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Informal networks of corruption: assessing the challenges for public sector whistleblowing in Nigeria

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Abstract

Recently, the Nigerian government adopted its first National Anti-Corruption Strategy—the first since its independence in 1960. While the strategy captures varying forms of corruption, whistleblowing is seen as one of the key strategies identified to confront anti-corruption in the public sector. The adoption of the whistleblowing policy and its on-going implementation however occurs without a legislative framework to protect whistleblowers. This article situates the whistleblower program in the wider socio-political context of anti-corruption in Nigeria, and public governance. The paper critically examines the implications of the legislative gaps for the long-term sustenance of the whistleblower protection program. This paper argues that the whistleblowing program is embedded in the wider socio-political and informal social norms that have historically privileged corruption in Nigeria. To enhance the overall effectiveness and institutionalization of the whistleblowing program in Nigeria, this paper contends that the urgent adoption of a comprehensive legislative protection framework is a minimum requirement. Significant practical steps must be taken to address the complex background of informal social networks of corruption, power dynamics, and social norms that are peculiar to the Nigerian economic and political context.

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Notes

  1. Transparency International, Corruption Perception Index 2016 (Jan. 25, 2017), https://www.transparency.org/news/feature/corruption_perceptions_index_2016; also see, The World Justice Project (WJP), Rule of Law Index 201, (2017) https://worldjusticeproject.org/our-work/wjp-rule-law-index/wjp-rule-law-index-2017–2018; See generally, Femi Falana, Why the Nigerian Government is Losing Corruption Cases, Premium Times (Apr. 15, 2017), http://opinion.premiumtimesng. com/2017/04/15/why-government-loses-corruption-cases-by-femi-falana/(decrying the lethargy in the prosecution of anti-corruption cases and the recent rise in the number cases lost by the government, Falana “predict[ed] that the federal government stands to lose more corruption cases unless the authorities are prepared to reorganise the anti-graft agencies and review the anti-corruption policy in line with the proposals designed by the Presidential Advisory Committee Against Corruption (PACAC) on the prosecution of politically exposed persons”).

  2. See, Federal Government of Nigeria, Federal Ministry of Finance—Whistle Blowing (FAQs), https://whistle.finance.gov.ng/_catalogs/masterpage/MOFWhistle/assets/FMF%20WHISTLEBLOWING%20FREQUENTLY%20ASKED%20QUESTIONS.pdf If an informant has evidence to support his or her disclosure, it must be submitted either via the portal or in writing to the special unit of the ministry. Examples of “information” that may be provided include violation of government’s financial regulations, mismanagement or misappropriation of public funds and assets, concealed and stolen public funds, financial malpractice or fraud, theft, collection or solicitation of brides, diversion/underreporting of revenues, conversion of public funds for private use, splitting of contracts, violation of procurement procedures and procurement fraud; also see generally, Federal Ministry of Finance Whistleblowing Portal, http://whistle.finance.gov.ng/Pages/default.aspx.

  3. Nigerian Federal Ministry of Justice, National Anti-Corruption Strategy—2017–2020, (Feb. 10, 2017); Also See, Fatima Waziri–Azi, An Evaluation of the Nigeria National Anti-Corruption Strategy, 5 Eur. J. Res. Soc. Sci. 1, 1–9 (2017); Frank Eleanya, FG Adopts 5 Year National Anti-Corruption Strategy, Bus. Day Newspapers, (Apr. 27, 2017) http://www.businessdayonline.com/fg-adopts-5-year-national-anti-corruption-strategy/; Building the Critical Mass for the National Anti-Corruption Strategy, Premium Times, (May 15, 2017), http://www.premiumtimesng.com/opinion/editorial/231250-editorial-building-the-critical-mass-for-the-national-anti-corruption-strategy.html.

  4. See Olusegun Obasanjo, The Role of the Church In the Fight Against Corruption In Nigeria, Premium Times, (Apr. 8, 2017), https://opinion.premiumtimesng.com/2017/04/08/the-role-of-the-church-in-the-fight-against-corruption-in-nigeria-by-olusegun-obasanjo/On the potential role of faith organizations in anti-corruption graft in Nigeria.

  5. Whistleblower Policy: A Successful FG’s Initiative, says Adeosun, Vanguard, (Aug. 15, 2017) https://www.vanguardngr.com/2017/08/whistleblower-policy-successful-fgs-initiative-says-adeosun/.

