Audit Bench of the Supreme Court

The Audit Bench of the Supreme Court adopted this second report
on the audit of the use of resources of the Special National Solidarity
Fund to fight Coronavirus and its economic and social impacts
for the 2020 financial year following the deliberation in Chamber
of Thursday, September 22 2022, on the report of Mr  Théodore
MBENOUN, President of the First Division.
Sitting in chambers, the committee was composed as follows:
Chairman:
 YAP ABDOU, the President of the Audit Bench of the
Supreme Court;
Members:
 WACKA née FOFUNG Justine NABUM, President of the 3rd
Division;
 MBENOUN Théodore, President of the 1st Division, General
Coordinator of the audit;
 NGATCHA Isaïe, President of the 4th Division;
 NDJOM NACK Elie Désiré, President of the 2nd Division;
 TCHOQUESSI née NJONKOU MANGWA Rose Justice of the
Supreme Court;
 SUH Alfred FUSI, Justice of the Supreme Court;
 MANGA MOUKOURI Isaac, Master of the Supreme Court;
 YEBGA MATIP Emmanuel, Master of the Supreme Court;
 NDONGO ETAME David, Master of the Supreme Court;
 DJOKO André, Master of the Supreme Court;
 MIKONE Martin Bienvenue, Master of the Supreme Court;
 ALIMA Jean Claude, Master of the Supreme Court;
 OUMAROU ABDOU, Master of the Supreme Court.

The Legal Department was represented by:

 NIBA Georges, Advocate General;

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

 ONANA ETOUNDI Félix, Advocate General,

NGUETCHUENG Bertrand, Registrar-in-Chief, took the minutes.
The audit work was conducted under the general supervision of the
President of the Audit Bench. He appointed a General Coordinator
and set up five work teams of Legal and Judicial Officers and Audit
Assistants led by Masters of the Supreme Court. The following
acted as rapporteurs:
MFUL’EMANE Yves Olivier, MBOCK née SAME LOTTIN
Laure Elsa, TAMA Vital Charly, NDJEMBA NKOTO Willy
Martial, SADJO MAÏGARY Patrice, YOH Elvis NCHINDA,
TCHINDE MBE Michel Ferrick, NYEMB Oscar Thierry Ulrick,
MATEKE NGALLE née MBOZO’O Stéphanie Arielle, MBEPET
née NGASGA MENYOMO Laurentine, LADENG Kizito
GAHGWANYIN, trainee Commissioners of Audit.
ENAM née EYINGA NLATE Evelyne Sandrine and NKOLO née
MEKENA Annette, Audit Assistants
The audit and consultancy firm BEKOLO & PARTNERS was
mandated to participate on an ad hoc basis to conduct an evaluation
of the information systems and procedures set up by ministries.

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 CONTENT
LIST OF TABLES.................................................................................................................VII

CHARTS .................................................................................................................................IX

TABLE OF ACRONYMS.....................................................................................................XI

SUMMARY..........................................................................................................................XIII

RECOMMENDATIONS.................................................................................................. XVII
TO THE PRIME MINISTER, HEAD OF GOVERNMENT......................................XVII
TO THE MINISTER OF FINANCE.............................................................................XVII
TO THE MINISTER OF AGRICULTURE AND RURAL DEVELOPMENT..........XVII
TO THE MINISTER OF FINANCE AND THE MINISTER OF YOUTH AFFAIRS
AND CIVIC EDUCATION............................................................................................XVII
TO ALL MINISTERS INVOLVED IN THE RESPONSE TO THE PANDEMIC...XVIII
GENERAL INTRODUCTION......................................................................................XIX
PART 1 - SCOPE OF THE AUDIT........................................................................................ 1
1 - A first report on the audit of three ministries..............................................................3
2 - A second report on the audit of the twenty other ministries and tax expenditures in
2020.......................................................................................................................................4
PART 2 - MANAGEMENT OF THE SPECIAL NATIONAL SOLIDARITY FUND:
LACK OF TRANSPARENCY AND POOR ACCOUNTABILITY.................................... 7

3 - Derogations granted to the Special Appropriation Account...........................................9

3.1. - First derogation resulting from the Ordinance of June 3 2020..........................9
3.2. - A second derogation contrary to the principle of budget annuality................10
4 - A management account submitted to the Audit Bench 14 months late....................11
5 - A lack of activity and financial reports from the ministries, which prevented the
strategic steering of the Special Fund..............................................................................12
PART 3 - CFAF 10.799 BILLION OF EXPENDITURE COMMITTED FROM THE
SPECIAL FUND AND OWN BUDGETS OF FOUR OF THE TWENTY MINISTRIES
AUDITED................................................................................................................................15
6 - A Special Appropriation Account not closed by December 31 2020........................17
6.1. - Expenditure commitments for the 2020 financial year that continued beyond
December 31 2020......................................................................................................... 17
6.2. - Misuse of the notion of carry-over.....................................................................17
7 - Expenditure for the 2020 financial year estimated at CFAF 8.512 billion under the
Special Appropriation Account........................................................................................ 19

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 Audit Bench of the Supreme Court

7.1. - A reconstruction of expenditure as at 31 December 2020.................................19

7.2. - Expenditure incurred by 04 ministries in the last quarter of 2020 with limited
impact ............................................................................................................................21
7.3. - A modest amount compared to the 132.9 billion FCFA committed in 2020 by
MINSANTE, MINRESI and MINFI...........................................................................21
8 - MINESUP, MINESEC and MINEDUB: CFAF 2.287 billion spent outside the
Special Appropriation Account........................................................................................ 25
8.1. - Expenditure of CFAF 199.9 million made in an emergency by MINEDUB
before the creation of the SAA, not adjusted..............................................................25
8.2. - Expenditure of CFA 634.4 million for the construction and equipment of
classrooms, not adjusted............................................................................................... 26
8.3 - Expenditure of CFAF 754.5 million from the budget of State Universities......26
8.3.1 University of Maroua....................................................................................... 27
8.3.2 University of Ngaoundere..............................................................................28
8.3.3 University of Bamenda...................................................................................29
8.3.4 University of Douala....................................................................................... 30
8.3.5 University of Buea........................................................................................... 30
8.3.6 University of Dschang..................................................................................... 31
8.3.7 The University of Yaounde I..........................................................................31
8.3.8 University of Yaounde II - Soa......................................................................31
8.3.9 Cameroon-Congo Interstate University (UIECC).....................................32
8.4. - Expenditure of CFAF 699 million from MINESEC’s own budget...................32
8.4.1. The reallocation of resources dedicated to FENASCO A Games to the
tune of 152 million FCFA........................................................................................ 32
8.4.2. Ad hoc transfer of funds to Regional Delegations..................................33
8.4.3. The special case of the Regional Delegation of Secondary Education
for the Centre............................................................................................................ 33
8.4.4. The development of distance learning.....................................................34
PART 4 - A COMMITMENT RATE OF 11.1% THAT HIGHLIGHTS A POOR
ORGANISATION OF MINISTRIES IN RESPONDING TO AN EMERGENCY......... 37
9. Inadequate information system and procedures........................................................39
9.1. Absence of internal actions and ad hoc organisation..........................................40
9.2. Lack of internal procedures to validate the eligibility of expenditure...............41
9.3. – Lack of an organisation to ensure effective financial reporting......................42
9.4. Lack of production of activity and financial reports, an obstacle to the
strategic steering of the Special Appropriation Account...........................................42
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

10. Administrations that did not use COVID-19 funds.................................................44

10.1. Administrations that received funding from entities other than COVID-19
SAA ................................................................................................................................45
10.2. Administrations that did not use COVID funds................................................46
11. Poor organisation of the response at the local level..................................................46
11.1. Implementation by councils deferred to the 2021 financial year.......................47
11.1.1. Late arrival of funds.......................................................................................... 47
11.1.2. Diversified use of funds, sometimes far from hygiene and sanitation
purpose.......................................................................................................................47
11.2. Lack of coordination between MINDDEVEL and MINSANTE.......................48
11.3. Funds not received by Douala 2 council..............................................................49
11.4. Resources received by Pouma council but not used...........................................49
11.5. Lack of evaluation................................................................................................. 50
12. Insufficient coordination between ministries and international
organisations in managing grants and implementing aid programmes..............50
12.1. A UNESCO programme of CFAF 5.356 billion poorly coordinated with
MINEDUB and MINESEC........................................................................................ 50
12.2. UNDP grants difficult to reach councils...........................................................51
12.2.1. Anti-COVID kits........................................................................................... 52
12.2.2. Digital tablets................................................................................................ 52
PART 5 - SLOW AND UNEVEN IMPLEMENTATION OF MEASURES..................... 53
13. Financial control of the streamlined circuit: files processed in 36 days
instead of 13..................................................................................................................... 55
14. The notion of urgency largely forgotten during the implementation of
contracts ............................................................................................................................56
14.1. Contracts awarded as a matter of urgency yet not implemented 18 months
later................................................................................................................................... 56
14.2. Equipment delivered and accepted, although the construction work is not
complete....................................................................................................................... 59
14.3. Inadequate management of deadlines..............................................................60
14.3.1. Exceeding the time limits for authorizations to award contracts by mutual
agreement...................................................................................................................... 60
14.3.2. Delivery or performance of services without obtaining an extension of
time................................................................................................................................ 61
15. Poor store accounting likely to promote misappropriations........................61

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 Audit Bench of the Supreme Court

16. Support from MINADER to reduce food dependency awarded to 64

individuals to the tune of CFAF 424.5 million.........................................................63
17. CFAF 225 million still to be paid to young volunteers mobilised to raise the
population awareness...................................................................................................... 64
PART 6 - VAT CREDIT REFUNDS, OTHER ADMINISTRATIVE MEASURES AND
TAX EXPENDITURE........................................................................................................... 67
18. Numerous tax measures decided by the government...................................69
18.1. Measures announced by the Prime Minister in a special statement on 30
April 2020 ....................................................................................................................69
18.2. Measures decided by Ordinance No. 2020/001 of 3 June 2020 of the
President of the Republic........................................................................................... 70
19. Implementation of tax measures.......................................................................71
19.1. VAT credits refund.............................................................................................. 71
19.1.1. A VAT credit refund scheme provided for in Article 149 of the General
Tax Code ....................................................................................................................71
19.1.2. The principle of separation of the functions of authorising officer and
accountant disregarded by the Director General of Taxes................................72
19.1.3. Failure to record VAT credits, contrary to the principle of recognition
of rights and obligations.......................................................................................... 73
19.1.4. Fifty-eight (58) beneficiary companies, mostly from the forestry
sector ........................................................................................................................74
19.2. Other administrative measures.....................................................................75
19.2.1. Suspension of forced recovery...................................................................75
19.2.2. Suspension of tax audits.............................................................................75
19.4. Tax expenditures.................................................................................................. 76
19.4.1. A lack of impact assessment......................................................................76
19.4.2. An a posteriori evaluation carried out at the request of the Audit
Bench ........................................................................................................................77
19.4.3. Tax measures under RLAs poorly implemented....................................78
19.4.3.1. Lack of monitoring by MINDDEVEL of the implementation of
fiscal measures in RLAs................................................................................. 78
19.4.3.2. A very low impact of RLAs fiscal measures due to the lack of
involvement of councils.................................................................................. 79
19.4.4. Low impact of tax expenditure estimated between CFAF 2 and 4
billion ........................................................................................................................80
GENERAL CONCLUSION.................................................................................................. 83

Appendix: LIST OF PEOPLE MET....................................................................................... i

