The Board of Trustees presents to the Iraqi public the second edition of the Natural Resources Transparency Commission's Action Plan, seeking to enhance governance and transparency in the oil, gas, and mining sectors and in compliance with Requirement 1.5 of the Extractive Industries Transparency Initiative (EITI) Standards, which calls for the Commission's work to address the implementation of "national priorities" for the three sectors through concrete, actionable activities resulting from consultations with broader stakeholders in government institutions, businesses, and civil society.

Challenges
Objectives
The fourth axis
Annual Achievement Report
Requirement 7.4 of the Extractive Industries Transparency Initiative Standards
T Activity Responsible authorities Target audience Expected results time frame Estimated cost Notes
(million dinars)
1 Annual Achievement Report 2023 Board of Trustees Wider stakeholders Identify the entity responsible for issuing the report. January 2024 - Done
Formation of the report preparation committee. Support Team
2 Review and discuss the first draft of the report. Board of Trustees Board of Trustees Opportunity to make comments and additions. February 2024 - Done
Support Team
3 Send a draft report for review and to provide suggestions and comments, if any. Board of Trustees International Secretariat. Ensure all report issuance requirements are covered. February 2024 - Done
International Secretariat
National Secretariat
4 Workshops for general discussion of the report. National Secretariat Wider stakeholders Involve civil society and other broader stakeholder groups in discussing and preparing the report and ensuring that the report reflects their activities related to the initiative. March 2024 7450 Done
Board of Trustees
5 Publish the final version of the report and send a copy to the International Secretariat. National Secretariat International Secretariat Informing wider stakeholders about the initiative's activity and keeping up with its work. March 2024 - Done
Wider stakeholders
1 Annual Achievement Report 2024 Board of Trustees Wider stakeholders Identify the entity responsible for issuing the report. January 2024 - In progress
Formation of the report preparation committee. Support Team
2 Review and discuss the first draft of the report. Board of Trustees Board of Trustees Opportunity to make comments and additions. February 2024 - In progress
Support Team
3 Send a draft report for review and to provide suggestions and comments, if any. Board of Trustees International Secretariat. Ensure all report issuance requirements are covered. February 2024 - In progress
International Secretariat
National Secretariat
4 Workshops for general discussion of the report. National Secretariat Wider stakeholders Involve civil society and other broader stakeholder groups in discussing and preparing the report and ensuring that the report reflects their activities related to the initiative. March 2024 4750 In progress
Board of Trustees
5 Publish the final version of the report and send a copy to the International Secretariat. National Secretariat International Secretariat Informing wider stakeholders about the initiative's activity and keeping up with its work. March 2024 - In progress
Wider stakeholders
the total 9,5
Challenges
Objectives
Axis 10
Annual Report
Requirements 6.2, 4.1, and 4.9 of the Extractive Industries Transparency Initiative Standards
No.ActivityResponsible EntitiesTarget EntitiesExpected ResultsTimeframeEstimated CostNotes
(Million Dinars)
First: 2022 Report
1Drafting Terms of Reference and adding beneficial ownership template among requirements.Support Team Board of TrusteesObtaining compatible texts and initiative standards to facilitate their discussion and approval by the Board. January – March 2024-Completed in 2023
National Secretariat
2Discussion and approval of Terms of Reference Board of TrusteesIndependent Administrator Companies Terms of Reference agreed upon by stakeholders.January – March 2024-Completed in 2023
Support Team
3Inviting companies, receiving and analyzing proposals, and recommending award Board of Trustees National Secretariat Independent Administrator CompaniesInforming the Board about proposals to facilitate awarding decision. January – March 2024-Completed in 2023
4Writing and signing the contract Board of Trustees National Secretariat Independent AdministratorContract with Independent Administrator company and beginning report preparation. January – March 2024250Work in progress
5Issuing preliminary reportIndependent Administrator Board of TrusteesBoard of TrusteesBoard approval of preliminary report and directing Independent Administrator to begin data collection and compilation. April – June 2024-Work in progress
Support Team
6Data collection and compilation Independent Administrator Board of TrusteesMinistry of OilDocumented and complete information and data. April – June 2024-Work in progress
