Transparency in the procurement process in Nigeria

Introduction

Governments allocate public funds toward social goods and services as an essential component of provision of public goods and economic planning. This is facilitated through public procurement, which is the process through which the government acquires works, goods, and services from the private sector. The estimate among OECD countries shows that public procurement accounts for a 12.9% share of the Gross Domestic Product (GDP) in 2021. In developing countries, public procurement was estimated to be around 30% of the GDP and represented more than 30% of total government spending before the outbreak of the COVID-19 pandemic. In 2016, the annual expenditure on procurement in Nigeria was estimated to range from 10% to 25% of GDP.

Due to the large amount of money involved, the procurement process is susceptible to official corruption and other forms of inefficiency. According to the United Nations Office on Drugs and Crime, approximately 57% of all foreign bribery cases are attributed to procurement corruption. To combat the challenges posed by corruption in public procurement, governments worldwide have instituted a range of guidelines and mechanisms. A central aspect of these efforts involves the implementation of a well-defined and transparent procurement process.

The significance of transparency is universally acknowledged as a formidable check on corrupt practices, and it assumes a fundamental role in guaranteeing optimal value for money. Incorporating provisions that prioritize transparency facilitates the monitoring and scrutiny of processes serving to establish accountability for decisionmakers and fosters a heightened sense of competition within public procurement. For the public procurement process to be transparent, all the parties or stakeholders involved, i.e. contractors, suppliers, service providers, and the general public, must have access to information related to the procurement. In other words, public procurement must be conducted in an honest, visible, and accessible manner to all the stakeholders involved. It means the ministries, departments, and agencies (MDAs) reveal, in an accessible way, all useful information related to procurement processes. This includes the dissemination of pertinent details regarding governmental procurement undertakings, spanning the phases of planning, tendering, assessment, and contract allocation, all presented in a clear and understandable manner and platform.

Since 1999, following the restoration of the democratic system of government after years of military rule, successive administrations in Nigeria have dedicated substantial efforts to ensure and enhance transparency in the procurement process. In 2000, President Olusegun Obasanjo’s administration, in collaboration with the World Bank, commissioned an assessment of the nation’s procurement process. The resulting reports, titled “Nigeria: Country Procurement Assessment Report (Volumes 1 and 2),” provided key recommendations. Among these recommendations, the World Bank advocated for the enactment of a procurement law, the establishment of a public procurement commission with oversight functions, and a revision of financial regulations to enhance transparency in dealings with relevant stakeholders. Additionally, the Bank emphasized the need for restructuring the tender board and regular capacity development for government officials. These reforms were proposed as essential steps toward fostering transparency and accountability in Nigeria’s procurement practices.

However, the pace of public procurement reforms at the federal level has been slow and incoherent. For example, it took the government seven years after the World Bank’s recommendations before the Public Procurement Act (2007) was enacted into law. The enactment of the Public Procurement Act led to the establishment of the Bureau of Public Procurement (Part 2, Section 3). The Act also provided for the constitution of the Procurement Council, which, as of today, is yet to be constituted (Part 1, Section 1). Ifejika contends that the Public Procurement Act faces challenges due to a high rate of corruption, poor administration of justice, political interference, inadequate monitoring and evaluation of procurement projects, and an indiscriminate choice of procurement systems.

Despite the challenges at the federal level, innovative public procurement reforms have emerged at the subnational levels. E-tendering and e-procurement were introduced in Kaduna and Ekiti states ahead of federal government marginal uptake of similar reforms.¹ While these innovations are expected to strengthen transparency, there have been limited studies on their impact and sustainability in light of public transitions. 

The goal of this research is to investigate the level of transparency in public procurement at the federal level vis-à-vis the subnational levels. This study will specifically address the following research questions: How transparent is each stage of the public procurement process in Nigeria? How accessible is public procurement information, and what are the obstacles to access for important stakeholders? What is the level of compliance with the Public Procurement Act or law? How effective is the oversight function in ensuring transparency? This information will feed conversations about procurement policies, potentially leading to significant adjustments to the country’s procurement methods.

The rest of the report is organized as follows: The next section focuses on the methodology used in gathering the data and the analytic approach adopted. Section three addresses the institutional environment surrounding the public procurement process in Nigeria. This is important because the procurement process does not take place in a vacuum but within an institutional environment. The better the institutional environment, the more transparent the procurement process will be. In section four, the legal framework that can support the procurement process and make it more transparent is examined. In the following section, the findings from the field are presented. Many challenges can preclude a transparent procurement process. Thus, in section six, those challenges are examined lucidly. Section seven concludes and offers critical areas where reforms need to be carried out. The final section presents some areas of procurement where ensuring absolute transparency in the procurement process may be impossible due to various reasons.

Methodology

The purpose of this study is to evaluate the transparency elements within the Nigerian procurement process. The study was carried out at the federal level and within two states: Ekiti State and Kaduna State. Ekiti State and Kaduna State were selected because they have, with the help of the World Bank, established an e-procurement portal. In other words, they are the leading states in the country with efficient e-procurement operations. We relied on desk reviews and Key Informant Interviews (KIIs) in conducting this research. The desk review covers existing research on transparency of Nigeria’s procurement, legal framework, and key policy documents. It involved an exhaustive examination of existing literature on Nigeria’s procurement transparency, including academic journals, legal documents, and key policy papers. The document review provides de jure context into the public procurement process in Nigeria, but mostly lacks insight on the de facto situation. Using structured questionnaires, KIIs were conducted to obtain information from government MDAs as well as private organizations who have experience with the procurement process at both the federal and state levels. Participants were selected through purposive sampling to target those who directly participated in or are knowledgeable about procurement processes. This approach was designed to provide credible insight into the public procurement process in practice. Participants were drawn from the public and private sectors and civil society organizations. The public sector participants comprise government officials from the MDAs (federal level and two states), while the private sector participants are contractors. Private organizations in particular were interviewed because they are recipients of public procurement contracts. Additionally, they were interviewed to provide a balanced overview of the public procurement process. In total, 10 public sector officials working on procurement were interviewed: five MDA officials at the federal level and five at the subnational level. Also at the federal level, two representatives of private organizations, which include one advocacy group and a women’s entrepreneurial association, were interviewed. At the state level, 14 representatives of private enterprises and civil society organizations were interviewed, comprising a total of 16 private sector/civil society KIIs. Contextual analysis was applied to the transcribed data from KII to obtain the empirical results presented in this study. The list of the stakeholders interviewed at the federal level (based in Abuja) and two states (Kaduna and Ekiti) is presented in the annex.