  6. William Q. Judge & D. Brian McNatt, The Antecedents and Effects of National Corruption: A Meta-Analysis, 46 J. World Bus. 93–103 (2011).

  7. “Discourse” is used here in the Foucauldian context to describe the variety of ways of the representation of corruption as a social reality. See, Akhil Gupta, Blurred Boundaries: The Discourse of Corruption, the Culture of Politics and the Imagined State, 22 Am. Ethnologist 375–402 (1995).

  8. Balakrishnan Rajagopal, Corruption, Legitimacy and Human Rights: The Dialectic of the Relationship, 14 Conn. J. Int’l L. 495–507 (1999) (Deploying what he describes as a “critical development theory”, Rajagopal argues that “corruption discourse performs the task of re-legitimating particular conceptions of development, rule of law, democracy and human rights that are elitist, statist and Eurocentric).

  9. See generally, Leena Koni Hoffmann & Raj Navanit Patel, Collective Action on Corruption in Nigeria: A Social Norms Approach to Connecting Society and Institutions, Chatham House Report, Royal Inst. Int’l Affairs 5, (May 2017). The report which is a social norms approach to anti-corruption in Nigeria is based on field research undertaking in Nigeria from October to November 2015 and for 4 months in 2016. The survey was conducted in urban and rural areas in six states: Adamawa, Benue, Enugu, Lagos, Rivers and Sokoto and in the Federal Capital Territory of Abuja. Also, “the report proposes the integration of behavioral lessons in anti-corruption policymaking, and advocates strategies for expanding Nigeria’s knowledge base and capacity concerning behavior and social norms-based interventions and solutions.” In the context of other countries in Africa and beyond, see, Claudia Baez-Camargo & Alena Ledeneva, Where Does Informality Stop and Corruption Begin? Informal Governance and the Public/Private Crossover in Mexico, Russia and Tanzania, 95 Slavonic & E. Eur. Rev. 49–75 (2017).

  10. See generally, A. J. Brown & Marika Donkin, Introduction, in Whistleblowing In The Australian Public Sector: Enhancing The Theory And Practice Of Internal Witness Management In Public Sector Organisations 21 (A.J. Brown ed., 2008); Janet P. Near & Marcia P. Miceli, Organizational Dissidence: The Case of Whistle-blowing, 4 J. Bus. Ethics 1-16 (1985); Janet P. Near & Marcia P. Miceli, Whistle-blowing: Myth and Reality, 22 J. Mgmt. 507, 507-526 (1996).

  11. Federal Government of Nigeria, supra note 2.

  12. In relation to the FMF-Whistle Program, see, Federal Government of Nigeria supra note 2.

  13. See, Gerry Ferguson, Global Corruption: Law, Theory and Practice 12-48 (2d ed. 2017); https://icclr.law.ubc.ca/wp-content/uploads/2017/06/Global-Corruption-Law-Theory-and-Practice-2017-1-1.pdf.

  14. Federal Government of Nigeria, supra note 2.

  15. Id, at 3.

  16. Id, at 4.

  17. Id.

  18. Id.

  19. Id.

  20. See, Channels Television, Raid On Ekweremadu’s House: Police Arraign Ahmed Echoda Over False Information (May 30, 2017), http://www.channelstv.com/2017/05/30/raid-ekweremadus-house-police-arraign-ahmed-echoda-false-information/(In this regard, a prosecution is already underway for the disclosure of false and malicious information against the Deputy Speaker of the Nigerian House of Representatives, although, it is unclear if the will to prosecute the case has progressed quickly because of the status of the individual wrongly accused).

  21. Federal Government of Nigeria, supra note 2, at 4.

  22. Whistle-Blower Policy: EFCC Recovers N17billion, Premium Times (Apr. 28, 2017), http://www.premiumtimesng.com/news/top-news/229850-whistle-blower-policy-efcc-recovers n17billion.html; Taline McPhedran, $43 million in Cash Found in Empty Nigerian Apartment, CTV News (Apr. 14, 2017), http://www.ctvnews.ca/mobile/business/43m-in-cash-found-in-empty-nigerian-apartment-1.3368884.