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 LIST OF TABLES

Table I .Distribution of the CFAF 76.87 billion from the Special National Solidarity Fund
among the 20 ministries audited in this report..................................................................... 5

Table II. Estimated 2020 expenditure of 20 ministries (excluding MINSANTE, MINRESI

and MINFI) under the SAA “Special National Solidarity Fund to fight against coronavirus
and its economic and social impacts.”.................................................................................. 20

Table III. Final reconstruction of the 2020 operations of the COVID-19 Special
Appropriation Account (accounts closed as at 31 December 2020)................................... 22

Table IV. University of Maroua: reallocation of funds for the fight against the Coronavirus
in 2020..................................................................................................................................... 27

TableV. MINESEC/Regional Delegation for the Centre: Direct purchases made by the
cashier...................................................................................................................................... 34

Table VI. Production of activity and financial reports by sectoral administrations........ 43

Table VII .List of grants received from the United Nations Development Programme (UN
DP)........................................................................................................................................... 51

Table VIII. Contracts for the equipment of multimedia rooms not delivered in March
2022, although the multimedia rooms have been delivered and accepted........................ 57

Table IX. Contracts awarded by MINADER in 2020 and not delivered as at 31 March 20
22............................................................................................................................................. 58

Table X. Uncompleted construction work despite the delivery and acceptance of

multimedia equipment in March 2022................................................................................ 60

TableXI. Material outputs under COVID-19 SAA higher than inputs............................. 62

Table XII. Materials removed from stock with no record.................................................. 63

table XIII. Estimated tax expenditure by tax type (2020 financial year........................... 81

VII
 CHARTS

Chart 1 - Breakdown of VAT credit refunds by sector........................................................74

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 TABLE OF ACRONYMS

ACCT Central Accounting officer/agency of the Treasury

AFD  French Development Agency
AfDB African Development Bank
BCA Administrative purchase order
BDEAC  Central African States Development Bank
BEAC  Bank of Central African States
WB  World Bank
COVID-19 SAA  Special Appropriation Account titled Special National Solidarity
Fund to fight against Coronavirus and its economic and social im-
pact
AB Audit Bench
CGI General tax code
SCC/AB Supreme Court of Cameroon/Audit Bench
DGSN General Delegation for National Security
DGB Directorate General of the Budget
DGT Directorate General of Taxes
DGTFMC Directorate General of the Treasury, Financial and Monetary Coop-
eration
DRES Regional Delegation of Secondary Education
DRJEC Regional Delegation of Youth Affairs and Civic Education
DRSP Regional Delegation of the Ministry of Public Health
FASS Reproductive Health Support Program
FENASCO National Federation of School Sports
FSSN or Special Fund  Audit of the Special National Solidarity Fund to fight against Coro-
navirus and its economic and social impact
INTOSAI  Organisation Internationale des Institutions Supérieures de Contrôle
des Finances Publiques/

International Organization of Supreme Audit Institutions

IRAD  Agricultural Research Institute for Development
IPSAS Normes comptables internationales du secteur public/

International Public Sector Accounting Standards

ISSAI Normes internationales des Institutions Supérieures de Contrôle des
Finances Publiques/

International Standards of State Audit Institutions

MINADER Ministry of Agriculture and Rural Development
MINAS Ministry of Social Affairs
MINCOMMERCE Ministry of Trade

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 Audit Bench of the Supreme Court

MINCOM  Ministry of Communication

MINDDEVEL The Minister of Decentralisation and Local Development,
MINDEF  Ministry of Defence
MINEPAT  Minister of Economy, Planning and Regional Development
MINEDUB Ministry of Basic Education
MINEPIA  Ministry of Livestock, Fisheries and Animal Industries
MINESEC  : Ministry of Secondary Education
MINESUP  Ministry of Higher Education
MINJEC  Ministry of Youth Affairs and Civic Education
MINAT Ministry of Territorial Administration
MINFI Ministry of Finance
MINMIDT Ministry of Mines, Industry and Technological Development
MINPMEESA Ministry of Small and Medium-sized Enterprises, Social Economy
and Handicrafts
MINPROFF  Ministry of Women’s Empowerment and the Family
MINRESI Ministry of Scientific Research and Innovation 
MINSANTE Ministry of Public Health
MINT Ministry of Transport
MINTOURL Ministry of Tourism and Leisure
MINTS Ministry of Labour and Social Security
MS Special contract
LCS Special jobbing order
WHO  World Health Organisation
UNDP United Nations Development Programme
PS SAA COVID-19  Specialised Paymaster for COVID-19 SAA
PS MINSANTE Specialised Paymaster at the Ministry of Public Health
PTF Technical and Financial Partners
UBA United Bank of Africa
UNOPS United Nations Office for Project Services
TG Central Treasury
EU  European Union
UIECC Cameroon-Congo Interstate University
UNESCO United Nations Educational, Scientific and Cultural Organisation
UNICEF United Nations InternationalChildren’s Emergency Fund

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 SUMMARY

In its first report, the Audit Bench audited the resources of the Special Appropriation
Account (SAA) called “National Solidarity Fund to fight coronavirus” for the
2020 financial year and the expenditure incurred by the Ministry of Public Health
(MINSANTE), the Ministry of Scientific Research and Innovation (MINRESI) and
the Ministry of Finance (MINFI). The Audit Institution decided to publish a second
report on the expenditure incurred by 20 other ministries in 2020 under the same
SAA and the tax expenditure for the same financial year.
The technical and administrative organisation of the COVID-19 SAA and its
operationalisation in November 2020 enabled these twenty other ministries to
control better the budgetary expenditure and the pace of consumption of funds.
Notwithstanding these elements, the Audit Bench makes six observations:
FIRSTLY, while the resources allocated by the decree of July 22 2020, to the
20 audited ministries amounted to CFAF 76.87 billion, the Audit Bench estimates
the expenditure incurred by four ministries in 2020 at CFAF 10.799 billion.
The 16 other audited ministries did not incur any expenditure that year. CFAF
8.512 billion of these funds were committed under the Special Appropriation
Account and CFAF 2.287 billion under the budget of the Ministry of Higher
Education (MINESUP), the Ministry of Secondary Education (MINESEC) and the
Ministry of Basic Education (MINEDUB). This amount is modest compared to
the expenditure incurred in 2020 by MINSANTE, MINRESI and MINFI, which
the Audit Bench estimated at CFAF 132.883 billion. These three ministries were
in the front line of the response to the pandemic, particularly in their health and
economic aspects, whereas the 20 ministries audited in this report appear to be in
the second line. Only the Ministry of Decentralisation and Local Development,
the Ministry of Agriculture and Rural Development, the Ministry of Youth Affairs
and Civic Education and the Ministry of Secondary Education committed small
expenditures. They also intervened mostly in the last quarter of 2020. On the other
hand, MINSANTE and MINRESI responded promptly to the emergency. In this
light, the Audit Bench considers that the effectiveness of the spending of these four
ministries was low given their stated objectives of economic resilience (programme
972) and social resilience (programme 974) for the year 2020.
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 Audit Bench of the Supreme Court

SECONDLY, it appears that 16 ministries incurred no expenditure in 2020.

This situation shows shortcomings in the organisation of these ministries, which
could not mobilise quickly in a national emergency. Specifically, the Audit Bench
notes that ministries, except MINSANTE, did not set up ad hoc organisations
or internal procedures to validate files eligible to be funded under the Special
Appropriation Account. They also failed to adapt their information system to
ensure effective reporting. In the end, they did not produce the activity and
financial reports requested by MINFI, which was a major obstacle to the strategic
steering of the Special Fund. In addition, some ministries refrained from incurring
SAA expenditure because they benefited directly from external funding, which
is inconsistent with optimising the allocation of available resources within the
Special Fund. Finally, the organisation of the response to the pandemic at the local
level was weak. The funds MINDDEVEL transferred to FEICOM in October only
reached councils in December. In practice, they could only be used in 2021. The
actions implemented at the local level in 2020 were initiated by Regional and Local
Authorities and funded from their own budgets.
THIRDLY, changing the rules to attach the expenditure of the 2020
financial year to the first six months of 2021 had no legal basis or accounting
justification. This undermined the principle of budgetary annuality and
compromised the transparency and accountability underpinning Special
Appropriation Accounts. While respecting the principle of budgetary annuality, the
Audit Bench had to recalculate the expenditure to be attached to this account for the
2020 financial year without being able to use reliable accounting documents. The
Special Appropriation Account management account was not produced until August
1 2022, and the documents sent to the Audit Bench by the Specialised Paymaster
did not make it possible to determine the expenditure incurred by the 20 audited
ministries as at December 31 2020. Given that the Ministry of Finance experienced
difficulty ensuring that accounts are monitored according to the regulations in force,
it is necessary to raise the question of maintaining this Special Appropriation.
FOURTHLY, monitoring the implementation of the measures revealed
serious shortcomings. The notion of urgency was largely forgotten. Bottlenecks
hampered the launch of contracts in the financial control of the streamlined circuit,
which was supposed to speed up the procedure (averagely 23 days of delay). In
contrast, many contracts were not executed 18 months after they were launched.
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

As for the management of store accounting, it is likely to have encouraged the

diversion of property. Finally, the Audit Bench points out that MINADER’S
grants of CFAF 424.5 million to reduce food dependency were awarded to
64 individuals, including a minister, two Parliamentarians, a colonel and a
Finance Controller. These people were not directly linked to agricultural activities
nor had proven competence in food security. It was, therefore, doubtful whether
they were in the best position to carry out actions aimed at this objective. Besides,
MINADER did not monitor the use of these resources, which left the door open to
possible misuse of aid.
FIFTHLY, the Audit Bench estimates the total expenditure under SAA
for 2020 at CFAF 141.395 billion, the total revenue at CFAF 161.837 billion,
leaving a positive balance of CFAF 20.442 billion at the end of the year, to be
carried over to the 2021 financial year.
SIXTHLY, the tax expenditure for the 2020 financial year is estimated
in between CFAF 2 and 4 billion, which is also a modest amount. One of the
measures concerned the VAT credit refund. To this effect, the Director General
of Taxes instructed the National Director of BEAC to transfer funds to a list of
companies in order to refund VAT credits by debiting the Special VAT Account.
The Audit Bench notes that the management of a Treasury account opened at the
central bank by the Director General of Taxes violates the principle of separation
of functions between the authorising officer and the accountant in the VAT credit
refunding chain. It also appears that the VAT credits validated by the competent
services of DGT are not recorded in the Department of Public Accounting accounts
whereas they generate debts that bind the State. At the end of the financial year,
the Director General of the Treasury, Financial and Monetary Cooperation sends a
letter to the Director General of Taxes to transmit every information necessary for
budget coverage. VAT credits are thus subject to extra-accounting management,
which limits the transparency of their management. On these points, it is necessary
to return to a strict budgetary orthodoxy. Finally, the Audit Bench notes that
MINDDEVEL’s Directorate of Local Finance is unable to provide reliable
information on the implementation of the taxation of Regional and Local
Authorities (RLAs). Reforms are needed to increase the Directorate’s operational
capacities, decentralisation being of strategic importance.
In light of these findings, the Audit Bench makes 12 recommendations. It also
initiates one (1) proceeding for mismanagement against certain officials.
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 Audit Bench of the Supreme Court

RECOMMENDATIONS
TO THE PRIME MINISTER, HEAD OF GOVERNMENT

1 - Increase the operational capacities of MINDDEVEL’s Directorate of Local

Finance to ensure effective monitoring of the taxation system implemented by
RLAs;