Ministry of Industry
Public Companies International Companies
7 Compliance report and discrepancy verificationIndependent Administrator Board of TrusteesBoard of Trustees Review and discussion of data and Independent Administrator's conclusions and verification of discrepancies. June 2024-Work in progress
Support Team
8Initial comprehensive reportIndependent Administrator Board of TrusteesBoard of TrusteesVerifying report comprehensiveness and compliance with Terms of Reference requirements and initiative standards. July - September 2024-Work in progress
Support Team
9International Secretariat comments on final draftInternational SecretariatBoard of Trustees Ensuring report comprehensiveness and compliance with all initiative standards. July - September 2024-Work in progress
National Secretariat
Independent Administrator
10Civil society and broader stakeholder comments Board of Trustees Independent Administrator Broader stakeholders Informing broader stakeholders about the report and ensuring their participation in its preparation and stating their comments before final publication.July - September 2024-Work in progress
11Final discussion and report approvalBoard of Trustees Independent Administrator Board of Trustees National Secretariat Independent Administrator Report ready for printing, publication and distribution. July - September 2024-Work in progress
12Executive summaryBoard of Trustees Independent Administrator Board of TrusteesPublishing executive summary. July - September 2024-Work in progress
13Printing, publication and distributionIndependent Administrator National Secretariat Broader stakeholdersPublishing report as beginning and stimulating public discussionsSeptember 2024-Work in progress
Second: 2023 Report
14Drafting Terms of Reference and adding beneficial ownership template among requirements.Support Team Board of TrusteesObtaining compatible texts and initiative standards to facilitate their discussion and approval by the Board. January – March 2024-Completed
National Secretariat(See Terms of Reference for 2022 report: Section (1.2.11))
15Discussion and approval of Terms of Reference Board of TrusteesIndependent Administrator Companies Terms of Reference agreed upon by stakeholders.January – March 2024-Work in progress
Support Team
16Inviting companies, receiving and analyzing proposals, and recommending award Board of Trustees National Secretariat Independent Administrator CompaniesInforming the Board about proposals to facilitate awarding decision. January – March 2024-Work in progress
17Writing and signing the contract Board of Trustees National Secretariat Independent AdministratorContract with Independent Administrator company and beginning report preparation. January – March 2024250Work in progress
18Issuing preliminary reportIndependent Administrator Board of TrusteesBoard of TrusteesBoard approval of preliminary report and directing Independent Administrator to begin data collection and compilation. April – June 2024-Work in progress
Support Team
19Data collection and compilation Independent Administrator Board of TrusteesMinistry of OilDocumented and complete information and data. April – June 2024-Work in progress
Ministry of Industry
Public Companies International Companies
20 Compliance report and discrepancy verificationIndependent Administrator Board of TrusteesBoard of Trustees Review and discussion of data and Independent Administrator's conclusions and verification of discrepancies. June 2024-Work in progress
Support Team
21Initial comprehensive reportIndependent Administrator Board of TrusteesBoard of TrusteesVerifying report comprehensiveness and compliance with Terms of Reference requirements and initiative standards. July - September 2024-Work in progress
Support Team
22International Secretariat comments on final draftInternational SecretariatBoard of Trustees Ensuring report comprehensiveness and compliance with all initiative standards. July - September 2024-Work in progress
National Secretariat
Independent Administrator
23Civil society and broader stakeholder comments Board of Trustees Independent Administrator Broader stakeholders Informing broader stakeholders about the report and ensuring their participation in its preparation and stating their comments before final publication.July - September 2024-Work in progress
24Final discussion and report approvalBoard of Trustees Independent Administrator Board of Trustees National Secretariat Independent Administrator Report ready for printing, publication and distribution. July - September 2024-Work in progress
25Executive summaryBoard of Trustees Independent Administrator Board of TrusteesPublishing executive summary. July - September 2024-Work in progress
26Printing, publication and distributionIndependent Administrator National Secretariat Broader stakeholdersPublishing report as beginning and stimulating public discussionsSeptember 2024-Work in progress