  23. How Whistleblower was Dismissed for Exposing Corruption in Federal Mortgage Bank, Sahara Reporters (Jun. 10, 2017). http://saharareporters.com/2017/06/10/how-whistleblower-was-dismissed-exposing-corruption-federal-mortgage-bank; also see, Group Demands Reinstatement of Sacked Whistleblowers, Premium Times (Jun. 12, 2017) http://www.premiumtimesng.com/news/more-news/233794-group-demands-reinstatement-of-sacked-whistle-blowers.html.

  24. Oladeinde Olawoyin, Civil Society Organizations Call for Reinstatement of Suspended Police Whistle-Blower, Premium Times, (Mar. 12, 2017) http://www.premiumtimesng.com/news/more-news/225905-civil-society-organisations-call-reinstatement-suspended-police-whistle-blower.html (This single example should not be taken as a generalization of the practice. It is only a warning of the pitfalls that await a public servant whistleblower in the absence of a protective legislation. The question whether such legislation will be implemented, assuming it exists, is outside the purview of this article). Other instances of retaliation exist: One Aaron Kaase, a Principal Administrative Officer at the Police Service Commission (PSC). Although the matter predates the adoption of the Whistleblower Policy, it is worth highlighting. On May 22, 2015, he submitted an evidence-based petition to the Independent Corrupt Practices and other Related Offences Commission (ICPC) against the Chairman, Mike Okiro, alleging acts of corruption. Following Kaase’s petition against Okiro, the PSC issued a letter backdated to May 21, 2015, suspending him from work indefinitely without pay. They claimed that he was suspended because of a prima facie case of serious misconduct based on spurious arrest and detention by the police, and arraignment on a fictitious criminal charge. Kaase received no previous query nor was any claim of “serious misconduct” a subject of any investigation that established guilt against him. For more than two years he has remained on suspension without pay while his fundamental rights are continuously violated. The Civil Society Network Against Corruption, CSNAC, has called for the reinstatement of a whistle-blower in the Police Service Commission; How Whistleblower was Dismissed for Exposing Corruption in Federal Mortgage Bank, Sahara Reporters, (Jun. 10, 2017), http://saharareporters.com/2017/06/10/how-whistleblower-was-dismissed-exposing-corruption-federal-mortgage-bank. The other relates to Mr. Murtala Aliyu Ibrahim, Unit Head/ICT Process Audit and Special Investigation Unit at the Federal Mortgage Bank of Nigeria (FMBN). He had exposed contract scams within the bank and for refused to endorse the bank’s 2016 Half-Year Income Validation Report that basically covers-up the fraud. Instead of addressing the alarm raised by Ibrahim, a memo dated 8th December 2016 signed by the Executive Management Committee transferred him from the head office to a remote location of the FMBN. Hoping to get some immediate redress from the retaliatory action of transferring him and addressing wider corruption within the bank, Mr. Ibrahim petitioned the Minister of Power, Works, and Housing through a series of letters. This effort however proved futile as he was later dismissed from service. Mr. Ibrahim now seeks to challenge his dismissal before a court of law contending that his actions were taken in line with the whistle-blowing policy of the Federal Government. The African Centre for Media & Information Literacy has called on the Minister for the immediate reinstatement of Mr. Ibrahim.

  25. Soni Daniel, Ministry Fires Whistle-Blower Who Exposed $229,000 Fraud, Vanguard (Mar. 4, 2017) http://www.vanguardngr.com/2017/03/ministry-fires-whistle-blower-exposed-229000-fraud/.

  26. Id. (“Thompson alleged that the acting DG was advised by the EFCC official responsible for the investigation, to, instead of refunding the $229,000, undertake trips to countries where projects were executed and bring evidence of travels.”).

  27. Abdullateef Salau, Ntia Thompson: Claims, Counter Claims Of Dismissed Whistle-Blower, Daily Trust (Apr. 7, 2017), https://www.dailytrust.com.ng/news/general/ntia-thompson-claims-counter-claims-of-dismissed-whistle-blower/192548.html.

  28. Id. According to the minister, the Federal Government of Nigeria has:

    “a comprehensive report on it and all the issues raised and steps taken…I’m going to look at every aspect of it and if there is a slight, even slightest possibility that there could have been any action that was taken as a result of this person being a whistle blower, I can give you an assurance and guarantee that damages will be paid and the person will be reinstated”.

    Also see, FG Ends Silence on Ntia Thmpson’s Case, Assures to Protect, Reward Whistle-blowers, Bus. Highlights (Mar. 20, 2017) http://businesshilights.com.ng/fg-ends-silence-on-ntia-thompsons-case-assures-to-protect-reward-whistle-blowers/.