TO THE MINISTER OF FINANCE

2 - Close the Special Appropriation Account (SAA) “National Solidarity Special
Fund to fight against coronavirus and its economic and social impacts” on December
31 of each financial year, in strict compliance with budgetary annuality, subject to
the adjustments authorised within the framework of the complementary period as
stipulated by Article 99-2 of Decree No. 2020/375 of 7 July 2020 on the General
Rules on Public Accounting;

3 - Record the expenditure incurred under the SAA “Special National Solidarity
Fund to fight against coronavirus and its economic and social impact” on the date
of commitment of each expense, without the possibility of carrying it over to the
following financial year, an option which is not in line with regulations in force;

4 - Strictly reserve the management of the VAT escrow account to the Central
accounting officer of the Treasury (ACCT) in accordance with the law;

5 - Record claims of VAT credit refund as soon as they are validated by the tax
administration, pursuant to Section 92 of Law No. 2018/012 of 11 July 2018 relating
to the Fiscal Regime of the State and other Public Entities;

TO THE MINISTER OF AGRICULTURE AND RURAL DEVELOPMENT

6 - Strictly separate stores to enable better record-keeping of goods;

TO THE MINISTER OF FINANCE AND THE MINISTER OF YOUTH

AFFAIRS AND CIVIC EDUCATION

7 - Conduct a concerted action between MINFI and MINJEC for the rapid payment
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 Audit Bench of the Supreme Court

of the young people whom MINJEC mobilised from April 2020 to raise the
population awareness on the barrier measures to adopt against the Coronavirus;

TO ALL MINISTERS INVOLVED IN THE RESPONSE TO THE PANDEMIC

8 - Develop and implement, at the level of each ministry, a procedure for the
validation of the eligibility of expenditures of the government response plan to
combat the coronavirus pandemic in order to avoid rejections by the Finance
Controller of the streamlined circuit;

9 - Evaluate the ministry’s information system and, if necessary, strengthen and

adapt it to ensure effective financial reporting required under SAA “Special National
Solidarity Fund to fight against coronavirus”;

10 - Provide the Audit Bench diligently with the information requested directly by
its teams or through experts regularly appointed by the Audit Institution;

11 – Produce quarterly and annual reports required by Circular No. 220/C/MINFI

of July 22 2020,though no activity was conducted, which explains the absence of
expenditure;

12 - Systematically inform the Minister of Finance of all funds received from public
entities or international donors in accordance with Section 8 of Law No. 2018/011
of July 12 2018.

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 GENERAL INTRODUCTION

The Coronavirus (COVID-19) health crisis affecting Cameroon since March 2020,
like other countries in Africa and the world, prompted a strong response from the
authorities. The government launched a Global Response Plan of CFAF 479 billion
over three years, that is CFAF 296 billion for the 2020 fiscal year. In this context,
Ordinance No. 2020/001 of 3 June 2020 of the President of the Republic, amending
and supplementing certain provisions of Law No. 2019/023 of 24 December 2019
to lay down the Finance Law of the Republic of Cameroon for the 2020 financial
year provided for tax relief measures estimated at CFAF 114 billion in 2020 and
the establishment of a Special Appropriation Account called “Special National
Solidarity Fund to fight against Coronavirus and its economic and social impacts”.
The budget allocated to this Special fund amounted to CFAF 180 billion, divided
into four programmes involving 24 ministries.

Given the importance of this response plan for the health of the population and
the national economy, the Audit Bench decided to include the audit of the Special
National Solidarity Fund in its programme for the 2020 financial year.

Moreover, the President of the Republic’s Ordinance No. 2020/001 of 3 June 2020
prescribed an independent audit, the results of which were to be made public. Decree
No. 2020/3221/PM of 22 July 2020 of the Prime Minister, Head of Government,
and Circular No. 00000220/C/MINFI of 22 July 2020 of the Minister of Finance
assigned this audit to the Audit Bench. The audit of the Audit Bench gave rise to
two reports. The first report was published on 16 November 2021. It focused on the
resources deployed for the health response to the crisis by the three ministries most
involved, which committed most of the expenditure of the Special Fund in 2020.
The present report focuses on the economic and social response implemented by
the other ministries during the same financial year.

In accordance with Section 86 of Law No. 2018/012 of 11 July 2018 relating to

the Fiscal Regime of the State and other Public Entities, the Audit Bench focused
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 Audit Bench of the Supreme Court

on the regularity of the use of public funds, that is, its economy, efficiency and
effectiveness and the performance of public action.

Finally, at the request of the Prime Minister, Head of Government and following its
programme, the Audit Bench conducted an audit of the Special Fund for the year
2021.

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 PART 1

SCOPE OF THE AUDIT

 Audit Bench of the Supreme Court

1 - A first report on the audit of three ministries

The Audit Bench of the Supreme Court deliberated on 4 June 2021 on the first
audit report on the Special National Solidarity Fund (2020 financial year). This
report was published on 16 November 2021. It focused on the expenditures of three
ministries: MINSANTE, MINRESI and MINFI, which accounted for the bulk of
the 2020 commitments, for a total amount of CFAF 132.9 billion.

The bulk of this expenditure, covering 22 activities, concerned the health response
to the tune of CFAF 50 billion, Programme 972 “economic resilience”, implemented
by MINFI as a discharge of domestic debt.

The Audit Bench concluded its work by stressing the swiftness of the government’s
response to the pandemic. In 2020, the national health system accommodated and
treated COVID-19 patients, whose number was fortunately limited. The setting
up of a dedicated and well-equipped unit in Yaoundé, the ORCA centre, played
a major role. However, the Audit Bench cannot say whether patients who were
treated from home because the hospitals involved did not have buildings to isolate
them were treated appropriately.

This first report identified major difficulties.

Care centres failed to provide the Ministry of Health with the right non-health
information, which limited the ministry’s strategic steering capacity and, therefore,
the effectiveness of the health response. In addition, the lack of centralised accounting
of commitments and payments made under the Special National Solidarity Fund
was a handicap for the strategic management of the prime minister’s response to
the pandemic. It made it impossible to have a complete and real-time overview of
the ministry’s actions.
Finally, the awarding of special contracts was very opaque and conducive to
numerous cases of abuse, many of which are likely to be classified as criminal
offences. The use of this derogative procedure beyond July 2020 was costly to
public finance.

Maintaining it is all the less justified as it has sometimes been slower and less
effective than ordinary procedures. The Audit Bench stressed specifically the need
to maintain the controls exercised by Finance Controllers, market engineers and
store accountants.
3
Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

These observations, and the major difficulty experienced by the audit teams in
gathering reliable accounting information, led the Audit Bench to insist on the
urgent need to speed up the state’s accounting reform, particularly regarding the
automation of the collection of accounting and financial information.

Thirty recommendations to the Prime Minister, Head of Government, the Minister

of Public Health, the Minister of Scientific Research and Innovation and the
Minister of Finance accompanied the first report.

In accordance with Law No. 2018/012 of 11 July 2018 relating to the Fiscal Regime
of the State and other Public Entities, the Audit Bench decided to open fourteen
proceedings for mismanagement.

Also, pursuant to Law No. 2003/005 of 21 April 2003 to lay down the jurisdiction,
organisation and functioning of the Audit Bench of the Supreme Court and Law
No. 2006/016 of 29 December 2006 to lay down the organisation and functioning
of the Supreme Court, the Audit Bench decided to open a procedure for de facto
management, and to transmit to the Procureur General at the Supreme Court twelve
(12) files likely to be qualified as criminal offences.

2 - A second report on the audit of the twenty other ministries and

tax expenditures in 2020

This report focuses on the activities carried out by 20 ministries during the 2020
financial year as part of the fight against the pandemic and the tax relaxation
measures estimated at CFAF 114 billion in the 2020 financial year.

Pursuant to the PrimeMinister’s Decree No. 2020/3221 of July 22 2020, the

resources allocated to these 20 ministries under the Special National Solidarity
Fund to fight against Coronavirus and its economic and social impacts amounted
to CFAF 76.87 billion, according to the breakdown detailed in table 1 below. The
allocation decree stated that these resources should be used in programmes 971
“strengthening the health system”, 972’ economic and financial resilience” and 974
“social resilience”.

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

Table I .Distribution of CFAF 76.87 billion from the Special

National Solidarity Fund among the 20 ministries audited
in this report

Resources allocated
Administrations Programmes
(in billions CFAF)
1 Ministry of Territorial Administration 1.4 971
2 General Delegation for National Security 3 971
3 Ministry of Defence 3.6 971
4 Ministry of Basic Education 6.5 974
5 Ministry of Communication 0.42 971
6 Ministry of Higher Education 6 974
7 Ministry of Trade 1 974
Minister of Economy, Planning and Regional
8 26 972 and 974
Development
9 Ministry of Tourism and Leisure 1.7 972
10 Ministry of Secondary Education 7 974
11 Ministry of Youth Affairs and Civic Education 0.75 971
Minister of Decentralisation and Local Develop-
12 2.5 971
ment
Ministry of Mines, Industry and Technological
13 1 972
Development
14 Ministry of Agriculture and Rural Development 6 972
Ministry of Livestock, Fisheries and Animal In-
15 2 972
dustries
Ministry of Small and Medium-sized Enterpris-
16 2 972
es, Social Economy and Handicraft
17 Ministry of Labour and Social Security 1 974
18 Ministry of Social Affairs 2.5 974
Ministry of women empowerment and the fam-
19 1.5 974
ily
20 Ministry of Transport 1 971
Total 76.87
Source: Decree No. 2020/3221 of the Prime Minister of July 22, 2020

5
Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 PART 2

MANAGEMENT OF THE SPECIAL NATIONAL

SOLIDARITY FUND: LACK OF TRANSPARENCY
AND POOR ACCOUNTABILITY
 Audit Bench of the Supreme Court

The Special National Solidarity Fund to fight against Coronavirus and its economic
and social impacts established by Ordinance No. 2020/001 of 3 June 2020 of the
President of the Republic is a Special Appropriation Account.

In its first report, the Audit Bench already pointed out that it was poorly managed
and that its operation during the 2020 financial year, which was governed by
derogatory rules, was not very transparent since payments from the general budget
and expenses associated with them to MINSANTÉ did not pass through the Public
Treasury account No. 470552 dedicated to the Special Fund, which was opened on
April 15 2020.

The Audit Bench, which had to undertake a difficult exercise to reconstitute the
payments from the general budget to the Special Fund, observed that this situation
was at odds with the objective of transparency underlying the creation of a Special
Appropriation Account dedicated to the fight against the pandemic and reflected a
lack of foresight in the management of revenue and expenditure operations of the
Special Fund.

The findings of the Audit Bench in this second report strengthen this observation.

3 - Derogations granted to the Special Appropriation Account

3.1. - First derogation resulting from the Ordinance of June 3 2020

The first report of the Audit Bench had already pointed out that, regarding the
dispositions of Law No. 2018/012 of 11 July 2018, Ordinance No. 2020/001 of 3
June 2020 introduced a major amendment since its article 57 (bis) provides that,
“the provisions of Section 47, paragraph 2 of the Law of 11 July 2018 relating to
the Fiscal Regime of the State and other Public Entities concerning the ceiling of
10% for payments from the general budget to a special appropriation account do
not apply to the Special National Solidarity Fund to fight against Coronavirus and
its economic and social impacts”.