Institutional environment of procurement process in Nigeria

According to the OECD, a transparent procurement process encompasses several vital characteristics, including integrity, accessibility, inclusive involvement, effectiveness, e-procurement, and accountability. However, in many developing countries like Nigeria, some of these attributes are challenging to observe or quantify. For example, while the federal government has shown willingness to implement e-procurement, it has struggled to muster the political will to fully launch it. Despite this deficiency, certain key indicators can be used to assess the level of transparency within a country’s public sector, showing the institutional environment in which government operations are conducted, including the procurement of goods, services, and works.  

For example, indicators such as budget openness, judiciary independence, and e-citizenship, as well as freedom of the press, implicitly capture the transparency within the public sector and, invariably, the procurement system that is managed within the public sector.

Budget transparency is a crucial institutional factor that can indicate the level of transparency in public procurement. Budget transparency is contextualized as full disclosure of all relevant information regarding fiscal operations or public finance in a timely and systematic manner. It “involves the clarity, comprehensiveness, reliability, timeliness, accessibility, and usability of public reports on public finances” as well as citizen engagement in the budgeting process. When the budgeting process is transparent, it enhances accountability, legitimacy, integrity, inclusiveness, trust, and quality of budget decisions. 

The International Budget Partnership (IBP) since 2006 has been assessing the openness of budget processes  through the Open Budget Survey (OBS). The OBS consists of 145 scored questions, out of which 109 assess public access to budget information, 18 assess opportunities for public participation in the budget process and 18 assess the role and effectiveness of the legislature and audit institutions. The participants are presented with five possible responses. The responses are then quantified using a scale of 0 to 100. A question obtains a score of 100 if the participant confirms that all aspects of the standard are satisfied or surpassed. Subsequently, when the essential aspects of the criteria are met, 67 points are given, minimum efforts to satisfy the standards are given 33 points, and 0 points are given when the standards are not met. The scores for each indicator (public participation and oversight) are averaged to provide an overall score of a country’s budget transparency. For public participation and budget oversight, three outcome categorizations exist, namely: few (weak), limited, and adequate. A country’s performance is deemed “few (weak)” if its score falls between 0 and 40, “limited” if it falls between 41 and 60, and “adequate” if it ranges from 61 to 100.²  For instance, a weak budget oversight score shows that the legislature or other institutions responsible for monitoring and scrutinizing the budget lack the necessary capacity or authority to effectively oversee the budget process. In the case of limited budget oversight, the score indicates that the aforementioned oversight bodies have some involvement in the budget process, albeit lacking full independence, capacity, or legal authority to exercise robust oversight. An adequate budget oversight score reflects well-functioning oversight institutions with strong capacity, independence, and legal frameworks that enable them to thoroughly scrutinize the budget and ensure accountability in the use of public funds.

Figure 1 shows the public participation in the budget process and budget oversight by the legislature in Nigeria. In 2017, Nigeria scored only 13 out of 100 in public participation, suggesting that the public is offered few opportunities for participation in the different stages of the budget process. Although there was a slight improvement in public participation over time—rising to 22 in 2019 and 26 in 2021—it declined again in 2023, with the country recording a score of 19 in public participation in the budget process. Overall, the level of public participation in the budgeting process remains very low in Nigeria. According to Iloh and Nwokedi, public participation in the budgeting process is low because the process is perceived as the exclusive right of the executive arm of the government, prepared by different MDAs. Citizens are only entitled to hear or participate in the budgeting process during the national assembly’s budget approval. However, low citizen participation is not exclusive to Nigeria alone; it is a global phenomenon. The average global score for public participation in the budget process stood at 15 in 2023. This indicates that globally, citizens or the public rarely participate in the budget process. An inclusive system incorporates citizens from the budget development stage, and not only as beneficiaries, in order to ensure the budget reflects citizens’ aspirations. Some specific forms of public participation include voting on allocation priorities for their constituency, participating in public hearings, setting up citizen advisory committees to engage stakeholders directly, institutionalizing citizen surveys, and creating a structured deliberation process for citizens to provide inputs.

In terms of budget oversight, Nigeria has progressed since 2017, scoring 56 out of 100 in 2017 which increased to 61 in 2021 and 2023, respectively. This shows that the budget oversight in the budget process is adequate. In other words, Nigeria’s legislative arm of government provides adequate oversight during the planning stage of the budget process. However, this may not be as strong during the budget implementation stage.

Generally, the budget process still faces significant challenges in Nigeria, which could have far-reaching implications for public procurement procedures in terms of transparency, fairness, and accountability. Specifically, a lack of transparency in the budgeting process can negatively affect public procurement by fostering an institutional environment conducive to corrupt activities and favoritism, which breed inefficiency in public sector service delivery. 

Apart from indicators of budget openness, several other indicators can be used to depict the institutional environment where public procurement takes place. The indicators include administrative burden or transparency, judicial independence, freedom of the press, and e-citizenship. These indicators are generally called the index of public integrity (IPI). Generally, IPI captures the assessment of public sector administrative and management practices that safeguard a country against corruption. In other words, it assesses a society’s ability to address or control corruption and ensure that public resources are effectively spent without practices related to corruption. According to CorruptionRisk.org, the IPI score ranges from 1 to 10, with 1 and 10 representing the lowest and highest level of public integrity, respectively.

This section focuses on three of the four IPI indicators stated above, namely judicial independence, e-citizenship, and press freedom.³ Figure 2 shows IPI in terms of judicial independence, e-citizenship, and press freedom. First, judicial independence means that the judiciary operates free from influence from other branches, particularly the executive and legislative arms. According to the United Nations Development Program (UNDP), judicial independence entails judges making decisions on cases impartially and without undue external interference. In practice, the independence of the judiciary is closely linked to the ease of doing business, including public procurement. Judicial independence provides a safeguard against corruption, favoritism, and other unethical conduct that could compromise the integrity of the procurement process. Additionally, it serves as a mechanism for resolving disputes arising from procurement bids, contract awards, and allegations of irregularities and misconduct. However, Figure 2 shows a gradual decline in Nigeria’s score for judicial independence since 2017. In 2017, the judiciary independence score stood at 5.32, which decreased to 4.20 in 2019 and 2021, and further to 3.38 in 2023. This suggests that while Nigeria has a judicial system, its level of independence is relatively low. To put it another way, a variety of factors have contributed to the significant challenges Nigeria’s judiciary system is encountering. Basiru and Arogundade argued that Nigeria’s judiciary’s challenges are not unconnected to internal crises or conflicts within the judiciary combined with a widespread culture of using the public office for personal gain. Nwozor also pointed out that judicial recklessness and corruption are the driving forces behind the judiciary’s lack of independence, judicial accountability, and numerous crises. The persistence of these challenges could erode trust in the judiciary among investors or aggrieved bidders involved in public procurement projects. A compromised judiciary can also lead to the erosion of the rule of law, political interference in the administration of justice, human rights violations, corruption, and ineffective checks and balances on the executive branch of government.