  29. AFRICMIL Worried Over Sack of Whistleblower by FMBN, Failure to Reinstate Another by Foreign Affairs Ministry, African C. Media & Info. Lit’cy (Jun. 12, 2017), http://www.africmil.org/whistle-blowers-under-threat-africmil-worried-over-sack-of-whistle-blower-by-fmbn-failure-to-reinstate-another-by-foreign-affairs-ministry/.

  30. See, Soni Daniel, $229,000 Scam: Foreign Ministry Recalls Whistleblower, Vanguard (Jun. 22, 2017), http://www.vanguardngr.com/2017/06/229000-scam-foreign-ministry-recalls-whistleblower/(A letter dated June 20, 2017 with reference No. PSO/C.430/11 recalling Mr. Thompson read as follows:

    “I am directed to refer to the appeal you forwarded to the Office of the Head of Civil Service of the Federation, OHCSF, in respect of your disengagement from service on the grounds of wrongful suspension, from service for exposing fraud in the Directorate of Technical Cooperation in Africa, DTCA, and to inform you that the Head of the Civil Service of the Federation has approved your appeal for: re-instatement into the service pending the outcome of the investigation into the fraud by the Economic and Financial Crimes Commission. Accordingly, have been reinstated into the service with effect from February 23, 2017. You are, therefore, to report to the Directorate for Technical Cooperation in Africa, DTCA, for further directives…”.

  31. Bassey Udo, Nigerian Agency Celebrate Amid Lingering Corruption Allegations, Premium Times (Aug. 1, 2017) http://www.premiumtimesng.com/news/top-news/238775-nigerian-agency-celebrates-amid-lingering-corruption-allegations.html. (“Despite his reinstatement, the officials involved continued their acts of intimidation and harassment against Mr. Thompson, who was neither restored to his office as directed by the minister, nor his arrears of salary since January 2017 paid to him.”).

  32. Cletus Ukpong, Nigerian Govt Pledges to Review Cases of Citizens Punished for Exposing Corruption, Premium Times (Mar. 19, 2017), http://www.premiumtimesng.com/news/top-news/226534-nigerian-govt-pledges-review-cases-citizens-punished-exposing-corruption.html.

  33. Id.

  34. See, Strengthening Whistleblower Protection: An International Imperative, Transparency Int’l, (Jun. 7, 2013). https://www.transparency.org/news/feature/strengthening_whistleblower_protection_an_ international_imperative.

  35. See generally, International Principles for Whistleblowing Legislation, Transparency Int’l (Nov. 5, 2013), https://www.transparency.org/whatwedo/publication/whistleblowing_in_europe_legal_protections_for_whistleblowers_in_the_eu; Mark Worth, Whistleblowing in Europe: Legal Protections for Whistleblowers in the EU, (2013); Council of Europe, Protection of Whistleblowers: A Brief Guide for Implementing a National Framework, (Aug. 2016), https://edoc.coe.int/en/fundamental-freedoms/7053-protection-of-whistleblowers-a-brief-guide-for-implementing-a-national-framework.html.

  36. Marcia P. Miceli, An International Comparison of the Incidence of Public Sector Whistle-Blowing and the Prediction of Retaliation: Australia, Norway, and the US, 72 Austl. J. Pub. Admin. 433–446 (2013).

  37. Ferguson, supra note 13, at 12–13.

  38. Gregory Liyanarachchi & Chris Newdick, The Impact of Moral Reasoning and Retaliation on Whistleblowing: New Zealand Evidence, 89 J. Bus. Ethics 37-57 (2009); David B. Greenberger, et al., Oppositions and Group Norms: The Reciprocal Influence of Whistle-Blowers and Co-Workers, 6 J. Bus. Ethics 527–542 (1987); Marcia P. Miceli & Janet P. Near, Relationships Among Value Congruence, Perceived Victimization, and Retaliation Against Whistle-Blowers, 20 J. of Mgmt. 773–794 (1994).

  39. Nigerian National Anti-Corruption Strategy, Federal Ministry of Justice (Jul. 5, 2017).

  40. Id, at 15–18.

  41. Id, at 27; Federal Government of Nigeria, supra note 2 (For the Nigerian government’s secure online portal through which information bordering on violation of financial regulations, mismanagement of public funds and assets, financial malpractice or fraud and theft that is deemed to be in the interest of the public can be disclosed).