The same Ordinance immediately draws the consequences of this situation since it
provides in its article 45 (new) that the resources of the Special National Solidarity
Fund amount to CFAF180 billion, or CFAF 43 billion in support funds from
Technical and Financial Partners (PTF) and CFAF 137 billion in payments from the
9
Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

general budget, i.e., 76.1% of total revenue. This situation has two consequences:
first, the Special Fund can no longer be considered a genuine Special Appropriation
Account since it operates three-quarters outside the rule governing the allocation
of resources; secondly, in practice, this situation created difficulty in monitoring
the Special Fund’s income, and therefore in the transparency of budgetary and
accounting operations.

3.2. - A second derogation contrary to the principle of budget annuality

It appears that the Special Fund accounts for the 2020 financial year were not
closed by 31 December 2020 and that the expenditure commitments authorised
for the 2020 financial year continued well beyond that date, presumably until June
30 2021, which would correspond to a financial year of 18 months, based on a
derogation of which the Audit Bench has not found any written record.

This new derogation is contrary to the principle of budget annuality, which is one
of the foundations of the accounting and financial management of the State. It is
also contrary to the International Public Sector Accounting Standards (IPSAS) for
public sector entities, which are based on the annual accounting principle.

This principle derives from sections 25, 39 and 49 of Law No. 2018/012 of July 11
2018.

The principle of annuality makes it possible to compare accounts of successive

financial years, which is no longer the case when the rules relating to the length of
the accounting year are changed.

The Minister of Finance acknowledges that the legal date for closing the accounts
for the COVID-19 SAA execution was not respected and that no action was taken
to justify this de facto extension.

For the Audit Bench, apart from the fact that this derogation has no justification, its
main effect is to confuse the accounting framework of the State budget for the 2020
financial year, where ordinary expenditure operations, committed and liquidated up
to December 31 2020, coexist with the expenditure operations of the Special Fund,
committed and liquidated beyond that date. Moreover, the Settlement Bill for the
2020 financial year, transmitted to Parliament for the November 2021 ordinary

10
Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

session, did not mention that the accounting operations of this SAA continued
beyond December 31 2020. This substantial omission prevented the Audit Bench
from informing Parliament on this point.

The Audit Bench also notes that this operation is not neutral since it no longer
reveals the low level of spending on the fight against the pandemic in 2020 by the
20 ministries that are the subject of this report (see §7 below).

In any event, the Audit Bench complied with budgetary orthodoxy, considering
only revenue and expenditure operations strictly related to the 2020 financial year.

Recommendation 1 to MINFI

The Audit Bench recommends to the Minister of Finance to close the accounts
of the SAA “Special National Solidarity Fund to fight against coronavirus and
its economic and social impacts” on December 31 of each financial year, in strict
compliance with the budgetary annuality, subject to the adjustments authorised
within the framework of the complementary period by article 99-2 of Decree No.
2020/375 of 7 July 2020 on the General Rules of Public Accounting.

4 - A management account submitted to the Audit Bench 14 months late

The SAA management account for the 2020 financial year was submitted to the
Audit Bench by the Specialized Paymaster of the Special Fund on August 1 2022.

Pursuant to Article 26-1 of Decree No. 2020-375 of 7 July 2020 to lay down the
general rules and regulations governing public accounting, the COVID-19 SAA
management account for the 2020 financial year should have been submitted for
judgment to the Audit Bench by May 31 2021. However, it was only produced on
August 1 2022, with a delay of fourteen (14) months.

Moreover, it was closed on June 30 2021, instead of December 31 2020, without

any legal basis (see above § 3.2.).

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

Although in his reply of August 1 2022, the Minister of Finance explained that this
delay was due to structural constraints, the Audit Bench recalls the imperative nature
of the regulatory provisions relating to the production of management accounts.

The quality of information in the management account does not make it possible
to know the state of expenditure commitments as at December 31 2020. Also, the
timing of its production did not provide the Audit Bench with a reliable working
basis for this audit. This also accounts for the difficulty in reconstructing the 2020
accounts of the Special Appropriation Account.

The Audit Bench considers that such a delay is not justified as the Special Account
was created urgently to address a major public health issue, which affected the
nation’s life for many months, and was a top national priority.

5 - A lack of activity and financial reports from the ministries, which prevented
the strategic steering of the Special Fund

Circular No. 00000220/C/MINFI of 22 July 2020 of the Minister of Finance

specifies the modalities of organisation, operation, monitoring and evaluation of
the National Solidarity Fund to fight against Coronavirus and its economic and
social impacts.

It describes the expenditure execution circuit: the Minister of Finance is the

principal authorising officer of the Special Appropriation Account in terms of
revenue and expenditure, and a streamlined financial circuit is set up under the
control of a Finance Controller, who is also the Head of the Budget Control, Audit
and Expenditure Quality Division (DCOB) housed at the Ministry of Finance
and who ensures the regularity of the expenditure, and a Specialised Paymaster is
assigned to SAA.

Above all, it lays down the arrangements for monitoring the execution of
expenditures relating to the Special Fund. The heads of the ministerial departments
had to produce the following:

- A quarterly report on the way COVID-19 SAA activities are conducted and
an assessment of the impact of each action and programme.

- An administrative account and a management account at the end of the

financial year, which they transmit to the Minister of Finance.

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

The audits conducted by the Audit Bench showed that these requirements were
often ignored: only MINPMEESA, MINADER and MINDDEVEL produced these
reports, while the other ministries failed to do so, mainly due to lack of a mechanism
to provide the required financial reporting effectively.

Without feedback from most of the ministries concerned, and while delays and
opacity characterised the accounting management of the Special Fund, it was
impossible for MINFI to conduct effective strategic steering of the Special Fund:
clearly, the authorities never had a real-time overview of the expenses incurred,
nor did they consider evaluating their effects. The Audit Bench had already noted
this in its first report on the three ministries at the heart of the fight against the
pandemic.In this sense, it reiterates Recommendation 1 of the report1.

1
Recommendation 1 of the first report: “Regularly include on the agenda of the meetings of the interminis-
terial body responsible for the strategic management of the pandemic, set up under the auspices of the Prime
Minister, the examination of the accounts of the COVID-19 SAA and the performance of each of the actions
financed”
13
Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 PART 3

CFAF 10.799 BILLION OF EXPENDITURE

COMMITTED FROM THE SPECIAL FUND
AND OWN BUDGETS OF FOUR OF THE
TWENTY MINISTRIES AUDITED
 Audit Bench of the Supreme Court

6 - A Special Appropriation Account not closed by December 31 2020

The Specialised Paymaster did not produce the management account of the SAA
“Special National Solidarity Fund to fight against coronavirus and its economic and
social impacts” for the 2020 financial year to the Audit Bench until August 1 2022.

6.1. - Expenditure commitments for the 2020 financial year that continued
beyond December 31 2020

Documents initially produced by the Specialised Paymaster of the “National

Solidarity Special Fund to fight against coronavirus and its economic and social
impacts” did not make it possible to determine the state of SAA accounts as at
December 31 2020. The monitoring report by administrations presented under the
heading “Budget 2020” indicates “period: from 01/08/2020 to 30/11/2021”, which
does not make it possible to know at what precise date the commitments listed in
this document ended.

This ambiguous presentation suggests that commitments for the 2020 financial year
continued until 30 November 2021 and, in any case, beyond December 31 2020.

This is a substantial anomaly which is, as already underlined in § 3 above, contrary

to the principle of budgetary annuality and to the rules laid down by Decree No.
2020/375 of 7 July 2020 on the general rules and regulations governing public
accounting, and specifically its article 99.

However, the Audit Bench was subsequently able to obtain from the Central
Accounting Officer of the Treasury the amounts of expenditure paid as at December
31 2020, but not the expenditure committed at that date (see §7 below).

6.2. - Misuse of the notion of carry-over

In its implementation report of the Special Fund for the 2021 financial year,
published in June 2022, MINFI states that, “At the close of the 2020 financial year,
files of certain administrations with expenditure eligible for the COVID-19 SAA
which had already received prior budgetary approval, were returned to the various
17
Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

ministries concerned for the physical implementation of the contracted services.

Their processing in the PROBMIS COVID-19 SAA system was not completed in
2020, resulting in a budgetary provision of 40 billion in the 2021 COVID SAA
allocations to cover this expenditure”. He points out that the PROBMIS COVID-19
SAA processing circuit complied with Circular No. 220/C/MINFI of July 22 2020,
“which provides for carry-over in point 3.6.”

The MINFI later publishes table N°5 of the “situation of files proposed for carry-over
by administrations for the 2020 financial year”, in which the amounts committed
(CFAF 42.656 billion), the number of services provided (CFAF 39.965 billion) and
the amount of 2021 carry-overs (CFAF 40.499 billion) appear.

The Audit Bench points out that this presentation is wrong in several respects:

First, it suggests that the 2020 SAA account was closed by December 31
2020, which was not the case;

Secondly, it shows a lack of understanding of the concept of carry-over. In

public accounting, the balances of SAA can be carried over from one year to the
next, and this is what is provided for in point 3.6 of Circular No. 220/C/MINFI
of July 22 2020. Nevertheless, the balances in question refer to unused budget
appropriations. However, the carry-overs in the table published in the COVID-19
SAA 2021 implementation report refer to appropriations already committed in
2020, in most cases with their service rendered.

The Audit Bench recalls a simple accounting rule; when an expenditure is incurred,
it must be recorded and debited to a class 1, 2 or 6 accounts on the date it is
incurred. In this case, the Specialised Paymaster and MINFI disregarded this basic
accounting rule. They, therefore, wrongly considered that CFAF 42.656 billion of
appropriations committed in 2020 (including CFAF 19.855 billion by MINSANTE,
which is out of the scope of this report) could be charged to the management of
the 2021 financial year. Moreover, the fact that the accounting processing with
PROBMIS was not conducted in 2020 did not prevent it from being carried out in
2021 while charging it to the management of the 2020 financial year.
In conclusion, the 2020 and 2021 implementation reports of COVID-19 SAA
produced by MINFI are marred by accounting errors. The Audit Bench was
therefore obliged to reconstruct the 2020 accounts of this Special Appropriation
Account for the 20 ministries audited in this report.
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

Recommendation 2 to MINFI

The Audit Bench recommends that MINFI records the expenditure incurred under
the SAA “Special National Solidarity Fund to fight against Coronavirus and its
economic and social impact” on the date of commitment of each expenditure,
without the possibility of carrying it over to the following financial year. This
option is not authorised by the regulations in force.

7 - Expenditure for the 2020 financial year estimated at CFAF 8.512 billion
under the Special Appropriation Account

7.1. - A reconstruction of expenditure as at 31 December 2020

The Audit Bench asked the Finance Controller to provide it with the situation of
commitments as at December 31 2020. In response, she produced a situation of
operations committed up to 30 June 2021 for the 2020 financial year, which does
not show the separation of the two financial years in accordance with the principle
of budget annuality.

The Specialised Paymaster, who was asked to provide the situation of commitments
entered and payments as of 31 December 2020, could only provide the statement
of payments at that date.

In this context of limited comprehension of financial information, the Audit Bench

was obliged to reconstruct the 2020 expenditure of the administrations involved
in this audit by separating the expenditure commitments made in 2020 and those
made in 2021.

The following table shows the expenses paid as at 31 December 2020. However,
from the list of contracts, the Audit Bench could reconstruct the amounts committed
by five ministries. Therefore, it makes “expenses incurred” and “expenses paid”
coexist, which is far from orthodox but is the best information available.

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

Table II. Estimated 2020 expenditure of 20 ministries

(excluding MINSANTE, MINRESI and MINFI) under the SAA
“Special National Solidarity Fund to fight against coronavirus
and its economic and social impacts.”

