Dear State Chairpersons of SCSC and State Coordinators,

Please when responding, kindly factor into your report/response, the below:

Please ensure that the report reflects government full ownership of security
safety responsibility. This preface and forward sections should be signed by
appropriate government Agency responsible for security management in the
state stating commitment to ensuring security safety under the project. All
these comments should be addressed in track changes in the report and show
where they were addressed in the SMP reports.

REMARK: The Chairman of SCSC who is also the Hon. Commissioner for Economic
Development, representing the State Governor (who is the Chief Security Officer of the State)
signs the Foreword. This shows that the Government is committed to ensuring the security of
the project in the State.

1. Need for a better description of roles and responsibilities of different actors

and some clear statement that responsibility for the management and
mitigation of security risks lies with the government.  Relatedly, the SMPs
could clarify the requirements that are the subject of legal obligations, what
timelines they are subject to and how much funding they will require.

REMARK: Section Eight: Security Supervision & Control of the AK-CARES’ SMP clearly
documents the relevant actors and sufficiently defines their responsibilities. The subsequent
Sections 9 and 10 respectively offers in elaborate details the scope for engagement of Private
and Public Security for professional operations/roles that are legally restricted to authorized
Security Service Providers. Similarly, Section 3 addresses qualifying security incidents that
are subject of legal enforcement and also the clause for funding.

2. Clarity on SRA – these are all SMPs, but they are presumably based on an
SRA (some mention an SRA) but then go on to speak about the requirement to
undertake SRAs.  It’s fine for one document to cover both SRA and SMPs but the
distinctions between what these do must be clear, as must the sequencing.  SRA
followed by SMPs, unless the intention is to do a general SRA followed by the
SMP (which we are reviewing) and additional site specific SRAs (and
presumably SMPs).  If this is the intention, it must be made explicit in this
document.

REMARK: AK-CARES’ SMP strictly follows the Template provided by FCSU/World Bank.
Accordingly, the SRA (Security Risk Analysis) enunciated therein concisely addresses the
scenarios of possible Project Security Risks and Mitigation Measures at project sites and
displays a Situation Analysis Matrix- to act as a graphical ready reference map of security
threat level of the geographical space of the State - a glance. This is logically followed by the
SMP in the booklet (where is this addressed in the report? Is there clear distinction between
security risk assessment and security management plan?)
3. Reference to the legal basis in Nigerian law, is good.  However, where there is
a suspected breach of domestic law, the SMP should stipulate the requirement
to make a referral to the competent authorities.

REMARK: AK-CARES’ SMP illustriously subscribes to all known applicable local, national
and international laws. These laws and conventions are duly cited (where is this comment
addressed in the report and where is the clear referral pathway to competent authority in
situation where there is breach of the law?)

4. The sections on GRMs is quite comprehensive but it is unclear whether under

a WB financed project, the GRM should be involved in investigation, determine
culpability or decisions relating to criminal prosecution?  Better to link the
GRM to the relevant and competent national authorities and / or contractor as
applicable.  Also, the GRMs should be equipped to deal with allegations of
SEA/SH.  These sections should also confirm the principle of confidentiality
with respect to any information gathered during intake etc.

REMARK: We have complied with this expectation (where in the report was this addressed?)

5. Codes of Conduct:  Most of the SMPs mention CoC but do not specify whether
any such CoC cover private security forces

REMARK: We have fully complied with this (where is this addressed in the report)

6. Screening for past abuses – clarify whether screening is done for both public
and private security and specify what that screening should be looking for (e.g.
past HRL / IHL abuses, SEA / SH, excessive use of force).  Some of the SMPs talk
about forces “not found wanting” which is a bit vague and quaint. 

REMARK: We have defined and documented the processes to specifically address this
concern in the SMP(where is this addressed in the report)

7. Specify whether the SMP and its requirements cover all contractors,
subcontractors, PIU and other implementing partners

REMARK: Within the scope of our operations, yes, we have made detailed coverage (where
in the report was this addressed? Also section 9.2 stated that the contractor shall be
responsible for all work and services performed by their security personnel)

8.  Confirm source of financing and responsibility for implementation of SMPs  

REMARK: Source of financing has been provided explicitly ( This did not clearly state the
source of funding. It only stated responsibility for funding. Please make clear the source of
funding.