The second indicator considered is E-citizenship, also known as digital citizenship, which refers to the appropriate and responsible use of Information and Communication Technology (ICT) by individuals and communities. According to Mossberger, Tolbert, and McNeal, digital citizens utilize ICT to engage in society, politics, and government, thereby influencing public policy reforms. The E-citizenship score for Nigeria has remained consistently low, averaging a score of 2.39 per survey from 2015-2023. This indicates that despite the increased access to ICT facilities, the utilization of these tools to responsibly influence government policy is limited in the country.

The last indicator considered is the freedom of the press, which is referred to as the principle that ensures that individuals or organizations have the right to express, publish, and share information, ideas, and opinions without the fear of censorship or interference from the government or its agencies. According to Article 19 of the Universal Declaration of Human Rights, “everyone has the right of freedom of opinion and expression, which includes the  freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers.” Among the indicators of IPI considered, Nigeria’s score for freedom of the press has been on the increase since 2017 except in 2023, when the score declined to 4.18 in 2023 from 5.86 in 2021. The decline in press freedom in recent times is reflected by the regular monitoring, occasional attack, and indiscriminate arrest of journalists observed especially during and after the 2023 elections. Thus, further efforts are required to enhance this score, as a continued regression in press freedom could result in limited accountability, reduced transparency, the dissemination of propaganda and misinformation, political manipulation, the suppression of public opinion, and human rights abuses.

Legal framework for transparency of the procurement process in Nigeria

To ensure that the procurement process is in line with international best practices such as competition, transparency, integrity, efficiency, and best value, a legal framework must be in place. A legal framework is necessary to reduce financial mismanagement associated with the purchase and supply of goods, services, and works, as well as to provide the government with the best value for money. Prior to the advent of a democratic government in 1999, Nigeria lacked a solid legal framework to guide public procurement. At the federal level, the minister of finance was responsible for regulating procurement activities. As a result, the Ministry of Finance established financial regulations that provided a set of internal guidelines governing the configuration and duties of tender boards in MDAs. Because the financial regulations were not accessible to suppliers (bidders) and the general public, the procurement process was opaque. As a result, it is impossible to gauge how well financial regulations are being followed, and it is frequently dependent on the whims and caprices of the Ministry of Finance. Furthermore, the ministry had the authority to unilaterally alter financial regulations.

In 2000, soon after he assumed office, President Olusegun Obasanjo requested assistance from the World Bank to assess the country’s procurement practices. At the end of the process, the World Bank published a document entitled “Country Procurement Assessment Report (CPAR).” The World Bank’s report revealed that prior procurement practices promoted corruption, did not give the government value for the money it spent, and subjected the procurement to the discretion of government personnel. The identified lapses led to the introduction of the Public Procurement Act in 2007. The Act led to the establishment of the Bureau of Public Procurement as a regulatory body to act as a legal and institutional framework and a platform for the growth of Nigeria’s professional capacity for public procurement.

The 2007 Public Procurement Act remains the only legal framework for public procurement in Nigeria. Its content lays out the rules to make sure the public procurement process is fair, competitive, efficient, and transparent. To maintain transparency in public procurement, the Act provides a certain threshold for procurement projects that can be implemented by different agents involved in the procurement of works, goods, and services. Infrastructural projects costing N500 million and above, or goods and services (non-consultant services and consultant services) costing N100 million and above must be approved by the Federal Executive Council. The ministerial tender board in each ministry, however, certifies infrastructural projects valued at N10 million or more but under N500 million, as well as goods and services valued at N5 million or more but under N100 million.

Additionally, to further guarantee the integrity and transparency of the procurement process, the Procurement Act specifies the role of private organizations and general interested organizations, particularly Civil Society Organizations (CSOs), as observers of the procurement process. The act also enables CSOs to perform analyses using procurement documents they have access to, including some unclassified procurement documents. However, they are only permitted to send in their reports to the appropriate authorities, primarily anti-corruption organizations like the Independent Corrupt Practices and Other Related Offences Commission and the Economic and Financial Crime Commission.

Since the country has a federalist system of government and the constitution outlines the functions of the federal, state, and local governments, subnational governments also have their own procurement legislation. Although the Public Procurement Act of 2007 was enacted for federal procurement, it served as the model for each state’s procurement law. Each of the selected states for this study operates its procurement system in the same way. The legal framework for the purchase of works, products, and services in Ekiti State is provided by the State Public Procurement Law No. 2, 2010 (re-enacted 2020). The law led to the establishment of the Ekiti State Council on Public Procurement and the Bureau of Public Procurement, which serve as the regulatory bodies charged with responsibility for the monitoring and oversight of state procurement.

The Kaduna State House of Assembly passed into law their State Public Procurement Law on June 1st, 2016. The passage of the procurement law led to the establishment of the Kaduna State Public Procurement Authority, which oversees the state’s procurement processes. The two states’ procurement laws serve the same purpose as the national Public Procurement Act of 2007, which is to ensure that all contracts or procurements (works, goods, and services) are open, accountable, competitive, transparent, cost-effective, and, most importantly, deliver value for money to the state governments.

However, the Public Procurement Act of 2007 is not without its flaws. Olatunji, et al. contended that the Public Procurement Act of 2007 exhibits several flaws. First, they argue that the Act lacks clarity in defining the roles and qualifications of procurement officers or managers hired by the government’s MDAs. In the absence of such criteria, the selection of procurement officers or managers may be fraught with corruption and variation, resulting in the employment of unqualified persons. Similarly, they stated that the Act does not specify the minimum qualifications for members of the procurement planning committee, thereby allowing anyone to join the committee, even if they lack the necessary qualifications to make critical procurement decisions. This could potentially have a negative impact on the success of procurement projects. Furthermore, the Public Procurement Act does not accommodate the roles of specialized professionals, particularly those involved in the procurement of engineering and construction works, which constitute the majority of the country’s procurement projects.