Ministries Expenses paid (in thousand CFAF)

DGSN 0
MINAT 0
MINCOM 0
MINDDEVEL 2,400 000
MINDEF 0
MINJEC * 225,000
MINT 0
MINADER * 3,239 126
MINEPAT 0
MINTOUL 0
MINEPIA 0
MINMIDT 0
MINPEMEESA 0
MINESUP 0
MINESEC * 2,648,000
MINEDUB * 0
MINCOMMERCE 0
MINPROFF * 0
MINTSS 0
MINAS 0
Total 8,512,126
* Expenditure incurred

As at 31 December 2020, only four (4) ministries committed expenditure in

COVID-19 SAA, namely MINDDEVEL (2.4 billion), MINESEC (2.65 billion),
MINADER (1.85 billion) and MINJEC (0.22 billion) for CFAF 8,512,126,000,
i.e., 11% of the CFAF 76,870,000,000 allocated by the Prime Minister, Head of
Government for the 2020 financial year.

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

7.2. - Expenditure incurred by 04 ministries in the last quarter of 2020 with

limited impact

Most of this expenditure was incurred in the last quarter of 2020, i.e., at the end of
the year. Given their late date and modest amount, the impact of these measures,
which mainly concerned programmes 972 (Economic and financial resilience) and
974 (Social resilience), was limited in 2020.

To illustrate, MINESEC signed fifteen (15) contracts on 21 December 2020, for

CFAF 2.238 billion, for constructing classrooms in different parts of the territory.
Given the time required to complete the work, the positive effects of this measure
were necessarily postponed until 2021.

7.3. - A modest amount compared to the 132.9 billion FCFA committed in

2020 by MINSANTE, MINRESI and MINFI

An estimate of expenses incurred by the four (4) ministries out of the twenty (20)
audited at CFAF 8.512 billion makes it possible to set the total expenses of the SAA
in 2020 at CFAF 141.395 billion.

The first report of the Audit Bench set the expenditure of MINSANTE, MINRESI
and MINFI, which were in the front line of the fight against the pandemic, at CFAF
132.883 billion. In comparison, the other 20 ministries appear to be in the second
line of the pandemic, with much more modest spending and a spending schedule
largely shifted towards the end of 2020. Therefore, the notion of urgency was not
applied in the same way for all ministries.

The reconstruction of operations of the Special Appropriation Account for the

2020 financial year, which updates the data published by the Audit Bench in its
first report, makes it possible to estimate the total expenditure at CFAF 141.395
billion and the total revenue at CFAF 161.837 billion, i.e., a positive balance of
CFAF 20.442 billion at the end of the financial year to be carried over to the 2021
financial year.

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

Table III. Final reconstruction of the 2020 operations of

the COVID-19 Special Appropriation Account (accounts
closed as at 31 December 2020)

USE
Amounts in
MINSANTE and MINRESI activities (Programme 971) thousands
CFAF
A1A2: Community monitoring in the districts and A1A3: Conduct of Covid
2,624,353
screening campaigns in the ten regions
A2A1: Construction, rehabilitation, extension and fitting out of Covid 19 posi-
4 085,566
tive isolation units
A2A2: Development and equipment of specialized centres for the care of Covid
3 967,624
19 patients
A2A5: Development and equipment of mortuaries and specialized health facil-
383,917
ities
A2A6: Construction and rehabilitation of medical imaging centres -

A2A7: Project management of construction, development and equipment works 421,290

A2A11: Development of quarantine centres in social housing 507,207

A2A10: Comprehensive hospital management of patients with Covid 19 1,085,802

A2A12: Hygiene Management in Care Hospitals Covid 19 -
A2A13: Management of Corpse of Covid 19 Patients -
A1A1: Procurement of rapid tests 25,806,000
A2A3: Procurement of medical equipment for the management of Covid 19
12,761,291
patients
A2A4: Procurement of medical ambulances 880,000
A2A8: Procurement of personal protective equipment 26,783,571
A2A9: Procurement of Covid 19 management drugs 836,443
A3A1: Strengthening barrier mesures to Covid 19 384,593
A3A2: Management of hygiene and sanitation of environments open to the pub-
787,867
lic
A3A3: Quarantine management of passengers arriving in Cameroon in the con-
851,843
text of an epidemic
TOTAL MINSANTE 82,167,367
A1A1: Evaluation of the performance of the Covid 19 rapid screening tests
-
Covid 19 rapid tests for certification
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

A1A2: Development of research and local production of essential antibiotic,

-
antimalarial, anti-inflammatory and immunomodulatory pharmaceuticals

A1A3: Strengthening collaboration between naturopaths and health care provid-

-
ers in the development and certification of traditional products

A1A4: Production of chloroquine and l’azithromycin 610,710

A3A1: Use of traditional medicinal plant extracts for the control of intestinal
-
parasites of ruminants and diseases/pests of plants and agricultural products

A3A2: Production of pre-basic seeds of priority food crops to strengthen food

19,565
and nutritional self-sufficiency
A3A3: Strengthening fish production and improved monogastrics -
TOTAL MINRESI 630,275
 
Domestic Public Debt (Programme 972)2
Reimbursement VAT credits 25,000,000
Clearance of domestic debt and subsidies 25,085,611
TOTAL Public debt 50,085,611

Other administrations 8,512,126

GRAND TOTAL 141,395,379

RESOURCES

Amounts in
Bank deposits thousand
CFAF
Cash 57,695

UBA account 150,000

BGFI BANK account 2,413,521

TOTAL 2,621,216

Payments to the Treasury account (No. 470552)  

Natural persons 120

2
The line «Clearance of domestic debt and subsidies», estimated at CFAF 75.085 billion in the first report, was reduced to
CFAF 50.085 billion to take into account an adjustment entry of CFAF 25 billion.
23
Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

Members of Government 154,600

DB MINEDUB / EN 1,253

BDEAC support 500,000

HUAWEI donation 100,000

TOTAL 755,973

Payments from the general state budget to MINSANTE  

Payments as at 31 December 2020

75,085,354 

TOTAL 75,085,354

   

Payments from the general state budget to other ministries  

Payments as at 31 December 2020 9,805,380

TOTAL 9,805,380

Payments from the general State budget for the clearance of domestic debt
 
and the stock of VAT credits

Reimbursement of VAT credits 25,000,000

Clearance of domestic debt and subsidies 25,085,611

TOTAL 50,085,011

   

Payments from Technical and Financial Partners (TFPs) *  

Payment as a contribution as at 31 December 2020 23,485,000

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

TOTAL 23,485,000

   

GRAND TOTAL 161,837,934

8 - MINESUP, MINESEC and MINEDUB: CFAF 2.287 billion spent outside

the Special Appropriation Account

The three ministries in charge of education, MINESUP, MINESEC and MINEDUB,

committed funds at the beginning of the pandemic, i.e., before the creation
of the SAA, from their own funds: CFAF 754.5 million by universities, on the
instructions of MINESUP, CFAF 699 million by MINESEC and CFAF 834 million
by MINEDUB. All these funds, i.e. CFAF 2.287 billion, were adjusted with the
SAA.

8.1. - Expenditure of CFAF 199.9 million made in an emergency by MINEDUB

before the creation of the SAA, not adjusted

Before the establishment of the SAA, MINEDUB authorised, by decision of 8 June

2020, the purchase from its own budget of:

- 34,791 face masks through 10 purchase orders, for CFAF 45,642,797;

- 5,443 buckets through 11 purchase orders, for CFAF 54,762,692;

- 4182 cartons of soap through 18 purchase orders for FCFA 85 859 232,

A total of FCFA 199 979 208.

Circular No. 220/C/MINFI of 22 July 2020 stipulates in point 2.19 that all
expenditure before the signing of the Ordinance of 3 June 2020 and falling within
the framework of the response strategy against COVID-19 must be the subject of
adjustment commitments and charged to SAA expenditure.

The Audit Bench notes that this was not done.

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

8.2. - Expenditure of CFA 634.4 million for the construction and equipment of
classrooms, not adjusted

By Letter N°000004236/L/MINEPAT/SG/DGEPIP/DPIP/SDPBIP/A3 of 20 August

2020, the Minister of Economy, Planning and Regional Development authorised
“the construction and equipping of classrooms with desks” to the tune of CFAF
800,000,000.

This support aimed to expand the response by using 2020 PIB-MINEPAT funding
to build classrooms and equip them with desks in the Adamawa, Centre, East,
Littoral, West and South regions.

The construction of public schools was committed in 2020 to the tune of CFAF
414,486,162 through 9 jobbing orders and the supply of 4613 desks through 7
jobbing orders to the tune of CFAF 219,949,239. Note that this expenditure is not
reflected in the COVID-19 SAA information.

The Minister of Finance justifies this lack of adjustment by the fact that the above
expenditure, having already been the subject of a first budgetary commitment in the
State budget, cannot be committed again in the COVID-19 SAA budget.

8.3 - Expenditure of CFAF 754.5 million from the budget of State Universities

By circular letter of 21 March 2020 relating to the measures to prevent and combat
the Coronavirus (COVID-19) in higher education, the Minister of State, Minister of
Higher Education asked Universities to apply governmental measures enacted on
very high instructions of the President of the Republic.

By letter of 4 June 2020, he gave new guidelines relating to the management of the
fight against the Coronavirus in the respective budgets of university institutions by
requesting the carry-over of the budgetary allocations devoted to the University
Games and extracurricular activities to the lines dedicated to sanitation and health
coverage of campuses, on the one hand, and the transfer of certain funds from the
investment budget to the protection and health care of the university community on
the other hand.

He also prescribed the organisation of Board meetings to make all these adjustments
in accordance with the regulations.
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

Subsequently, agreements were signed from 9 September 2020 between MINESUP

and State Universities for the provision of each of them with a budgetary allocation
of CFAF 303,885,000 and CFAF 68.5 million for the Cameroon-Congo Interstate
University.

The first expenses resulting from the directives of 4 June 2020 were financed from
University budgets; they amounted to CFAF 754 537 964.

No expenditure from the resources resulting from the agreement was made for the
2020 financial year.

8.3.1 University of Maroua

It appears from the resolutions of the seventh extraordinary session of the Board of
Directors of the University of Maroua dated 22 May 2020 that the budgetary savings
from the postponement of extracurricular activities to 2021 of CFAF 144,382,449
were reallocated to the fight against the Coronavirus, with a view to the resumption
of face-to-face academic activities on 1 June 2020.

Table IV. University of Maroua: reallocation of funds for the

fight against Coronavirus in 2020

Programme 244: Governance and institutional support

Action 6: Development of Human Resources

Activity 6.14: Coronavirus response plan

Appropriations
Code Headings and tasks transferred (in
CFAF)
6.14.1 Purchase of an ambulance 40,000,000
6.14.2 Purchase of face masks 35,000,000
6.14.3 Purchase of thermoflashs 7,500,000
6.14.4 Disinfection of sites 9,382 449
6.14.5 Hand-washing facilities 4,000,000

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 Audit Bench of the Supreme Court

6.14.6 Purchase of hydroalcoholic gels 8,500 000

6.14.7 Purchase of essential medication 5,000 000
6.14.8 Purchase of video projectors 10,000 000
6.14.9 Grant for digitisation of lectures 5,000 000
6.14.10 Provision of internet bandwidth 10,000 000
6.14.11 Making campuses healthier 10,000 0000
TOTAL 144,382 449
Source: University of Maroua

Out of the estimated CFAF 144,382,449, the university committed CFAF 81,896,413.
During the on-site audits, the Audit Bench noted that some items listed in the table
above were completed, including the purchase of an ambulance, the installation of
a hand-washing facility and the purchase of personal protective equipment.
The supporting documents relating to the disinfection of sites, the provision of
internet bandwidth and the purchase of essential medication, amounting to CFAF
20,419,848, are insufficient in light of the regulations in force.