  42. These bills include: The Public Interest Disclosure Bill 2015, HB 03, is currently under consideration by the Nigerian House of Representatives. It was first introduced on July 28, 2015 and on same day it passed the First Reading. On December 15, 2015, it passed the second reading and two years later, the House Committee on Justice provided its report on the Bill to the House on January 26, 2017. No further action known to the author has since been reported on the Bill. (Copy on file with the author)

    The Public Interest Disclosure Bill 2015, HB 03, is currently under consideration by the Nigerian House of Representatives. It was first introduced on July 28, 2015 and on same day it passed the First Reading. On December 15, 2015, it passed the second reading and two years later, the House Committee on Justice provided its report on the Bill to the House on January 26, 2017. No further action known to the author has since been reported on the Bill. (Copy on file with the author). The Witness Protection Programme Bill 2015, HB 132, is also before the Nigerian House of Representatives. It was first introduced on November 25, 2015 and has since under First and Second Reading respectively on November 25, 2015 and February 23, 2016 and was passed by the lower House on June 7, 2016. While it appears, the Bill was introduced into the Nigerian Senate on October 11, 2016, no further activity has been reported on the Bill. (Copy on file with the author). The second Witness Protection Programme Bill 2015, SB 157 was introduced in the Nigerian Senate on December 8, 2015. It differs in substance from the version introduced in the lower house and has gone through Second Reading on October 19, 2016 with eventual passage on June 8, 2017. The Bill is yet to be introduced to the House of Representatives for consideration. (Copy on file with the author). The Whistle Blowers Protection Bill, 2016, SB 158 was also first introduced in the senate on March 15, 2016. It passed Second Reading October 19, 2016 with eventual passage by the Senate on June 8, 2017. The Bill is yet to be introduced to the House of Representatives too. (Copy on file with the author). The Whistle Blower Protection Bill 2017, HB 1073, was first introduced before the House of Representatives on July 12, 2017. It has not gone beyond the first reading.

  43. Irma E. Sandoval, Contemporary Debates on Corruption and Transparency: Rethinking State, Market, and Society (2011); David Banisar, Whistleblowing: International Standards and Developments (2011).

  44. Rajagopal, supra note 8, at 505.

  45. Id., at 507.

  46. See, Carmen Malena, et al., Social Accountability: An Introduction to the Concept and Emerging Practice, (Dec. 1, 2004) http://documents.worldbank.org/curated/en/327691468779445304/Social-accountability-an-introduction-to-the-concept-and-emerging-practice (The World Bank defines social accountability as “the broad range of actions and mechanisms beyond voting that citizens can use to hold the state to account, as well as actions on the part of government, civil society, media and other societal actors that promote or facilitate these efforts”).

  47. J.P. Olivier de Sardan, A Moral Economy of Corruption in Africa?, 37 J. Modern Afri. Stud. 25–52 (1999).

  48. Hoffman & Patel, supra note at 9; also see, Cristina Bicchieri & Hugo Mercier, Norms and Beliefs: How Change Occurs, Academia (2014) https://www.academia.edu/1596868/Norms_and_Beliefs_How _Change_Occurs; Maria Xenitidou & Bruce Edmonds, Complexity of Social Norms 37–54 (2014).

  49. See, Claudia Baez-Camargo & Alena Ledeneva, Where Does Informality Stop and Corruption Begin? Informal Governance and the Public/Private Crossover in Mexico, Russia and Tanzania, 95 The Slavonic & E. Eur. Rev. 49-75 (2017) (Innovations in Corruption Studies); According to the authors:

    in spite of cultural, historical and regional diversity, the three countries … share a characteristic that is stubbornly persistent outside of the developed world: the failure to control corruption notwithstanding the adoption of exemplary legal frameworks that incorporate many of the internationally recognized best anti-corruption practices.

  50. Id, at 50.

  51. Id., at 52.

  52. Id.

  53. See, P. Selznick, Foundation of the Theory of Organisation, 13 Am. Sociological Rev. 25–35 (1948); For various iterations of the concept of co-optation is social sciences scholarship, see G. Bertocchi & M. Spagat, The Politics of Co-optation, 29 J. Comp. Econ. 591 (2001); Patrick G. Coy, Co-optation: The Wiley-Blackwell Encyclopedia of Social and Political Movements, (1993).