Transparency in the procurement process in practice

Since the Public Procurement Act was enacted in 2007, the federal and state governments have shown a keen interest in ensuring the Nigerian procurement process is transparent. The pertinent questions are: What is the level of adherence to the tenets of the Public Procurement Act? What is the level of transparency in public procurement? This can be dissected by examining the procurement process in the country. Thus, this section aims to examine the levels of transparency in the procurement processes, focusing on the federal level and two states—Ekiti State and Kaduna State. As stated in the Public Procurement Act, the procurement process consists of various stages, including drafting a procurement plan, advertising the procurement contract, contract bidding, approval of procurement projects, publishing procurement plans, disclosure of bidding criteria, dispute resolution, monitoring procurement, and the establishment of e-procurement platforms. We evaluate the level of public procurement transparency across the procurement value chain below, as each stage mandates transparency.

Advertisement of procurement bids

The advertisement of procurement projects is one of the crucial elements of ensuring transparency in the public procurement process. By advertising these projects, essential details, including requirements, timeframes, and scope, are made available to the public. This practice helps to disseminate information widely, which encourages competition, reduces favoritism, enhances public accountability, ensures legal compliance, and supports efficient resource use.

Both the federal and state governments in Nigeria have taken significant steps to ensure the promotion of transparency in procurement processes. The government’s agencies are required to prepare a procurement plan, which is the first step in the procurement process. After developing these plans, agencies must invite bids from interested parties as stipulated in Public Procurement Act (2007) Section 25 which states that the procurement contract must be published in two national newspapers and the Federal Tender Journal to ensure a broad dissemination of procurement opportunities and maximize participation.

Interviews with ten stakeholders across various ministries and government agencies at both the federal and state levels revealed a strong commitment to transparency in the procurement advertising process. The ministries and agencies stressed the importance of publicly announcing bidding opportunities in two national daily newspapers and the biannual Federal Tender Journal.

“We advertise in the two national dailies and the federal tender journal.”
-Federal respondent

“Yes, we make a call for bidders in the newspapers (one or two daily newspapers), government tender journals.”
-Federal respondent

According to the interviewees’ submissions, advertising procurement programs have considerably enhanced Nigeria’s procurement process. Private organizations’ responses confirm the positive impact of this transparency. Private sector participants reported a rise in opportunities to bid on projects, indicating a more open and competitive procurement climate.

“I would say that there is a great improvement. Because some years back, we didn’t know what it’s called like an advertisement. People don’t even know. Then, you know, they will just call somebody, come and supply, come and do this, you know. Because of the law, you have to tender. There must be a tender, which to some extent is very good. It has really improved.”
–Private organization respondent

The evidence from state-level responses is consistent with the federal guidelines for publicizing bid solicitations, demonstrating a determined effort to improve procurement transparency and competition at all levels of government.

In Kaduna, the publication of bidding procedures in national dailies as well as the establishment of the e-procurement platform in 2016 demonstrate a proactive effort toward transparency. The state’s efforts to consolidate bidding advertisements on the Kaduna State Public Procurement Authority’s website demonstrate its commitment to making procurement processes more accessible and transparent. This centralization not only simplifies access to information, but it also reduces the possibility of inconsistencies caused by using different distribution channels.

Similarly, in Ekiti, the use of various media—radio jingles, newspapers, notice boards and online platforms such as the Ekiti State Bureau of Public Procurement website—shows a comprehensive approach to ensuring broad reach and inclusivity in the procurement process. This method demonstrates an understanding that different sectors of the public acquire information through diverse channels, maximizing the spread of procurement opportunities. However, in the state, project finance and approval authority influence the practice of posting procurement opportunities. Public advertising of high-value contracts ensures rigorous examination and competitive bidding. Low-cost acquisitions, on the other hand, frequently avoid public advertising, potentially resulting in lower openness and accountability for smaller projects. This threshold method identifies a potential gap in the procurement process, where smaller contracts may not receive the same level of public inspection.

“Because like I said, not all procurements are advertised because there is a threshold for advertising project. Only those within the threshold of advertisement are advertised.”
-Federal respondent

Best practices in public procurement entail extensively advertising government contracts before the commencement of the procurement process, as stipulated in Section 25 of the Procurement Act (6 weeks). However, in Nigeria, advertising frequently appears around the start of the procurement process. The study by Njoku, Abdullahi, and Ahmed revealed that factors such as delay in releasing funds for advertising, pervasive adherence to secrecy, and political interference are responsible for delay in timely advertisement of procurement projects. Such delayed advertising drastically reduces the time for prospective vendors to prepare and submit bids, restricting participation and competitiveness. This does not only violate the principle of transparency, but it also creates an unfair playing field in which only suppliers with the fastest turnaround times may compete. This approach unintentionally disadvantages smaller or less well-resourced vendors, who may require more time to prepare full bids. This exclusionary impact goes against the purpose of guaranteeing fair competition and equal opportunity for all possible bidders. Furthermore, the limited bidding duration may result in unsatisfactory procurement outcomes. With fewer participants, the pool of proposals is smaller, which reduces the likelihood of receiving high-quality, cost-effective bids. Due to the reduced competitive pressure to provide the greatest value, this arrangement may lead to higher prices and potentially lower quality for government projects.

Bidding strategies

The choice of bidding methods is critical to determining the transparency of the public procurement process. In Nigeria, governments at all levels use both competitive and restrictive/selective bidding methods.

According to OECD, competitive bidding entails inviting a large number of bidders to respond to the invitation to tender or bid for procurement projects. Competitive bidding ensures transparency and is less prone to corruption. It promotes open competition, which increases the chances of receiving high-quality, cost-effective offers. It also reduces the likelihood of favoritism by ensuring that all possible vendors have an equal opportunity to participate, increasing public trust in the procurement process.

In contrast, restrictive or selective bidding is a procurement method that restricts the request for tender to a small number of suppliers, contractors, or service providers. This method can be more efficient in some situations, albeit less transparent. The method can speed up the procurement process and may be appropriate for specialized projects when a small number of providers have the necessary knowledge. However, it has major drawbacks because it reduces competition, which may lead to higher costs and lower quality outcomes as the incentive to provide the best value diminishes. Moreover, it creates the potential for bias and corruption because the selection criteria may be less rigorous or transparent.