The Audit Bench also notes that no expenditure was incurred in 2020 from the
appropriations of the agreement signed with MINESUP.

8.3.2 University of Ngaoundere

In application of the instructions received by letter dated 04 June 2020 from the
Minister of State, Minister of Higher Education, the Rector of the University
of Ngaoundéré requested, by letter dated 16 July 2020, the transfer of lines
5418241731040 and 54182417310402813 of the 2020 PIB, in the respective
amounts of one hundred and sixty-three million (163,000,000) CFA francs and ten
million (10,000,000) CFA francs respectively, distributed as follows:

- the work to finalise amphitheatre 500 and related offices of ESMV for one
hundred and six million (106 000 000) CFA francs;

- the equipping of amphitheatre 500 of ESMV with desks and the rehabilitation
of certain infrastructure for sixty-seven million (67 000 000) CFA francs.

Analysis of the documents received by the Audit Bench shows that these
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

appropriations were used for the acquisition of supplies and personal protective
equipment, and medical equipment following the administrative purchase order
procedure. Part of these funds was spent as bonuses to staff involved in the fight
against the COVID-19 pandemic. The total expenditure amounted to CFAF
125,801,370, i.e., a difference of CFAF 47,198,630 compared to the initial request.

The Audit Bench stresses the inadequacy of the supporting documents corresponding
to this expenditure regarding the requirements of the 22 July 2020 circular,
specifying the modalities of organisation, operation and monitoring-evaluation of
the Special Fund, particularly in its appendix, which indicates the list of supporting
documents for expenditure regarding purchase orders (File No. 2) and the release
of funds (File No. 3):

- minutes were attached to ten (10) purchase orders for CFAF 40,434,382 and
transmitted to the Audit Bench without any other supporting documents;

- minutes relating to purchases worth CFAF 55,628,523 were sent to the

Audit Bench without copies of the relevant purchase orders.

Also, bonuses were granted to some staff of the University of Ngaoundéré:

- to the tune of CFAF 15,636,640 without authorisation order signed by the

Rector, nor documentary evidence of signature;

- to the tune of CFAF 14,101,825 with an authorisation order but without

proof of their collection by the beneficiaries.

In both cases, payments were made by the designated “cashier”.

In this case, the inadequacy of the supporting documents for CFAF 266,531,130
is likely to constitute a management error.

8.3.3 University of Bamenda

The Rector of the University did not provide the Audit Bench with the deliberations
of the Board of Directors on the carry-over of budgetary allocations relating to
University Games and extracurricular activities to the lines dedicated to sanitation
and health coverage of the campus, which constitutes an obstacle to its due diligence
verification. Furthermore, no supporting documents for expenditure from own
resources were produced.
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 Audit Bench of the Supreme Court

Insufficient supporting documents in this case may constitute a management

error.

8.3.4 University of Douala

The University of Douala requested the Minister of State, Minister of Higher

Education to open a “special intervention” line in its budget to cover the following
expenditure:
- disinfection of classrooms and administrative offices at the University of
Douala;

- coverage of the costs related to the operation of an Information Systems

Division (ISD) to launch online delivery of courses;

- the resumption of in-person classes at the University of Douala;

- the purchase of fabrics to manufacture face masks;

- the purchase of other disinfection equipment;

- the payment of students engaged in the maintenance of classrooms and

other green spaces, i.e., expenses evaluated at CFAF 275,000,000 charged
to the university’s budget for the 2020 financial year.

These budget lines were supplied with CFAF 533.4 million from the funds initially
allocated to the organisation of the University Games, UNIFAC and the acquisition
of the bus for students after approval of the deliberative body of the University of
Douala meeting in its seventh extraordinary session on 14 April 2020.

The Audit Bench notes the inadequacy of supporting documents for expenditure
financed by the release of funds, corresponding to 9 purchase orders worth CFAF
31,590,860 and a jobbing order of CFAF 20,650,000.

8.3.5 University of Buea

While budgetary appropriations for University Games and national celebrations
amounted to CFAF 167,000,000 in 2020, the funds used for expenditure related to
the fight against the pandemic amounted to CFAF 56,045,109, i.e., a commitment
rate of 33.55%. Unfortunately, no supporting documents for this expenditure were
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

sent to the Audit Bench.

This lack of supporting documentation is likely to constitute a management

error.

8.3.6 University of Dschang

The funds reallocated to fight against pandemic amounted to FCFA 151,888,938,
but only FCFA 91,043,534 were used.

8.3.7 The University of Yaounde I

The Rector indicated to the Audit Bench in his letter of 10 May 2022 that, as part of
the academic and financial autonomy of the university, in the face of the crisis and
the social panic as a result, the University of Yaounde I refrained from upsetting the
integrity of the budget voted for the 2020 financial year.
In this case, analysis of accounting documents shows that no expenditure was
incurred to fight against pandemic.

8.3.8 University of Yaounde II - Soa

An “internal commission in charge of the response to COVID-19” replaced the

Board of Directors to modify the initial budget of the university and decided to
transfer CFAF 90,000,000 from the line of University Games to that of sovereignty
expenditure “to take urgent measures within the various campuses and to respect
the barrier measures as enacted by the Government.”

The Audit Bench points out that the Board of Directors should have modified
the initial budget. The urgency of the situation cannot justify using an internal
commission, which is not in conformity with the regulations and directives of
MINESUP.

In any case, the expenditure incurred in 2020 in this framework to the tune of CFAF
42,058,510 was not justified in the documents sent to the audit institution.

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8.3.9 Cameroon-Congo Interstate University (UIECC)

The funds reallocated and committed to fight against pandemic amounted to CFAF
19 996 662. No supporting documents for this expenditure were sent to the Audit
Bench.

8.4. - Expenditure of CFAF 699 million from MINESEC’s own budget

To limit contamination, the government decided to close schools on 17 March
2020. Classes resumed on 1 June 2020 to enable students in examination classes
to complete the year and take part in the official exams organised by the Cameroon
Baccalaureat Board and the Cameroon General Certificate of Education Board.
Certain measures were taken by the Government to limit the spread of the virus and
to respect the rules of hygiene in schools during the resumption of classes.

Special measures were taken to reopen schools.

8.4.1 The reallocation of resources dedicated to FENASCO A Games to the

tune of 152 million FCFA

In a letter dated 15 May 2020, the Secretary General of the Prime Minister’s Office
reminded MINESEC of the Prime Minister’s high directives on the response
strategy against the coronavirus pandemic in Cameroon, notably the publication of
a readjusted school calendar and the reallocation of resources initially dedicated to
FENASCO games and other cultural events to activities relating to the fight against
COVID-19

Thus, a MINESEC decision dated 26 May 2020 reallocated the resources dedicated
to FENASCO A games to finance the Secondary Education Response Plan in the
ten regions. Accordingly, on 27 March 2020, the COVID-19 SAA focal point at
MINESEC deposited the said funds in the accounts of the School Health Support
Fund (FASS) of the various Regional Delegations.
The main objective of these resources was to provide schools with face masks, gels,
disinfectants and cleaning products.

CFAF 102,000,000 were made available to Regional Delegations. However,

several statement of accounts were still not produced by June 2022.
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

Moreover, an additional FCFA 30,000,000 were allocated for the production of

masks in some approved technical schools. FCFA 20,000,000 were set aside for the
supervision of the various activities.

MINESEC did not produce statement of accounts or supporting documents of

expenditure for:

- FENASCO A funds reallocated for the East, West, Littoral and Far North
Regions (CFAF 48,750,000);

- the production of face masks in certain approved technical schools (CFAF

30 000 000);

- supervision activities (CFAF 20,000,000),

That is a total of 98,750,000 FCFA in unjustified expenditure.

8.4.2 Ad hoc transfer of funds to Regional Delegations

By various decisions signed on 26 May 2020, the Minister of Secondary Education

authorised the ad hoc transfer of funds to the Regional Delegates of Secondary
Education to finance the Response Plan against COVID-19 in the secondary schools
of their jurisdictions.

These funds were intended for the purchase of hand washing and disinfection
products, body temperature monitoring equipment, personal protective masks and
hygiene items.

Of the FCFA 582,000,000 transferred, the Audit Bench notes that the statement
of accounts of the Littoral and West Regions were not produced, i.e., CFAF
147,000,000, of funds used was not justified.

8.4.3 The special case of the Regional Delegation of Secondary Education for
the Centre
To deal with COVID-19, MINESEC signed an ad hoc transfer of funds to its
Regional Delegates. On 27 March 2020, the MINESEC COVID-19 SAA focal point
deposited resources from the School Health Support Fund (FASS) in the accounts
of Regional Delegations. Due to all these transfers, the Regional Delegation for the
Centre received CFAF 152 000 000.

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 Audit Bench of the Supreme Court

By Decision No. 000235/D/J/SG/SAFL of 2 June 2020, the Governor of the Centre

Region authorised the release of the sum of FCFA 130 million in favour of a cashier
appointed by the same decision. The latter made direct purchases to the tune of
CFAF 111,172,500 instead of using purchase orders, jobbing orders and contracts
as recalled in Circular No. 00000220/C/MINFI of 22 July 2020 specifying the
modalities of organisation, operation and monitoring-evaluation of the Special
Fund for National Solidarity.
TableV. MINESEC/Regional Delegation for the Centre:
Direct purchases made by the cashier

Amount in
No. Service provider Description
CFAF
01 DKD AGRO AGRO PRO Sprayer 9,500 000
02 CONFECTION MANDILARIS Protective mask (Mandilaris) 50,000 000
03 MTE MEDICAL Infrared thermometer AICAIRE 20,400 000
ALT FRANCK PRIX ; ETS LA
04 Cardboard of 60-piece of soap 22,522 500
MENAGERE
05 GROUPE RIGOSTONE PRIMA tap buckets of 50 L 6,500 000
1000l cubitainers with installation acces-
06 GROUPE RIGOSTONE 2,250 000
sories
TOTAL 111,172,500

The Audit Bench estimated at CFAF 9.148 million the damage caused to the State
of Cameroon, which did not collect registration fees, attestation of non-exclusion,
stamp duties and income tax, due to the circumvention of procedures, which is
likely to constitute a management error of the Regional Delegate for the Centre.

8.4.4 The development of distance learning

During the break between 17 March 2020 and 1 June 2020, and as a matter of
urgency, the Government took decisions to make digital resources available to
students in exam classes.

In his letter dated 21 April 2021 reporting to the Prime Minister on the use of
resources allocated to his ministry for the fight against COVID-19, the Minister
of Secondary Education emphasised that while waiting for the resources from
COVID-19 SAA, budget appropriations from his ministry were redirected to
finance:
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

- the setting up of a distance learning centre at the Bilingual Technical

Industrial and Commercial High School of Yaoundé;

- the production of 320 digital teaching resources, recorded and broadcast on

CRTV in 2020 to complete the 2019/2020 school year;

- the development of a minesec-distancelearning.cm website and the

acquisition of a YouTube channel for the same project (minesec distance
learning).

