Written evidence submitted by Mr Justin Moore (IRN0024)


Implementing the Integrated Review in Nigeria


Better data is needed to support a coherent approach across government


Key points






The government has already taken this approach to another of its key policy objectives – improving the environment - and therefore should be able to apply it to its foreign policy goals.




  1. I’m a policy analyst with over 18 years’ experience and run Development Monitor, an initiative to promote better data about the UK’s interactions with developing countries. I publish a dashboard of major financial flows between the UK and developing countries, and research how improved data can support more effective and coherent policies.


Coherent action is needed across government


  1. Coherent policies and effective implementation of policy across government are needed in order for the UK to make progress on its objectives towards Nigeria. The importance of coherent action is illustrated by the following examples.


Tackling biodiversity loss, defending human rights


  1. Although the activities of UK companies can make a positive economic contribution to Nigeria, there is also a risk that they undermine UK objectives to tackle biodiversity loss and defend human rights.


  1. Prominent examples are oil spills by the Nigerian subsidiary of UK-listed Shell which have had a disastrous environmental impact on the Niger Delta. Cleaning up the area will cost at least $1bn and take up to 30 years, according a United Nations report[i].  Oil pollution contributes[ii] to habitat destruction and biodiversity loss and has led to serious human rights impacts[iii], on people’s health and ability to access food and clean water.


  1. Shell’s subsidiary accepted[iv] that the oil spills in 2008 resulted from the failure of old and poorly maintained pipelines. However, so far only 11% of the total area contaminated is being cleaned, according to a reportiii by NGOs. In addition, communities affected by oil spills have for years sought legal redress in UK courts. Shell has tried to block these, disputing whether it can be held responsible for its Nigeria subsidiary. Nonetheless, a recent supreme court judgement says it can.[v]


  1. The UK’s current approach to such issues is to promote (via a unit[vi] in the Department for International Trade) voluntary OECD Guidelines for Multinational Enterprises for responsible business conduct. It does not assess of the level of compliance or awareness of these guidelines. Systematic monitoring of awareness was recommended by a 2019 OECD peer review[vii] of the UK but has not yet been implemented.


  1. The effectiveness of voluntary guidelines has been challenged by the Corporate Justice Coalition who are calling for[viii] a “failure to prevent” mechanism for corporate abuses, which would incentivise companies to take action to prevent abuse from happening, and hold companies accountable if they failed to do so.


Tackling economic crime and illicit finance


  1. The FCDO recognises[ix] that the Nigerian government struggles with corruption and says it will support it in tackling corruption. Yet significant amounts of corrupt Nigeria money have passed through the UK. For example:




  1. Following the anti-corruption corruption conference, in September 2016, the UK signed an agreement with Nigeria[xii] on returning stolen criminal assets to Nigeria. As of March 2021, the only stolen money to be returned[xiii] under this agreement was £4.2 million, less than 0.02% of the total sum that Nigeria suspected had been stolen.


Good work done by UK aid can by undermined by other UK activities


  1. UK aid has benefited millions of people in Nigeria over the last few years, bringing better education, sanitation and nutrition.[xiv] However, the UK’s other interactions with Nigeria, like the examples discussed above, can sometimes work against the benefits that our aid spending brings. The table below compares UK aid to other UK impacts, drawing on the examples above.




UK bilateral aid to Nigeria

Other UK impacts


£110 million

Shell oil spill devastates environment. Clean-up costs: >$1 billion (>£600m)


£186 million

Allegedly corrupt transfer facilitated by UK bank: $800 million (£500m)



£500 million

Nigeria estimate of money laundered through UK: $37 billion (£25.6bn)


Better data on the UK’s interactions with Nigeria is needed to support progress


  1. For the UK to be more coherent in its relations with Nigeria, and more effective in progressing the IR’s objectives, it needs better data about the impact and effectiveness of its policies. Making this data available openly will also support accountability by allowing Parliament, the media and the public to understand what government is doing. Conversely, data gaps mean that poor policies and poor policy implementation, potentially working against the UK’s aims, can go unnoticed, and opportunities for advancing the UK’s aims may be missed.


  1. Three specific examples which are important for the UK’s relationship with Nigeria:



  1. There are likely to be many other opportunities to improve data in support of the UK’s policy towards Nigeria, for example better data on the economic and social contribution of UK companies operating in Nigeria.




  1. To support progress on the UK’s goals for Nigeria, Government should:


  1. The Government has already taken this approach to the UK’s environmental performance and progress against its 25 year Environment Plan. Improving the environment is another major policy aim where the impact of the UK’s efforts are complex and where a coherent cross-government approach is needed to realise the UK’s ambitions. If the Government is willing and able to take this approach to its environmental objectives then it should also apply to its foreign policy objectives.








June 2021


[i] U.N. slams Shell as Nigeria needs biggest ever oil clean-up (Reuters, 2011)

[ii] A review of the threat of oil exploitation to mangrove ecosystem: Insights from Niger Delta, Nigeria (Global Ecology and Conservation, June 2020)

[iii] Nigeria: Shell still failing to clean up pollution in Niger Delta (Amnesty International UK, June 2020)

[iv] Leigh Day - Oil Spills on the Niger Delta

[v] Nigerians can bring claims against Shell in UK, supreme court rules (The Guardian, 2021)

[vi] The UK National Contact Point is responsible for promoting the OECD guidelines for multinational enterprises on responsible business conduct and for operating the complaints mechanism set out in the guidelines.

[vii] OECD Guidelines for Multinational Enterprises - UK Contact Point Peer Review, Recommendation 2.2 (OECD,2019)

[viii] Companies would have to take action to prevent human rights abuses and environmental harm in, or arising from, their global products, services, operations, investments, and value chain – through carrying out human rights and environmental due diligence. They could be held liable in a UK court for harm, loss and damage arising from their failure to prevent harmful impacts. (Corporate Justice Coalition, Dec 2020)

[ix] FCDO Profile of development work: Nigeria

[x] JP Morgan says it knew ex-minister linked to firm in Nigeria oilfield deal (Reuters, April 2018)

[xi] Nigeria not seeking a Cameron apology, but 'wants its assets back'. President Buhari said he would rather have some of the billions stolen from his country returned than an apology for ‘fantastically corrupt’ comments (The Guardian, May 2016)

[xii] Immigration Minister signs agreement with Nigeria on returning stolen criminal assets. Criminal assets stolen in Nigeria and seized in the UK are to be returned to the West African country through a new agreement (Gov.uk, September 2016)

[xiii] UK to send millions of pounds recovered from corrupt officials back to Nigeria (gov.uk, March 2021)

[xiv] Benefits of UK aid to Nigeria from Development Tracker

[xv] Data extracted from Campaign Against Arms Trade database in June 2021, which in turn is based on the quarterly reports of the UK Export Control Joint Unit

[xvi] This issue has also been flagged by myself and several experts witnesses to the Committees on Arms Export Controls inquiry into UK arms exports in 2019