The stakeholders interviewed at federal and state MDAs repeatedly stated that competitive bidding is the most common approach used.

“Open competitive bidding is the method usually used by the Kaduna State government.”
–State respondent

In Nigeria, the choice between open competitive bidding and restrictive bidding is influenced by the allocated procurement budget and the nature of the goods or services to be acquired. This decisionmaking process is crucial for balancing transparency with practicality and security.

For example, in cases of military procurement, the sensitive nature of the goods often necessitates restrictive bidding. This approach is consistent with international best practices, where security considerations override the usual preference for open competitive bidding. By limiting the pool of bidders to a select few, the government can mitigate risks related to national security and sensitive information. This method highlights the need for a nuanced approach to procurement, balancing transparency against specific security and confidentiality requirements.

Apart from this, for procurement projects with allocated funds below a certain threshold, such as those under N5 million, it may not be practical or necessary to adopt a formal bidding strategy. Instead, alternative procurement methods or simplified processes might be more appropriate. This aligns with the principle of proportionality, ensuring that the complexity and cost of the procurement process are commensurate with the project’s scale and budget. Simplified processes for smaller projects can reduce administrative burdens and increase efficiency while still maintaining accountability and compliance with relevant regulations. However, the absence of periodic reviews for these procurement methods raises concerns about potential abuse. Regular assessments could potentially manipulate the use of restrictive or simplified bidding processes to favor certain vendors or circumvent transparency measures. Implementing periodic reviews would ensure that procurement practices remain aligned with quality standards and adapt to changing needs and contexts. This would enhance accountability and prevent the erosion of trust in the procurement system.

Procurement thresholds for approval

The transparency of any public procurement contract is ensured by the approval granted by the relevant authorities, as stipulated by the law. In the context of Nigeria’s federal law, the Procurement Act of 2007 delineates distinct thresholds of approval for various authorities involved in the procurement process. These diverse thresholds aim to guarantee consistent and pragmatic procurement outcomes, thereby improving budget implementation and fostering a business-friendly environment. This collective effort ultimately promotes transparency in the procurement process. Table 1 provides the authorities that can approve a project based on the value of the project.

At the state level, procurement projects are approved in accordance with the federal approval pattern. The Kaduna Public Procurement Law provides details about the approval threshold for the state’s contracts. Specifically, the law stipulates that the State Executive Council can only approve a contract value above N100 million. Also, Ekiti State Public Procurement Law provides an approval threshold for procurement contracts in the state. However, all public procurement projects are approved and supervised by the Bureau of Public Procurement at the federal level and the State Bureau of Public Procurement.   

Disclosure of bidding evaluation criteria

To ensure openness in the procurement process, the evaluation criteria must be clearly communicated to all prospective bidders. Section 8 No. 49 of the Public Procurement Act of 2007 specifies the minimum requirements that bidders must achieve in order to be considered for procurement contracts. By sharing the evaluation criteria, the government reduces the possibility of favoritism and arbitrary decisionmaking, promoting a competitive and equitable bidding environment. This transparency not only fosters confidence among potential bidders, but it also increases the credibility of the procurement process. It ensures that contractors are selected based on merit and adherence to set standards, rather than subjective or ambiguous criteria.

Evidence from responders across MDAs shows that these criteria are routinely made available to all bidders. 

“If you’re talking about transparency, bidders are supposed to know their valuation criteria—the criteria on which they are supposed to be judged. So that’s supposed to be disclosed. So, we disclose the evaluation criteria.”
–Federal respondent

“We disclose everything that will guide the bidders. Everything they need to know is made public in the advertisement.”
–Federal respondent

Interviews with private groups provide some evidence to support the claim that MDAs reveal evaluation criteria to potential bidders. However, major obstacles still exist in the government contract bidding process, notably between bid submission and opening. These issues frequently include political influence and individual biases that favor specific bidders, affecting the transparency and fairness of public procurement programs. The time between bid submission and opening is critical because it is susceptible to manipulation and improper influence. Political intervention can bias the process, rewarding bidders with political clout over those who may provide greater value and quality. This not only jeopardizes the integrity of the procurement process, but it also hinders genuine competition, discouraging capable vendors from bidding in future bids due to perceived unfairness.

“You must have all the necessary documents to bid for a government contract, however, the problem is that between that bidding and the opening, the people evaluating it, that is where we can see many manipulations and all that. When it comes to bidding and opening, everybody has it once you pick the form, you have all your documents, and you have all your copies. You already have what is required, and so when they call you when they are asking, you know what it is all about.”
–Private organization respondent

The disclosure of bidding results is an important aspect of transparency in the public procurement process. However, responses from several ministries indicate discrepancies in this practice. Some ministries claim to notify both successful and unsuccessful bidders about the results, while others assert to informing only successful bidders.

This discrepancy in responses reveals a substantial gap in the procurement process, which has the potential to undermine the ideals of competitiveness, equity, and transparency. Notifying only successful bidders deprives unsuccessful bidders of valuable feedback and insights that could help them make better future bids. It also raises questions about the process’s integrity, as a lack of communication with defeated bids can undermine trust in the system.

“It is statutorily bound on us after bidding to brief the bidders on the outcome of the exercises. For you to know why you were not qualified. Maybe one of the criteria for bidding for procurements was not met by the companies that were not selected.”
–Federal respondent

“Once the contract is concluded, only the winner or winners would be published. It is not meant to be published to everybody.”
–Federal respondent

Despite MDAs’ mixed responses to the disclosure of procurement results, information from private business owners reveals a substantial gap: Unsuccessful bidders frequently do not receive feedback from the government. This lack of communication may jeopardize the transparency and effectiveness of the public procurement process.

“I have not seen any publication that says that one bid, ten people bid and one person gets this or that. They don’t even get back to you. You understand? To even let you know that you bided and lost. But they do some kind of publication. They put it on their notice board in their office, which you can go and check and see if your name is there or not. They only published those that they awarded the contract.”
–Private organization respondent

The analysis thus far reveals that, while Nigeria’s procurement process somewhat matches with worldwide criteria for open bidding, it falls short in important areas required for full transparency. Williams-Elegbe states that the Public Procurement Act only notifies successful bidders upon acceptance of their offers, while unsuccessful bidders only receive information on bid inspection, explanation, evaluation, and contract award recommendations after the award. This practice is in direct contrast to worldwide best practices.