Total500
Challenges
Objectives
First axis
Verification requirements
Validation Requirements
Requirements 7.3 and International Board Resolution No. 2023-55/BM-58 regarding the determination of the verification date
No. 2019-56 / BM-45 BM-45/ 56-2019 regarding corrective measures
T Activity Responsible authorities Target audience Expected results time frame Estimated cost Notes (in progress, facing challenges, accomplished)
Corrective actions:
1 A meeting of the Board of Trustees was held in the presence of the President and with the participation of the International Secretariat to discuss the weak participation and develop solutions in accordance with the criteria of requirements 1.2 and document this in minutes signed by everyone. Chairman of the Council Government Companies Civil Society Board of Trustees 1. Full and effective participation of all entities represented on the Council, not limiting their role to disclosing data only. 2. Members' efforts with the entities they represent to ensure the adoption of a systematic disclosure program. January 2024 1. Completed 2. In progress
2 Restructuring the Board of Trustees to comply with Requirement 1.4 and amending Diwani Order 23512 accordingly. Chairman of the Council Board of Trustees New Diwani order to ensure: April 2024 - 1. In progress
the government Wider stakeholders 1. An effective Board of Trustees that operates with complete independence and represents all multiple stakeholders. 2. In progress
Companies General Secretariat of the Council of Ministers 2. The existence of paragraphs of the internal regulations, including the tasks and powers of the Council and the National Secretariat, the mechanism for selecting original and alternate members, and taking into account gender balance. 3. In progress
civil society 3. Determining the Ministry of Oil’s responsibility for providing financial and administrative requirements.
National Secretariat
3 Reformulate the business plan to fit requirement 1.5 Board of Trustees Wider stakeholders 1. An action plan stemming from broader stakeholder consultations in government, business, and civil society January 2023 - 1. Accomplish
Support Team 2. Includes specific activities with costs and funding sources. 2. Accomplish
National Secretariat 3. Includes procedures for following up on recommendations issued by verification procedures and transparency reports. 3. Accomplish
4. Updatable to reflect ongoing monitoring of implementation and support efforts to obtain donor support. 4. Accomplish
4 Updating the terms of reference for upcoming transparency reports to include an updated and advanced mechanism for publishing the financial relations between state-owned companies and the government, including the sources of financing their operating and investment budgets, production costs and profits, their contributions to financing the federal budget, and the loans granted to them, in accordance with Requirements 2.6.a and 2.6.b. Board of Trustees Independent administrator 1. Financial relationships between the government and state-owned enterprises are made clear, detailed, and publicly available. March 2024 - 1. Done
Support Team Wider stakeholders 2. Loans or loan guarantees provided by the government to any oil, gas and mining companies are published and available to the public. 2. Done
National Secretariat 3. There are efforts to encourage the disclosure of this data through the systematic disclosure program and through the annual transparency report. 3. Done
(See the Terms of Reference for the 2022 Report: Paragraph (1.3.5), Table No. (1) Participation of State-Owned Enterprises)
5 A workshop, with the participation of the International Secretariat and the World Bank, was held to clarify the issue of relative importance and evaluate the comments made by the Board in previous reports, in accordance with requirements 4.1 and 4.9, and to document this in minutes that will be published on the website and made available to the public. National Secretariat Board of Trustees 1. Transparency reporting compliance includes a clear assessment by the independent administrator of the materiality of companies that refrain from disclosure, and making recommendations regarding the impact of this on the comprehensiveness of compliance. March 2023 - 1. Accomplish
Support Team 2. Comprehensive documentation of Board of Trustees discussions and a mechanism for setting relative importance thresholds. 2. Accomplish
Independent administrator 3. Seeking to oblige companies with payments within the scope of materiality to disclose according to the agreed-upon disclosure forms. 3. Accomplish