Regarding the first two tasks, MINESEC received support from UNESCO in
the form of equipment for recording digital teaching resources and assistance in
organising a teacher retraining seminar in Buea. The first recordings were made
at the premises of MINPOSTEL. Subsequently, CRTV made its recording room
available for the recording of digital resources by teachers with materials received
from UNESCO.

For the last task, a jobbing order of CFAF 15,045,021, including VAT, was signed
with CAMTEL for the secure hosting and deployment of digital platforms for the
Ministry of Secondary Education. However, the documents relating to the work
carried out by CAMTEL in the context of this last task were not transmitted to the
Audit Bench.

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 PART 4

A COMMITMENT RATE OF 11.1% THAT

HIGHLIGHTS A POOR ORGANISATION
OF MINISTRIES IN RESPONDING
TO AN EMERGENCY
 Audit Bench of the Supreme Court

Out of twenty ministries to which a budgetary envelope of CFAF 76.87 billion

was allocated for the 2020 financial year, only four ministries spent CFAF 8.512
billion under the Special Appropriation Account for the said year, i.e., 11.1% of
the allocated funds. In contrast, sixteen ministries made no expenditure in 2020,
despite the emergency and the directives issued by the Prime Minister, Head of
Government.

This situation reflects shortcomings in the organisation of administrations, which

were unable to mobilise quickly in a national emergency or which incurred
expenditures without using the funds allocated under the Special Appropriation
Account, notably by relying on funding from international organisations.

9. Inadequate information system and procedures

The Audit Bench commissioned Bekolo & Partners, an audit and consultancy firm,
to collect data from sectoral administrations to evaluate the information system and
procedures.

Nine (9) administrations responded favourably: Ministry of Decentralisation and

Local Development (MINDDEVEL), Ministry of Youth Affairs and Civic Education
(MINJEC), Ministry of Tourism and Leisure (MINTOUL), Ministry of Livestock,
Fisheries and Animal Industries (MINEPIA), Ministry of Mines Industry and
Technological Development (MINMIDT), Ministry of Small and Medium Sized
Enterprises, Social Economy and Handicraft (MINPMEESA), Ministry of Basic
Education (MINEDUB), Ministry of Trade (MINCOMMERCE) and Ministry of
Labour and Social Security (MINTSS).

In contrast, eleven (11) sectoral administrations did not provide any information:
General Delegation for National Security (DGSN), Ministry of Territorial
Administration (MINAT), Ministry of Communication (MINCOM), Ministry of
Defence (MINDEF), Ministry of Transport (MINT), Ministry of Agriculture and
Rural Development (MINADER), Ministry of the Economy, Planning and Regional
Development (MINEPAT), Ministry of Higher Education (MINESUP), Ministry of
Secondary Education (MINESEC), Ministry of Women’s Empowerment and the
Family (MINPROFF) and Ministry of Social Affairs (MINAS).

Of these eleven administrations, some expressed their reluctance to provide data

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

on information systems to a private expert, although the Audit Bench had regularly
commissioned the latter. However, in its procedures, the Audit Bench binds the
experts to be committed to the professional secrecy that is imposed on itself, in
accordance with Section 20 of Law No. 2003/005 of 21 April 2003 laying down the
competence,organisation and functioning of the Audit Bench of the Supreme Court
and with ISSAI Standard 100.

The reluctance of these administrations to provide information prevented the Audit

Bench from assessing the effectiveness of the information system and procedures
put in place as part of the Government’s response plan to combat the Coronavirus
and its economic and social impacts.

It appears that various shortcomings were thus hidden in the organisation of the
administrations concerned.

Recommendation 3 to Ministers involved in the response to the pandemic

The Audit Bench recommends that the Ministers involved in the response to
the pandemic diligently provide the information requested by its teams through
experts regularly commissioned by it.

9.1. Absence of internal actions and ad hoc organisation

First, most sectoral administrations3 have not taken any internal action regarding
the sectoral organisation of the response to the pandemic, its administrative and
financial management, and accountability.

Many of them did not set up an ad hoc organisation, with the accountability of
the various stakeholders, which would have been necessary given the urgent and
strategic nature of the activities assigned to each sectoral administration concerned.
This is the case, for example, with the Ministry of Decentralisation and Local
Development (MINDDEVEL), the Ministry of Mines, Industry and Technological
Development (MINMIDT), the Ministry of Trade (MINCOMMERCE) and the

3
This is the case, for example, with the Ministry of Mines, Industry and Technological Development (MINMIDT), the
Ministry of Trade (MINCOMMERCE) and the Ministry of Labour and Social Security (MINTSS).

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

Ministry of Labour and Social Security (MINTSS).

However, the current organisation of administrations, often marked by cumbersome

decision-making and poor responsiveness, was not likely to respond effectively to
an emergency situation.

On the other hand, the Audit Bench emphasised in its first report that the Ministry of
Public Health (MINSANTE) could quickly set up a crisis organisation that allowed
it to respond well.

9.2. Lack of internal procedures to validate the eligibility of expenditure

Expenditure under COVID-19 SAA is subject to the procedures defined by

Circular No. 220/C/MINFI of 22 July 2020 of the Minister of Finance specifying
the modalities of organisation, operation and monitoring-evaluation of the Special
National Solidarity Fund to fight against Coronavirus and its economic and social
impacts. They had to comply with one of the following two categories of procedures:

- the normal procedure (administrative purchase orders, jobbing orders,

contracts);

- the simplified procedure (release of funds or expenditure that cannot be

executed under the normal procedure).

To effectively implement the response plan, each sectoral administration should

have ensured that the expenditure submitted to the Finance Controller of the
streamlined circuit met the eligibility criteria set out in the circular of 20 July by
implementing internal procedures to validate the eligibility of each expenditure.

Most of the administrations audited did not do so. This failure prevented staff in
the sectoral administrations from taking ownership of the process of validating the
eligibility of expenditure.

This situation had a twofold consequence: the rate of rejection of expenditure

submitted to the Finance Controller under the streamlined circuit was high, and his
department was overloaded with files that should not have been submitted to him,
increasing the processing time of files, which exceeded the 13-day time limit set out
in the circular of 20 July 2020 by an average of 23 days (see §11 below).

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 Audit Bench of the Supreme Court

Recommendation 4 to Ministers involved in the response to the pandemic

The Audit Bench recommends that the Ministers involved in the response to the
pandemic draw up and implement a procedure at the level of each ministry to
validate the eligibility of expenditure under the government’s response plan to
combat the coronavirus pandemic, to avoid rejection by the Finance Controller
of the streamlined circuit.

9.3. – Lack of an organisation to ensure effective financial reporting

Circular No. 220/C/MINFI of 22 July 2020 lists the reporting obligations of

ministers. They must produce the following:

- quarterly to MINFI, a report on the implementation of COVID-19 SAA

activities, as well as an evaluation of the effects of each action and the
impact of the programme on the fight against the pandemic;

- At the end of each financial year, an administrative account and a management

account are to be transmitted to MINFI.

Given the demands for rapid information under the COVID-19 SAA, a mechanism
was needed to ensure effective financial reporting. However, most of the
administrations audited had not set up a dedicated information system or adapted
their information system, which made it difficult to produce the required activity
and financial reports on time.

Recommendation 5 to Ministers involved in the response to the pandemic

The Audit Bench recommends that the Ministers involved in the response to the
pandemic assess their ministry’s information system and, if necessary, strengthen
and adapt it to ensure the effective financial reporting required under COVID-19
SAA.

9.4. Lack of production of activity and financial reports, an obstacle to the

strategic steering of the Special Appropriation Account

Activity and financial reports required by Circular No. 220/C/MINFI of 22 July 2020
must be produced independently upon completion of activities, or the commitments
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

and payment of the services provided, to report on the achievements and difficulties
encountered.

However, most of the sectoral administrations did not produce the quarterly and
annual activity and financial reports of COVID-19 SAA, which prevented the
Prime Minister from having an overview of the situation and contributed to the
weakness of the strategic management of COVID-19 SAA, which the Audit Bench
had already highlighted in its first report.

Table VI. Production of activity and financial reports by

sectoral administrations

Sectoral adminis-
No. Observation
trations

MINDDEVEL did not produce quarterly activity reports required

by circular No. 220/C/MINFI of 22 July 2020 for the 2020 financial
year. None of the financial and accounting reports required by Cir-
1 MINDDEVEL
cular No. 220/C/MINFI of 22 July 2020 was produced by MIND-
DEVEL for the 2020 financial year. Similarly, the activity and finan-
cial reports of the 360 Councils were not submitted.

Only the implementation report for the first quarter was prepared
and submitted to MINFI in accordance with the provisions of Cir-
cular No. 220/C/MINFI of 22 July 2020; the reports for subsequent
quarters have not yet been produced. None of the financial and
2 MINEPIA
accounting reports required by Circular No. 220/C/MINFI of 22
July 2020 was produced by MINEPIA for the 2020 financial year
because MINFI has made no payments and disbursements under
COVID-19 SAA.
Copies of the quarterly activity reports were not made available to
us. Besides, the annual activity report has not been prepared.

3 MINMIDT None of the financial and accounting reports required by Circular

No. 220/C/MINFI of 22 July 2020 was produced by MINMIDT for
the 2020 financial year because there has been no commitment of
expenditure or disbursement of funds by MINMIDT.

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 Audit Bench of the Supreme Court

None of the financial and accounting reports required by Circular

No. 220/C/MINFI of 22 July 2020 was produced by MINEDUB for
4 MINEDUB
the 2020 financial year because most services are ongoing. There-
fore, no report was submitted to MINFI.
None of the activity reports required by Circular No. 220/C/MINFI
of 22 July 2020 was produced by MINCOMMERCE for the 2020
financial year because this ministry has carried out no activities.

None of the financial and accounting reports required by Circular

5 MINCOMMERCE
No. 220/C/MINFI of 22 July 2020 was produced by MINCOM-
MERCE for the 2020 financial year because there has been no com-
mitment of expenditure or disbursement of funds by this ministry.

Source: Reports of the audit and consultancy firm Bekolo & Partners

The Audit Bench points out that the absence of reporting contributed significantly
to the lack of transparency in managing COVID-19 funds. This makes it impossible
to assess SAA’s results and performance and implement corrective measures in
time.

Recommendation 6 to Ministers involved in the response to the pandemic

The Audit Bench recommends that the Ministers involved in the response to
the pandemic produce quarterly and annual reports as required by Circular
No. 220/C/MINFI of 22 July 2020, including no activity reports, which makes it
possible to note the absence of expenditure.

10. Administrations that did not use COVID-19 funds

Sixteen (16) ministries did not incure any expenditure in 2020 under the COVID-19
Special Appropriation Account. From the investigations conducted by the Audit
Bench, it appears that:

- Some administrations received funding from entities other than COVID-19

SAA

- other administrations deliberately decided to stop using SAA funds.

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 Audit Bench of the Supreme Court

10.1. Administrations that received funding from entities other than

COVID-19 SAA

Some administrations, such as MINAT, received resources directly from external

donors as part of the response to the pandemic without informing the Minister
of Finance. The Minister of Territorial Administration indicated that the activities
incumbent on him in the fight against the Coronavirus were fully carried out.
Consequently, he returned the funds allocated under the SAA, i.e., 1.4 billion
FCFA, to the Ministry of Finance. However, he did not provide the Audit Bench
with either the money received from donors or details of the activities carried out.

This situation is contrary to the provisions of Section 8 of Law No. 2018/011 of 12

July 2018, according to which:

“(1) Government services and international donors must inform the Minister in
charge of finance of all funds granted to public entities or for the execution of
projects and activities of public interest.