  54. Baez-Camargo & Ledeneva, supra note 49, at 53. (“The criteria for such recruitment and the non-transparency of the redistribution are both linked to corrupt behaviors”).

  55. Id., at 62.

  56. Baez-Camargo & Ledeneva, supra note 49, at 68.

  57. Claudia Baez-Camargo & Nikos Passas, Hidden Agendas, Social Norms and Why we Need to Re-Think Anti-Corruption 2017, OECD Global Anti-Corruption & Integrity Forum (2017) https://www.oecd.org/cleangovbiz/Integrity-Forum-2017-Baez%20Camargo-Passas-hidden-agendas-social-norms.pdf.

  58. Id.

  59. See, Jean-Francois Bayart, The State in Africa: The Politics of the Belly, (1993). Author is aware that political scientists have addressed this question in the context of “clientelism” and “belly-politics” in Africa. However, author has deliberately framed the analysis differently in order to open up new paths of analysis to interrogate the complex issue of corruption that is not bound to end in doom or outright failure.

  60. Baez-Camargo & Passas, supra note 57, at 3.

  61. British Academy, BA/DFID Anti-Corruption Evidence Partnership (2015), https://www.britac.ac. uk/node/3584; Since 2015, a series of empirical multi-disciplinary research projects funded by The British Academy currently examine various aspects of informal governance both in the context of corruption, collective action and public service more broadly. British Academy, Informal Governance and Corruption—Transcending the Principal Agent and Collective Action Paradigms, https://www.britac.ac.uk/node/4660. In particular, see, Claudia Baez Camargo, et al., Informal Governance and Corruption—Transcending the Principal Agent and Collective Action, British Academy (2017); This “multidisciplinary research team combines unique regional expertise and practical experience in order to produce evidence for the relevance of informality for the 'localisation’ of anticorruption strategies, thus enhancing their impact, and for a new generation of policies harnessing the potential of local patterns of informality.”. Also see, Gerhard Anders, et. al., Accountability through Practical Norms: Civil Service Reform in Africa from Below, British Academy (2017) (The project, presently in its second year, explores:

    ways to improve service delivery and levels of integrity by drawing on empirical evidence on practical informal norms in key government departments (health and education) in Sierra Leone, Senegal, Togo, Niger, Tanzania and Malawi. It will be the first comparative, cross-country study employing anthropological and socio-legal methods at a large scale to generate systematic empirical evidence on practical norms covering francophone and Anglophone countries in two regions, West and East Africa.

  62. See, Baez-Camargo and Passas, supra note 57.

  63. Hoffman & Patel, supra note at 8.

  64. See, Bill Libit, et al., Elements of an Effective Whistleblower Hotline, Harvard Law School Forum on Corp. Gov. & Fin. Reg. (Oct. 25, 2014), https://corpgov.law.harvard.edu/2014/10/25/elements-of-an-effective-whistleblower-hotline/.

  65. James Gerard Caillier, An Examination of the Role Whistle-Blowing Education Plays in the Whistle-Blowing Process, 54 Soc. Sci. J. 4–12 (2017).

  66. The modest success that the program has enjoyed since its introduction attests to this fact.

  67. See, Baez-Camargo and Passas, supra note 57.

  68. Id.

  69. See, Yoon Jik Cho & Hyun Jin Song, Determinants of Whistleblowing Within Government Agencies, 44 Pub. Personnel Mgmt. 450-472 (2015). For empirical studies on the link between whistleblowing education and whistleblowing intentions.

  70. See, Ayo Sogunro, Why Whistle-Blowing Won’t Save Nigeria, African Arguments (May 4, 2017), http://africanarguments.org/2017/05/04/whistle-blowing-wont-save-nigeria/.

  71. Nigeria Must Strengthen Anti-Corruption Bodies and Increase Transparency on Asset Recovery, Transparency International (June 16, 2016), https://www.transparency.org/news/pressrelease/nigerian_must_strenghthen_anti_corruption_bodies_and_increase_transparency.

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    Olabisi D. Akinkugbe

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Akinkugbe, O.D. Informal networks of corruption: assessing the challenges for public sector whistleblowing in Nigeria. Jindal Global Law Review 9, 11–28 (2018). https://doi.org/10.1007/s41020-018-0055-5

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