6 Updating the terms of reference for upcoming transparency reports to include an updated and advanced mechanism for publishing cash and in-kind revenues and their physical transfers, and publishing a map of the financial relationships of state-owned extractive companies, in accordance with Requirement 4.5. Board of Trustees Independent administrator 1. Disclosure of all revenues of state-owned companies that fall within the scope of relative importance, whether cash or in kind, and all their transfers to and from the government. March 2024 - 1. Done
Support Team Wider stakeholders 2. To enhance compliance, efforts are underway to publish a clear map of all financial relationships of state-owned extractive companies. 2. Done
National Secretariat (See the Terms of Reference for the 2022 Report: Paragraph (1.3.5), Table No. (1) Participation of State-Owned Enterprises)
7 Updating the terms of reference for upcoming transparency reports to ensure detailed, rather than aggregate, data is published, and striving to disclose at the project level, in accordance with an updated and advanced mechanism for publishing cash and in-kind revenues, in accordance with Requirement 4.7 and the decisions approved by the International Board at its 36th meeting in Bogotá. Board of Trustees Independent administrator 1. Publish compliance data, including cost recovery, profitability fees, etc., in detail by company, revenue stream, and government entity. March 2024 - 1. Done
Support Team Wider stakeholders 2. Endeavour to disclose the level of (the project) with regard to fees and taxes for specific sectors before the deadline for the transparency report. 2. Done
National Secretariat (See the 2022 Report Terms of Reference: Paragraph (1.2.6))
8 Updating the terms of reference for upcoming transparency reports to ensure the reliability of the data published in accordance with International Standards on Auditing and in accordance with Requirement 4.9.b.3 and the terms of reference for the independent administrator approved by the International Board. Board of Trustees Independent administrator 1. All financial statements for the Transparency Report are subject to review by an independent external auditor in accordance with International Auditing Standards and in accordance with Requirement 4.9.b.3 and the Terms of Reference for the Independent Administrator approved by the International Board. March 2024 - 1. Done
Support Team Wider stakeholders 2. The Transparency Report includes an assessment of whether all government agencies and global companies covered by the report have actually disclosed the required data. 2. Done
National Secretariat 3. The Transparency Report publishes all gaps and weaknesses in the data collection process, including naming entities that did not comply with the disclosure mechanism, and assessing the impact of this on the comprehensiveness and reliability of the report. 3. Done
4. The Transparency Report includes a comprehensive summary of the independent administrator's work and the limitations imposed on the assessment provided. It also includes an assessment of the comprehensiveness and reliability of the (financial) data provided. 4. Done
(See the 2022 Report Terms of Reference: Paragraph (1.2.7))
9 Update the terms of reference for upcoming transparency reports to ensure detailed disclosure of social benefits in accordance with Requirement 6.1 Board of Trustees Independent administrator Detailed (not total) disclosure of mandatory social benefits, including the amounts paid, their type, and the beneficiary, with the name and job title of the non-governmental beneficiary (third party), and whether the expenses were provided in cash or in kind. March 2024 - (See the 2022 Report Terms of Reference: Paragraph (1.3.1))
Support Team Wider stakeholders
National Secretariat
10 Update the publishing and distribution plan and the media plan in accordance with requirement 7.1. Board of Trustees Independent administrator 1. All transparency report data is effectively published, publicly available, and subject to public debate. June 2024 -          1. In progress
Support Team Wider stakeholders 2. A media plan that looks beyond introducing the initiative and focuses on, reviewing and discussing the national priorities identified in the action plan. 2. In progress
National Secretariat 3. Engage broader stakeholders in disseminating and raising awareness of the report outcomes, including parliamentarians, academics, the media, and residents of areas near the sites. 3. In progress
4. Adopting an open data policy regarding data availability, release, and reuse. 4. In progress
11 The action plan shall include a mechanism for following up on the recommendations of previous reports in accordance with Requirement 7.3. Board of Trustees Independent administrator 1. Continuous follow-up of the recommendations of previous reports. 2023 - 1. Accomplish
Support Team Wider stakeholders 2. Identify the causes of data discrepancies and address challenges in the disclosure and investigation process. 2. Accomplish
