the company Al Rawafed Serbia signed the contract on joint investment in the agricultural land in the northwestern part of Serbia, that entails, land belonging to the military institution Morović. The land was leased through an agreement under favourable conditions, without ensuring fixed compensation, which leaves the military dependent on the profit earned by the company [3].

There is no evidence of individual personnel being involved in business relating to Serbia’s natural resource exploitation.

There is generally no public information on relevant activities, plans and other topics related to natural resources. The Ministry of Defence does not perceive natural resources as a topic of particular public interest. These are resources that are under the jurisdiction of a military facility, and have a special protected status, and therefore the information is confidential. For example, the Ministry of Defence has failed to provide information on the execution and details of the contract with Al-Rawafed company to journalists for a long time [1]. In 2017, the minister of defence stated at a press conference that the MoD had not received any money for the use of the land in Morovic [2]. Namely, the state profit from the land lease is currently six times lower than before the investor’s arrival [3].

There is no special interest of the public and the parliament for the issues of monitoring the work of military facilities that are related to the use of natural resources. As an exception, scrutiny over the controversial case cited in 18D came down to a group of interested journalists that followed the case. In the National Assembly, opposition MPs have attempted to form an inquiry committee to investigate the case several times, without any success [1]. Additionally, when the contract details were questioned on some of the DIAC sittings, the public remained deprived of a comprehensive answer [2].

Defence institutions are, by constitutional means, prohibited from having controlling or financial interests in businesses associated with the country’s natural resource exploitation (1,2). Armed forces must remain apart from the exploitation of natural resources. Article 18 of the Constitution specifies that the army undertakes the duty of defending the nation, its independence, and its territorial integrity. It must remain entirely impartial. Article 13 stipulates the ownership of natural resources: ‘Natural resources belong to the people of Tunisia. The state exercises sovereignty over them in the name of the people. Investment contracts related to these resources shall be presented to the competent committee in the Assembly of the Representatives of the People. The agreements concluded shall be submitted to the Assembly for approval.’ (3).

According to our sources, there has been no case where the MoD or the armed forces have had any business or commercial interest in any of the country’s natural resources (1,2). Exploitation in natural resources is totally prohibited and illegal. (2) There is no other publicly available evidence that defence institutions or individual personnel within these institutions, have controlling or financial interests in businesses associated with the country’s natural resource exploitation (3).

According to our sources, there could be rare cases of high profile officers who may own businesses and have financial interests, but these are illicit activities and usually are registered under another person’s name (e.g a relative)(1,2). There is no publicly available evidence that defence institutions or individual personnel within these institutions have controlling or financial interests in businesses associated with the country’s natural resource exploitation (1).

This indicator is marked Not Applicable as there are no financial interests and commercial enterprises managed and owned by the MoD or the armed forces ( except sports clubs, which are semi-independent) there is no data available for the public (1,2).

This indicator is marked Not Applicable as there are no declared financial interests of the MoD, and so there is no public scrutiny of it (1,2).

Defence institutions are not prohibited from having controlling or financial interests in businesses associated with Ukraine’s natural resource exploitation. For instance, the MoD is one of the biggest landowners in Ukraine, controlling over 533 thousand hectares of land (this makes the MoD the third biggest landowner in Ukraine [2]). The MoD also has enterprises, some of them extract sand and gravel and conduct the wholesale of wood [3].

There are instances of the MoD being involved in businesses related to country`s national resource exploitation, but these are MOD legal activities with the enterprises having been legally transferred to the MoD following the CMU decision [1]. For instance, the MoD controls the state enterprise “Druzhbiievskyi quarry of non-metallic minerals “quartz” which extracts sand and gravel, mines building stone, and recycles it into rubble. It also controls the state enterprise “Kharkiv factory of reinforced concrete products” which conducts inter alia wholesale of wood [2].

Defence personnel are prohibited (except for servicemen of regular military service and cadets) from engaging in other paid (except for teaching, scientific and creative activity, medical practice, instructor and judge practice in sports) or entrepreneurial activities [1]. There are cases of defence personnel being accused of corruption, but there is no information on cases related to the country`s national resource exploitation [2, 3].

According to a publicly available list [1] of all enterprises owned by the state, the MoD runs 118 enterprises, including those on the temporarily occupied Crimea, as of April 2018 including those related to Ukraine’s national resource exploitation. Additionally, some of the information is piecemeal and scattered throughout different pieces of legislation and releases [2, 3, 4]. However, there is no publicly available data on the revenues, operations and expenditures of those enterprises. Defence personnel are prohibited from engaging in other paid or entrepreneurial activities [5]. However, they are subject to the submission of e-declarations and have to declare their incomes and interests each year, indicating sources of income and amounts [6].

MoD enterprises, including those related to Ukraine’s national resource exploitation, are subject to public scrutiny [1]. There is no evidence of parliamentary scrutiny of these activities.