According to the OECD, promoting transparency necessitates that the government disclose selection criteria and offer clear, timely details about the contract award mechanism before beginning the procurement process. Justifying the selection criteria and giving detailed contract award information are critical for limiting manipulation risks, encouraging healthy competition, and providing equal opportunity to all bids. These processes guarantee that all participants understand the rules and evaluation standards, which promote fairness and transparency. Furthermore, the OECD highlights the need for fully disclosing beneficiary identities, which include both the government and bidding enterprises. Nigeria’s procurement system currently lacks this level of transparency, showing a significant need for improvement. Full disclosure will increase accountability and trust by allowing stakeholders to ensure that procurement decisions are free of prejudice and undue influence.

Category of firms bidding for government projects

Analyzing the categories of firms eligible to bid for government contracts in Nigeria reveals that the Public Procurement Act does not provide preferential treatment depending on firm size. Legally, any firm, regardless of size, can engage in government procurement processes at both the state and federal levels. However, firms’ eligibility is closely related to the amount and scale of the project, which determines the credentials required for bidding on advertised procurement contracts.

Respondents at the federal level stated that procurement contracts worth less than N5 million are rarely advertised publicly. This approach allows both small and large enterprises to bid on these contracts, as long as they meet the Public Procurement Act’s conditions. Financial capability, technological expertise, and prior performance, among other characteristics, are typical.

Allowing different categories of firms necessitates an inclusive and competitive bidding environment. The approach aims to improve procurement processes and reduce administrative overhead by removing the requirement for public advertising for lower-value contracts.

“All. Both large and small. You know, it depends on the nature of the procurement or contract, but all categories of firms bid.”
–Federal respondent

“The categories of firms that bid must meet the core mandate for bidding as provided in PPA, 2007 (BPP), that is, they must be registered and pay taxes regularly. So small businesses can bid for projects or jobs worth 500,000 naira”
–Federal respondent

Section 34 of the Public Procurement Act contains a provision that favors domestic companies over international companies, particularly for projects that fit within the capabilities of local businesses. This is referred to as the margin of preference. According to the Act, a procuring body may provide this margin throughout the contract evaluation process, especially when comparing bids from domestic and foreign suppliers or locally-made versus foreign-manufactured items. This policy’s main goal is to assist and encourage homegrown companies to stimulate regional economic growth.

Dispute resolution

In any procurement process, it is not uncommon to encounter aggrieved bidders who may express dissatisfaction with the process. To ensure transparency, complaints from such aggrieved bidders must be diligently addressed. However, the responses received from the various respondents across MDAs show that they have not experienced such conflict arising from the contract. This response appears odd because it is not common to hear that all parties or stakeholders are pleased with the procurement process. A quick glance at the Public Procurement Act reveals that it lacks mechanisms for addressing disputes. Precisely, the act in Section 24 Number 26 states that all procurement contracts shall contain provisions for arbitral proceedings as the primary form of dispute resolution.

“We have not experienced any such dispute.”
-Federal respondent

“We have never had a dispute. We have never had it.”
–Federal respondent

At the state level, the people interviewed from the two states submitted that they have not heard or witnessed instances of disputes arising during the procurement process. As a result, information about dispute resolution mechanisms is currently unavailable.

In cases where firms, bidders, or contractors fail to adhere to the procurement contract’s terms and conditions, the MDAs do not have the authority to impose penalties on erring firms. Instead, the constituted law obligates the MDAs to hand over such non-compliant firms to the relevant authorities, such as the Bureau of Public Procurement, enforcement agencies, or anti-corruption agencies, for appropriate trial or prosecution.

While the respondents from both the federal and state levels did not explicitly provide reasons for the absence of disputes arising from aggrieved contractors in the country, evidence from independent private organizations indicates that there is a lack of a designated authority to address such complaints. There appears to be no established channel for lodging a complaint or seeking redress when a bidder fails to secure a contract. People generally believe that they have no choice but to accept the outcome.

“Who do you want to ask? Like in my case, because I have an insider, that is how I got to know that the permanent secretary has given it to his brother. But I was on my own, thinking that I had gotten the contract because of the assurance given to me by the director, only for me to discover that the contract had been given to another person. There is no person to report such a case to.”
-Private organization respondent

Resolution of disputes arising from procurement bids is one of the prerequisites for ensuring transparency. Thus, it is important to address this issue. In order to tackle the problems in Nigeria’s procurement process, it is crucial to establish a specialized dispute resolution entity with well-defined procedures, modify the Public Procurement Act to incorporate explicit provisions for resolving disputes, and provide an internet platform for submitting complaints. To guarantee transparency and accountability, it is essential to implement frequent audits, provide public reporting, and provide training for procurement officials and contractors. Seeking input from industry associations, carrying out trial programs to evaluate new methods, and conducting awareness campaigns will strengthen the system, guaranteeing a strong and equitable procurement process for all parties involved.

Monitoring of public procurement projects

The major goal of government procurement is to provide value for money when purchasing goods, services, and works, which requires competent monitoring of procurement projects to assure quality delivery. The Public Procurement Act of 2007 requires the Bureau of Public Procurement to oversee government projects from start to finish, guaranteeing adherence to established standards and procedures.

At the state level, comparable structures exist, with organizations such as the Kaduna State Public Procurement Authority and the Ekiti State Bureau of Public Procurement playing critical roles. The Ekiti e-procurement site, for example, is critical to project monitoring.

Despite these frameworks, responses from multiple MDAs reveal that many personnel are unaware of the precise methods for project monitoring, oversight, and execution. This lack of awareness weakens the effectiveness of the current oversight institutions.

To solve this shortage, independent organizations such as BudgiT have stepped in to monitor government projects at both the federal and state levels using its “Tracka” platform. Tracka enables citizens to follow budgetary capital expenditure and constituency projects, thereby improving service delivery by encouraging active public participation and creating a feedback loop between the public and government institutions. Also, the Private and Public Development Centre (PPDC), which was established in 2003, monitors procurement projects across the country using home-grown technology, data, innovation, research, community engagement, and political participation with the goal of promoting transparency and accountability in the execution of public projects. While commendable, the scope of Tracka and PPDC’s efforts is limited. Hence, a strong, state-led monitoring and evaluation structure is required to ensure full compliance and effective oversight of procurement programs. This framework should include ongoing training and awareness programs for MDA staff, clear project monitoring criteria, and the incorporation of citizen feedback systems to guarantee transparency and accountability in government procurement.