National Secretariat 3. The Council should take a more proactive role in adding its own recommendations to the recommendations of the independent administrator. 3. Accomplish
12 The work plan shall include a detailed mechanism to ensure that the annual achievement report contains all the criteria of Requirement 7.4. Board of Trustees Independent administrator 1. Enable all broader stakeholders to add any inputs to the annual achievement report and have their views appropriately reflected. January 2024 - 1. Accomplish
Support Team Wider stakeholders 2. The annual achievement report includes a narrative description of the efforts made to enhance the impact of the initiative’s implementation. 2. Accomplish
National Secretariat
Miscellaneous activities related to verification requirements
13 Preparing informational publications about the role of public companies and explaining the mechanism of public companies’ dealings with the government in terms of payments and dues. National Secretariat Wider stakeholders Explaining the role of public companies and how revenues are transferred from companies to the government, so that the public can understand the relationship between public companies and the government. January - March 2024 2 Facing challenges due to lack of allocations
14 A general meeting of oil, gas, and mining companies will be held under the auspices of the Minister of Oil and attended by the International Secretariat and the World Bank. The meeting will discuss the role and responsibilities of the companies under Requirement 1.2, and minutes will be signed containing the agreed-upon main points. The discussions will include: Chairman of the Council global companies 1. Issuing an announcement published on the websites of national and international companies operating in the oil, gas, and mining sectors, whereby the companies commit to fully implementing the requirements and standards of the Transparency Initiative, including, but not limited to: First quarter of 2024 9 1. Facing challenges due to lack of response
1. Contract Transparency Policy under Requirement 2.4 and the government’s policy in publishing contracts published on the Ministry’s website at the link, Circular No. 111 signed by Undersecretary Karim Hattab dated 4/8/2019, Letter No. 124 of His Excellency the Minister Thamer Al-Ghasban dated 4/27/2020, Circular No. 1094 of His Excellency the Minister Hayan Abdul-Ghani Al-Sawad dated 12/11/2023, and Circular No. 134 of the postponement signed by His Excellency the Minister Hayan Abdul-Ghani Al-Sawad dated 2/18/2024 Board of Trustees National companies - Implementing systematic disclosure programs, beneficial ownership, contract transparency, etc. 2. Facing challenges due to lack of response
2. The impact of companies’ reluctance to disclose their data on the accuracy, comprehensiveness, and relevance of the 2021 report, as follows: Support Team civil society - Disclosure of the data required for transparency reports in the form and time specified in the disclosure forms. 3. Facing challenges due to lack of response
Only 17 out of 27 companies in the licensing rounds disclosed their data. National Secretariat Media - Full, effective, influential and continuous participation in the activities of the Transparency Authority, including disclosure of data and attendance at Board meetings. 4. Facing challenges due to lack of response
Only 34 out of 56 crude oil buying companies disclosed their data. - Organizing field introductory workshops for their employees and participating in organizing capacity-building programs for members of the Council and the National Secretariat.
Less than 5% of companies provided their data with the required accuracy and reliability. - Representatives of companies on the Board of Trustees inform international and national companies of the Board’s discussions and decisions.
- Not all companies have submitted the required data for the beneficial ownership program. - Publishing the initiative’s activities and news on company websites.
2. Companies agree with the Ministries of Oil and Industry and Minerals on a unified policy for "contract transparency," which includes defining the contracts required to be published in terms of contract type, minimum contract amount, and the amount of data permitted to be published, as well as the publishing mechanism. This policy should be made publicly available on the websites of the ministries and national and international companies.
3. Issuance of new directives by the Ministries of Oil and Industry and Minerals obligating extractive companies in the two ministries to publish their contracts signed in 2021 and beyond in accordance with the above-mentioned contract publication policy.
4. Discussing the Ishtar system between BP and the Ministry of Oil, and determining whether it is sufficient to publish data and considering the possibility of integrating it into the systematic disclosure program.