Research reveals that there are no restrictions on defence institutions or individuals having controlling or financial interests in businesses associated with the country’s natural resource exploitation, including oil and gas. There are legal provisions within the constitution that restrict institutions and individuals’ investments in the country’s natural resources; however, these do not apply to the defence sector and the federal armed forces. Article 120 of the Constitution states, “the UAE has exclusive legislative and executive jurisdiction in the following matters: Defence and the federal armed forces” (1). This means that the Constitution and other regulations and laws do not apply to defence and military institutions, but do apply to individuals within the sector. For example, Federal Law No. 6 of 2004 (the Federal Armed Forces Law) involves the service of officers in the armed forces. The law contains certain express provisions relating to the conduct of armed forces personnel with regards to conflicts of interest and gifts. Article 47 of the Federal Armed Forces Law prohibits officers from undertaking work for third parties under any circumstances without the permission of the Chief of Staff. Article 48 of the Federal Armed Forces Law prohibits officers from having any interests, whether personal or through an intermediary, in any works or contracts related to the armed forces, except for the leasing of property owned by him or her (4).

There is no legislation or any regulations that prohibit defence institutions from involvement in businesses associated with the country’s natural resource exploitation (1). There is also no indication that defence involvement in businesses is illegal.

Desk-based research shows that the Emirates Defence Industries Company (EDIC) is an umbrella company for many other companies (2), such as Mubadala Development, which focuses on natural resources including petroleum. The Chairman of Mubadala is H.H. Sheikh Mohammed bin Zayed bin Sultan Al-Nahyan, who is the Crown Prince of Abu Dhabi, and the Deputy Supreme Commander of the UAE’s Armed Forces (3).

Individual personnel, rather than institutions, need approval from the commander in chief to set up any kind of business in the country’s natural resources. The involvement of senior commanders is legal and widespread at different levels (of bussinesses) (1), (2).

The interests are not declared publicly. There are no details of sources of income, operations, expenditures, or full disclosure of activities (1), (2).

The military and defence sector do not publicly declare their financial interest in businesses associated with the country’s natural resources. The FNC (1), the consultative semi-legislative body in the UAE, has no power to scrutinise the financial interests of defence and military institutions in the country’s natural resource businesses. Additionally, there is no evidence of any media reporting or public debate scrutinising these interests or investments. Despite the availability of the audit report for the country’s major state-owned enterprise, which is also involved in the country’s natural resource exploitation, no evidence is available at all concerning the public or the media shedding a negative light on such interests (2).

Country Sort by Country 18a. Legal framework Sort By Subindicator 18b. Defence institutions: Financial or controlling interests in practice Sort By Subindicator 18c. Individual defence personnel: Financial or controlling interests in practice Sort By Subindicator 18d. Transparency Sort By Subindicator 18e. Scrutiny Sort By Subindicator
Albania 0 / 100 100 / 100 100 / 100 NA NA
Algeria 50 / 100 0 / 100 0 / 100 0 / 100 0 / 100
Angola 25 / 100 25 / 100 0 / 100 0 / 100 25 / 100
Armenia 0 / 100 100 / 100 100 / 100 NA NA
Azerbaijan 100 / 100 NEI NEI 0 / 100 0 / 100
Bosnia and Herzegovina 100 / 100 100 / 100 100 / 100 NA NA
Burkina Faso 100 / 100 75 / 100 100 / 100 0 / 100 0 / 100
Cameroon 0 / 100 50 / 100 25 / 100 0 / 100 0 / 100
Cote d'Ivoire 0 / 100 100 / 100 50 / 100 0 / 100 0 / 100
Egypt 0 / 100 25 / 100 100 / 100 25 / 100 0 / 100
Estonia 0 / 100 100 / 100 100 / 100 NA NA
Georgia 100 / 100 100 / 100 100 / 100 NA NA
Ghana 0 / 100 100 / 100 75 / 100 NA 50 / 100
Hungary 100 / 100 100 / 100 100 / 100 NA NA
Iraq 0 / 100 0 / 100 0 / 100 0 / 100 0 / 100
Jordan 0 / 100 25 / 100 25 / 100 50 / 100 0 / 100
Kosovo 0 / 100 100 / 100 100 / 100 NA NA
Kuwait 0 / 100 100 / 100 100 / 100 NA NA
Latvia 100 / 100 100 / 100 100 / 100 NA NA
Lebanon 0 / 100 100 / 100 100 / 100 NA NA
Lithuania 0 / 100 100 / 100 100 / 100 NA NA
Mali 0 / 100 100 / 100 100 / 100 0 / 100 0 / 100
Montenegro 0 / 100 100 / 100 100 / 100 NA NA
Morocco 0 / 100 50 / 100 NEI 0 / 100 0 / 100
Niger 0 / 100 100 / 100 75 / 100 NA NA
Nigeria 50 / 100 100 / 100 0 / 100 0 / 100 0 / 100
North Macedonia 100 / 100 100 / 100 NEI NA NA
Oman 0 / 100 25 / 100 100 / 100 0 / 100 0 / 100
Palestine NA 100 / 100 100 / 100 NA NA
Poland 50 / 100 100 / 100 100 / 100 NA NA
Qatar 0 / 100 75 / 100 100 / 100 0 / 100 0 / 100
Saudi Arabia 0 / 100 25 / 100 25 / 100 0 / 100 0 / 100
Serbia 0 / 100 50 / 100 100 / 100 0 / 100 25 / 100
Tunisia 100 / 100 100 / 100 75 / 100 NA NA
Ukraine 0 / 100 75 / 100 75 / 100 0 / 100 50 / 100
United Arab Emirates 0 / 100 25 / 100 25 / 100 0 / 100 0 / 100

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

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