E-Procurement

E-procurement is critical for developing countries to address the lack of transparency in procurement processes. Its benefits go beyond curbing corruption; it streamlines operations, improves efficiency, lowers administrative expenses or costs, and encourages transparency. E-procurement also improves accuracy, promotes competition, and shortens procurement times (Nawi, et al., 2016). As a result, it improves service delivery and maximizes the use of public expenditures, making public institutions more efficient and effective.

The Nigerian government has acknowledged these benefits and is implementing reforms. President Muhammadu Buhari allotted N1.6 billion in 2016 to establish an e-government procurement platform that is still not operational. Meanwhile, the government launched the NOCOPO portal, which showcases ongoing procurement projects but is not a genuine e-procurement system.

At the state level, the World Bank has encouraged procurement reforms, particularly the use of e-procurement, to increase transparency. Kaduna State has led the way by building an e-procurement platform that has considerably increased transparency, allowing small enterprises to participate more actively in bidding.

Ekiti State has also benefited from World Bank assistance in implementing an e-procurement platform. This has resulted in standardized procedures, reduced complexity, and improved clarity. Digitalizing procurement records and data has increased information accessibility, leveled the playing field for small enterprises, and encouraged fair competition. 

“Kaduna State E-procurement is very transparent because you just have to interface with the computer. You don’t have to know anyone, you don’t have to seek favor from anyone, and all you need is to know how to use the computer. I assure you that the Kaduna State procurement system is more transparent than many states and even the federal government.”
-Private organization respondent, Kaduna

“The E-procurement process is very transparent. You can be in the comfort of your room, bid for a contract, and participate openly in the bidding process. In as much as your bid is the lowest responsive, you will be awarded the contract without support from any government officials.”
–Private organization respondent, Kaduna

“Like I told you, we came from a very crude procurement process. But after 2016, and 2017, it keeps getting better and better, and now you don’t need to know anyone to bid for a contract. If your technical and financial bids are accurate, you can win a contract from the comfort of your office.”
–Private organization respondent, Kaduna

Respondents in Ekiti highlight the significant benefits of the locally-designed e-procurement system, which has significantly increased transparency in the state’s procurement operations. The use of this system is a big step forward in modernizing procurement procedures in Ekiti. Not only does it adhere to global best practices, but it also tailors the strategy to meet the unique needs and challenges of the state.

“In the past, most of us didn’t really know the contract sum for a particular project, we just saw the project ongoing and said the government is working but on the OCDS now you will be able to see how much government has expended on this contract and also as you proceed and challenges are also there. There is one of our challenges; that we also need to populate the OCDS. That is also another area that requires manpower and ICT effort. We also want to be putting on the OCDS portal the extent to which the government has paid. For example, maybe there is a contract of 20 million, and the government has mobilized 5 million, you should be able to see that on this project, the government has paid 5 million and still has 15 million left to be paid. Most people believe that the moment they see the contract sum of the project, the entire sum has been handed over to the contractor for him to do the job, but most times they don’t see that the government paid on a mid-sum basis or installments.”
–Private organization respondent, Ekiti

In conclusion, the difference in the adoption of e-procurement between the state and federal levels highlights the importance of political will in advancing revolutionary projects. State governments have shown a proactive commitment, while a lack of political will, internal resistance, budgetary restrictions, and structural complexity may be the cause of the federal government’s delay. To successfully adopt e-procurement and promote accountability, efficiency, and openness in government procedures, political will is still a crucial prerequisite.

Challenges to effective transparency in the procurement process

Despite significant efforts by governments at both federal and state levels to promote transparency in the public procurement process, numerous challenges persist, leading to ineffectiveness and continued opaqueness in the procurement process.

At the federal level, a prominent challenge impeding the procurement process is the insufficient political will to fully implement the provisions outlined in the Public Procurement Act of 2007. This act includes a crucial proposal for establishing the National Council on Public Procurement (NCPP), tasked with the responsibility of evaluating, endorsing, and adjusting the monetary and prior review thresholds applicable to the provisions of the Public Procurement Act for various entities involved in the process.⁴ However, the lack of adequate political commitment has hindered the realization of this essential measure, thus affecting the overall transparency and effectiveness of the public procurement process. Apart from this, a lack of political will also manifests in the inability of various administrations’ governments to carry out significant reforms to address the deficiencies observed in the Public Procurement Act of 2007. Reforming the current Public Procurement Act is critical for meeting the emerging challenges in the procurement space and improving government service delivery in the public sector. Succinctly, continuous reforms ensure or foster accountability, efficiency, transparency, and fairness in the allocation of public funds. Most significantly, these reforms are crucial for combating corruption in the public procurement process.

Despite the government’s efforts to implement e-procurement, the realization of the procurement portal project is still pending. Back in 2016, the government announced its intention to modernize the procurement system, recognizing the potential benefits of e-procurement. It was estimated that the introduction of e-procurement could lead to cost savings of up to $270 million USD, which could then be redirected towards providing essential social services to citizens. In 2020, the government took a significant step forward by committing a substantial amount of N1.6 billion ($4.5 million USD) to initiate the implementation of the government e-procurement platform. This financial commitment demonstrated the government’s commitment to embracing technological advancements in the procurement process. However, despite the allocation of funds and the intentions set forth, the implementation process is still ongoing, as reported by respondents from various MDAs.

“E-procurement is still underway. They are working on it in our head office.”
–Federal respondent

Political intervention is another challenge that poses a significant obstacle to Nigeria’s procurement process transparency. Regrettably, political interests often take precedence over the socioeconomic justifications that should underpin procurement decisions. These political interests manifest in various forms, including ethnic considerations. This political consideration often results in the allocation of procurement contracts to unsuitable contractors.  This phenomenon undermines the principles of fairness, efficiency, and accountability that should govern the procurement process. It also further corrupts the integrity of the procurement process. Such actions divert resources away from their intended purposes, weakening public trust and eroding the credibility of the procurement system.

Access to comprehensive and meaningful procurement data remains a significant challenge in Nigeria, despite the introduction of the NOCOPO portal by the government to display ongoing contracts. While the initiative represents a step towards transparency, the current platform often falls short in providing timely and comprehensive data required for effective planning and policy formulation.