15 Seeking the Ministry of Industry and Minerals to issue directives obligating its companies operating in the mining sector to publish their final accounts on the Ministry’s website and the companies’ websites, in line with the directives of the Ministry of Oil issued pursuant to the second paragraph of the Minister’s Circular No. 1094 dated 12/11/2023. Board of Trustees National companies operating in the mining sector 1. Issuing a circular signed by the Minister of Industry and Minerals requiring companies operating in the mining sector to publish copies of their final accounts and certificate of incorporation. The final accounts must include a statement indicating whether they have been approved by the Federal Board of Supreme Audit or whether they are still under audit. January 2025 - 1. In progress
National Secretariat Wider stakeholders 2. The final accounts and certificates of incorporation of all national companies operating in the oil, gas, and mining sectors are duly published on the companies’ websites. 2. In progress
16 Paragraph (6) of the Independent Administrator’s Recommendations for the 2021 Report on the Publication of Final Accounts under Requirement 2.6, b Accelerating the audit process for state-owned companies and publishing their audited financial statements Board of Trustees Ministry of Oil 1. Seeking the Federal Board of Financial Supervision to expedite the audit procedures. First quarter of 2024 - 1. In progress
National Secretariat Ministry of Industry and Minerals 2. Urging companies to continue publishing audited final accounts. 2. In progress
Federal Board of Supreme Audit 3. The Authority shall publish the final accounts or document and publish the legal and administrative obstacles that prevent publication on the specified date. 3. In progress
17 Updating the licensing register and publishing it on the websites of the Ministry of Oil and the Petroleum Contracts and Licensing Department. National Secretariat Media Office of the Ministry of Oil A complete, up-to-date licensing record is posted on the website and available to the public. March 2024 - Done
Support Team Petroleum Contracts and Licensing Department
Wider stakeholders
the total 9
Challenges
Objectives
Axis Nine
Corruption indicators
Requirement 1.4, 1.5, 2.1, 7.1 Anti-corruption strategy/corruption indicators in the Ministry of Oil and the Ministry of Industry and Minerals
No.ActivityResponsible PartiesTarget PartiesExpected ResultsTimelineEstimated CostNotes
(Million Dinars)
1Contracting with an international and/or local expert to conduct a survey to identify corruption indicators in oil, gas and mining sectors within the framework of the anti-corruption strategyBoard of TrusteesWorld BankA comprehensive professional study of corruption indicators with clear identification of causes, results and solutionsLast quarter of 2024To be determined later based on funding availability and funding entityWork in progress
National SecretariatMinistry of Oil
Ministry of Industry and Minerals
Integrity Commission
Civil Society
2Workshop to compare outputs of the above study with corruption indicators in oil, gas and mining sectors included in the anti-corruption strategy and observations of the Ministries of Oil and Industry and Minerals thereonBoard of TrusteesIntegrity Committee in ParliamentDeveloping the anti-corruption strategy and obtaining realistic and addressable corruption indicators in oil, gas and mining sectors and providing recommendations and follow-upLast quarter of 20244.75Work in progress
National SecretariatIntegrity Commission
Federal Board of Supreme Audit
Studies, Planning, Follow-up and Legal Departments in the Ministries of Oil and Industry and Minerals
Legal Advisor in Ministry of Oil
3Contracting with an international expert to prepare a study on investment in mining, privatization, partnership contracts, their feasibility, challenges facing them, and ways to develop themBoard of TrusteesMinistry of Industry and MineralsProviding recommendations on ways to develop the sector and optimal investment and providing recommendations on combating corruption and maximizing revenuesLast quarter of 2024To be determined later based on funding availability and funding entityWork in progress
Iraqi Federation of Industries
4Workshop on corruption and waste indicators in fuel consumed at power generation stations in the Ministry of Electricity, import contracts, testing laboratories, and transportation between ports and stationsBoard of TrusteesPetroleum Products Distribution CompanyIdentifying sources of corruption and waste and providing recommendations and follow-upLast quarter of 20244.75Work in progress
National SecretariatOil Marketing Company
Fuel Center in Ministry of Electricity
5Developing disclosure templates in transparency reports to include more detailed data on imported fuel, locally produced fuel, import and transportation contracts. Comparing it with actual consumption and determining the energy production ratio per liter of fuel and comparing it with internationally adopted ratiosBoard of TrusteesIndependent AdministratorInforming citizens and relevant entities about accurate and detailed data on consumed fuel and providing recommendations on addressing corruption and waste thereinLast quarter of 2024-Work in progress
Total9.5
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