The skewed distribution of procurement workers across MDAs poses a significant challenge to Nigeria’s procurement landscape. This phenomenon is characterized by some procurement officers lobbying to be posted to what is perceived as “juicy” MDAs, resulting in an overpopulation of procurement workers in these select agencies. Conversely, certain MDAs experience a shortage of procurement officers, which detrimentally impacts their overall performance. The uneven distribution of procurement workers often leads to several issues, such as inefficient resource allocation, uneven workloads, lack of expertise, increased corruption risk, and inadequate or unequal service delivery.

“They have gone through some online courses for training. However, that does not mean that they are sound. There are about five of us working on procurement in this department. We are supposed to be more than that. We are five. Like I told you before, it is the nature of this department because this department is not the department that engages in sophistication in procurement. So, we need more procurement specialists in this ministry. People went to where things are happening.”
-Federal respondent

At the state level, despite the implementation of e-procurement platforms in the states, which were expected to enhance transparency and efficiency in the procurement processes, several challenges persist, hindering the full realization of the intended benefits.

In Ekiti, evidence from our KIIs showed that the state, with the help of the World Bank, established an e-procurement platform in 2022. However, procurement officers and vendors do not have enough capacity to maximize the benefits of this development. It was revealed by both some women in business and civil society that they cannot utilize and engage in the process. This is because many women-owned businesses are small in size and therefore lack the technical skills, particularly ICT and negotiation skills, required to bid for public procurement, especially bids that involve the use of e-procurement platforms. Additionally, according to the UN-Women report, several challenges face women-owned businesses, including a lack of financial capacity, deficiencies in business management, family obligations, and societal norms. In a male-dominated business environment, networking may become difficult for women because of issues such as sexual harassment.  Besides, some contracts, such as the procurement of works that include construction and engineering, are considered masculine works, and thus women by societal standards may not be considered for such contracts. These societal beliefs, norms, or biases prevent women from fully participating in the public procurement space in developing countries like Nigeria.

“Yes, one thing we need to do is to have a home-grown e-procurement portal and also there was one we deployed through support from the World Bank which we got from European Dynamics. So, we have that e-procurement portal we are running presently in Ekiti State.”
-Private organization respondent, Ekiti

“The e-procurement platform we are not yet conversant with and we need to be strengthened in that area.”
–NGO respondent, Ekiti

Conclusion and critical reform areas for transparency

This report highlights efforts undertaken by both federal- and state-level MDAs in Nigeria to enhance transparency within their procurement practices. These efforts are vital in combating corruption, ensuring accountability, and optimizing the utilization of public resources. The widespread dissemination of procurement opportunities through national newspapers and the Federal Tender Journal is a positive step, reflecting the commitment of MDAs to broaden participation and increase transparency.

The global policy environment is dynamic, necessitating policymakers to remain proactive in adapting to evolving developments within the realm of policy. Consequently, reforms within the public sphere must harmonize with the advancements occurring in the public arena. In the context of procurement practices in Nigeria, there is a clear indication that the federal government still has significant ground to cover. The analysis conducted thus far reveals that substantive reforms concerning federal-level procurement have not materialized in recent years. This is particularly related to the implementation of e-procurement and the inauguration of the National Council on Public Procurement. All procurement operations continue to operate within the framework of the 2007 Procurement Act, which experts widely acknowledge as outdated. The prolonged existence of a law without corresponding reforms creates opportunities for individuals to devise adaptive mechanisms that exploit its shortcomings, thereby subverting its intent. This phenomenon is similar to the concept of “creative accounting” in finance, where a system ostensibly adheres to accounting regulations, but accountants use these loopholes to manipulate financial records by capitalizing on identified gaps. As a result, it becomes imperative to embark on a path of reforms aimed at bolstering the transparency of the procurement process in Nigeria.

First, the existing 2007 Public Procurement Act requires immediate and comprehensive amendments to align with the evolving landscape of procurement best practices within the international community. This legislative framework necessitates substantial revision to meet internationally recognized standards, thereby ensuring a transparent and equitable procurement process. Reforms must encompass various aspects, including the promotion of fair competition, accommodation of diverse interests, and the inclusion of enterprises such as small-scale and women-owned businesses.

Second, the adoption of e-procurement has been universally recognized as indispensable in ensuring transparency within the procurement process. Embracing e-procurement acts as an effective deterrent against corruption, primarily by reducing interpersonal interactions that frequently foster instances of official misconduct. E-procurement has the potential to facilitate meticulous procurement tracking by both governmental entities and suppliers, in addition to its ability to digitize the procurement process. Also, e-procurement makes it easy for the government to centralize the procurement process, facilitate electronic bidding, automate every facet of procurement, and facilitate procurement data analysis. The present prevailing public procurement space is marred by superfluous bureaucratic procedures that contribute to the protracted and cumbersome nature of the procurement process. The transition to e-procurement provides a viable solution by streamlining the cumbersome procurement process and eliminating unnecessary complexities. Given the compelling rationale underpinning e-procurement, it becomes an imperative prerogative for governments to promptly implement this electronic platform. Such swift implementation not only amplifies transparency within the procurement milieu but also ensures an enhanced focus on fiscal prudence and optimal utilization of resources.

Third, disputes are an inevitable part of every engagement, including public procurement contracts. When such a situation arises, there is a need to have formal dispute resolution mechanisms for resolving such disputes, because a lack of such mechanisms is detrimental to the procurement process and trust in the public engagement between government officials and bidders. To address the lack of dispute resolution in Nigeria’s public space, the government should establish an independent public procurement dispute resolution body, which could be under the Federal Ministry of Justice. The body should be saddled with the responsibility of handling grievances arising from the bidding process and restoring or bringing about transparency in the public procurement process. The body’s operation must be governed by a clear legal framework. This legal framework could be drafted by the Federal Ministry of Justice through consultation of relevant stakeholders in the public procurement space.

Finally, to enhance transparency, collaboration among government bodies, policymakers, and stakeholders is imperative. In fact, to foster this collaboration, all MDAs must endeavor to make all disclosable information—from the inception of procurement to the end of the procurement cycle—transparently available to all relevant stakeholders. This will lead to a more transparent, efficient, equitable, and accountable public procurement system in Nigeria. While substantial progress has been made, and the ongoing effort by the government to revamp and reform the Public Procurement Act of 2007 serves as a right step in the right direction, there remains a need for continuous alignment with best practices to ensure the integrity of procurement processes.

Annex 1: Interviewed stakeholders