(2) The allocation of such funds shall be subject to prior approval of the minister
in charge of finance (...)”.

Moreover, Section 67 of the same law states that, “with respect to revenue, the
minister in charge of finance shall be the sole principal authorising officer…”.

Besides, other administrations, notably DGSN and MINDEF, benefited from direct
financing from SNH without informing the Minister of Finance.

Point 2.2 of Circular No. 00000220/C/MINFI of 22 July 2020 specifying the

modalities of organisation, operation and monitoring-evaluation of the Special
National Solidarity Fund to Fight against Coronavirus and its economic and social
impacts states, however that, “The Minister of Finance is the chief authorising
officer of COVID-19 SAA for revenue and expenditure. In this capacity, he/she shall
centralise all revenues and order all expenditures of the said Account.”

The lack of information from the Minister of Finance, who is the main authorising
officer for State budget revenue and COVID-19 SAA revenue and expenditure,
on the resources obtained for the response made it difficult to centralise financial
information exhaustively.

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 Audit Bench of the Supreme Court

Recommendation 7 to Ministers involved in the response to the pandemic

The Audit Bench recommends that Ministers involved in the response to the
pandemic systematically inform the Minister of Finance of all funds received
from public entities or international donors, in accordance with Section 8 of Law
No. 2018/011 of 12 July 2018.

10.2. Administrations that did not use COVID funds

According to the statement of commitments produced by the Finance Controller of
the streamlined circuit, some administrations which had initiated the procedure for
the commitment of expenditure discontinued it4.

Eight (8) administrations decided not to use COVID-19 SAA resources for a
total amount of FCFA 11,420,000,000, i.e., 6.34% of funds allocated for the 2020
financial year.

The non-consumption of funds allocated to the administrations identified for the

2020 financial year calls into question the relevance of the needs expressed by these
administrations. This can also reflect unpreparedness, lack of coordination, control
over procedures and the inability to carry out planned activities.

11. Poor organisation of the response at the local level

The Prime Minister’s allocation decree of 22 July 2020 entrusted the Ministry of
Decentralisation and Local Development (MINDDEVEL) with the task of leading
the response at the local level, with councils, under programme 971, action 03,
activity 1 “Management of hygiene and sanitation in spaces open to the public”.
MINDDEVEL considered that it did not have the operational capacity to implement
this activity and that it was appropriate to transfer this responsibility to councils
together with funds. Circular Letter No. 3942/LC/MINDDEVEL of 22 October
2020 to mayors, however, merely mentions the purpose of the transfer of funds
without any other useful details.

4
This is the case of DGSN, MINCOMMERCE, MINCOM, MINT, MINMIDT, MINTSS, MINDEF, MINAT.
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
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The budget allocated to implement this activity was consumed up to 96%, i.e. CFAF
2.4 billion. The Minister transferred this amount to the Special Fund for Equipment
and Inter-communal Intervention (FEICOM) and instructed it to distribute it among
the 360 councils: each council of divisional capitals received CFAF 11,666,666,
and the other sub-divisional councils received CFAF 5,000,000.

The remaining CFAF 100 million was to finance monitoring and evaluation missions
to implement the activity by MINDDEVEL’s central and devolved administration
staff. This amount was not committed in 2020.

11.1 Implementation by councils deferred to the 2021 financial year

11.1.1 Late arrival of funds

By decision of 13 October 2020, MINDDEVEL allocated a budget envelope to the

council through FEICOM. However, these funds were transferred to councils only
on 3 and 4 December 2020.

On that date, most councils did not consider it appropriate to use the funds before
a deliberation of their Municipal Council to integrate these revenues into their
accounts. The sessions were held only in 2021.

Therefore, although the budget appropriations were committed in 2020 by

MINDDEVEL, the expenditure circuit was such that these funds were only
consumed in 2021, as indicated by statements collected by the Audit Bench.

Note, however, that many councils did not wait to receive funds from the State and
that in 2020 they cleaned public spaces, except for hospitals, from their own funds
by mobilising their municipal hygiene and sanitation services.

11.1.2 Diversified use of funds, sometimes far from hygiene and sanitation
purpose

Without specific ministerial guidelines, the use of transferred resources was

diversified. While some sought and obtained authorisation from the Ministry
of Public Contracts (MINMAP) to award direct contracts and to use the mutual
agreement procedure to purchase disinfectants or personal protective equipment,
others used these resources to carry out projects that are not related to the purpose
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of the appropriation and were thus able to finance the construction of boreholes
with water towers or even the purchase of tricycles.

Given the risks of a resurgence of the pandemic, it is important that the measure
«Hygiene management and sanitation of spaces open to the public” be maintained
and financed in 2022, or even in 2023, provided that MINDDEVEL draws up a
circular setting out the use of the funds.

11.2. Lack of coordination between MINDDEVEL and MINSANTE

The Prime Minister’s allocation decree of 20 July 2020 entrusted the Ministry of
Public Health (MINSANTE) with the implementation of activities with the same
title as that of MINDDEVEL (Programme 971, action 03, activity 02 “Management
of hygiene and sanitation in spaces open to the public”), with a budget of CFAF
850 million5.

The Audit Bench notes that the two administrations did not coordinate the
implementation of this measure.

It also points out that the draft guidance documents issued by WHO for sectors
other than health were not brought to the attention of mayors responsible for their
operational implementation.

These environmental cleaning and disinfection recommendations included:

- faith-based community settings;

- funeral services;

- workplaces;

- the food sector;

- the aviation sector;

- the maritime sector;

- schools;

- prisons.
5
Note that the same decree allocated CFAF 4.193 billion to MINSANTE for community surveillance in health districts,
which was distributed among health districts, and CFAF 1.7 billion to conduct COVID-19 screening campaigns in the ten
regions.
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They prescribed specific cleaning and disinfection techniques and formulas

for preparing disinfection solutions. MINSANTE produced no indication of the
components to be used to disinfect sites and the protection of those in charge of
implementing this activity.

This lack of coordination prevented an optimal allocation of funds to councils. It

led to health risks for people handling chemicals without knowledge of how to use
them.

11.3. Funds not received by Douala 2 council

Douala 2 council did not receive the sum of CFAF 11,666,666 allocated to it by the
State to support the fight against the pandemic.

When contacted by the Audit Bench, the Director General of FEICOM acknowledged
this situation, which he explained as a material error that led to the transfer of these
funds to the Douala 5 council. He provided the Audit Bench with proof of an
adjustment of the situation by a transmission letter of 6 September 2022.

11.4. Resources received by Pouma council but not used

Pouma council received from FEICOM a transfer of CFAF 5 million to implement

measures of hygiene and sanitation of spaces open to the public. However, the
mayor indicated that these funds were not yet mobilised by his council as of 4 May
2022, as the Municipal Treasurer did not inform him of the availability and use of
COVID-19 SAA resources.

He indicated that a report of this situation was transmitted to the Minister of

Decentralisation and Local Development and that these funds are still available in
the council bank account at SCB-Edéa Branch.

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11.5. Lack of evaluation

On 18 November 2020, MINDDEVEL sent two letters to its Regional and

Departmental Delegates concerning the monitoring and evaluation of the
implementation, by councils, of activities to clean up spaces open to the public.

These circular letters do not specify the methods and means of collecting information
and the deadlines for producing financial reports and reports on the monitoring and
evaluation of activity 1 of programme 971, either for the various councils or for
Regional and Departmental Delegates.
Despite these intentions, the Audit Bench notes that the analysis of the impact of
councils’ activities as part of Government’s response plan against the pandemic,
was not carried out. MINDDEVEL did not produce activity reports as required by
circular No. 220/C/MINFI of 22 July 2020 for the 2020 financial year.

Besides, no study on urban sanitation policy and the impact of the government’s
response plan against the COVID-19 pandemic at the local level is available.
However, a budget of 100 million CFA francs was earmarked for this purpose.

12. Insufficient coordination between ministries and international

organisations in managing grants and implementing aid programmes
The Audit Bench notes that ministries have been unresponsive, or even absent, in
optimising donations received or aid programmes from international organisations.
Each ministry coordinated this aid at its level.

12.1. A UNESCO programme of CFAF 5.356 billion poorly coordinated

with MINEDUB and MINESEC
UNESCO launched and implemented, through UNICEF, an emergency response
project against COVID-19 in basic education, aiming to ensure the continuity
of preschool, primary (under MINEDUB) and lower general secondary (under
MINESEC) education in a safe and protective environment. This programme was
financed in 2020 to the tune of US$8.104 million, or CFAF 5.356 billion.
The Audit Bench observes that the two main components of this programme were,
on the one hand, the establishment of a multidimensional distance learning system
through radio, television, online internet platforms (www.monecolenligne et www.
myschoolonline ) and self-learning materials; and on the other hand, the reopening
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of schools and resumption of classes in a safe and protective health environment.

These objectives overlapped with the activities of MINEDUB and MINESEC as

set out in the Prime Minister’s allocation decree of 22 July 2020. For example,
MINEDUB’s programme 974 (social resilience) action 7, titled “development of
distance learning and control tools and virtual platforms,” with a budget of CFAF
390 million, included four activities; MINESEC’s programme 974 (social resilience)
action 03 was titled “Development of distance education/training system” and was
allocated CFAF 7 billion.
The Audit Bench observes that despite the size of the funds committed in 2020 by
UNESCO, in relation to the expenditure of MINEDUB and MINESEC in the same
year, i.e., 0 for MINEDUB and CFAF 2.648 billion for MINESEC, the activities
carried out by UNESCO were not subject to prior consultation with MINEDUB, and
were carried out with local MINEDUB and MINESEC officials, without reporting
to the central administration. Furthermore, poor coordination created a risk of
duplication, given that these ministries were supposed to implement activities that
exactly overlapped with those of UNESCO.

UNESCO interventions were probably not reported to the Government in accordance

with the provisions of Section 8 of the Law on the Fiscal Regime of the State.

12.2. UNDP grants difficult to reach councils

MINDDEVEL received various grants from UNDP, as summarised in Table 7

below:
Table VII .List of grants received from the United Nations
Development Programme (UNDP)
No. Description Quantity
1 Washable protective masks 29,920
2 Backpack sprayers 110
3 BACTOL Disinfecting Gel of 250 ml 1,320
4 La Croix bottles of bleach of 1,5 L 1100
5 Cardboard of 60 pieces of soap of 400g 220
6 25 kg bags of Chlorine 44
7 MADAR detergent of 1kg 1,100
8 plastic buckets of 20 l with adapted tap 1,100
9 SAMSUNG GALAXY TAB A Tablets of 8 INCH 378
Source: MINDDEVEL

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12.2.1. Anti-COVID kits

Anti-COVID-19 kits were intended for 22 sub-divisional councils in the following

cities: Yaounde (07), Douala (06), Maroua (03), Limbé (03) and Bamenda (03).

The seven Yaounde sub-divisional councils received their equipment on Wednesday,

10 June 2020, at the Yaounde City Council Hall during an official handing-over
ceremony presided over by the Secretary General of MINDDEVEL. As regards the
other councils (15), it was up to MINDDEVEL to ensure the delivery of the kits.

Representatives of six councils received their kits at MINDDEVEL against receipt

(the sub-divisional councils of Limbé and Garoua). The rest of the equipment was
forwarded to the other councils.

12.2.2. Digital tablets

The 378 tablets, intended for reporting and monitoring pandemic interventions,
were dedicated to the 360 councils and 14 city councils. Four (4) digital tablets
were intended for the departments in charge of statistics and information
systems of MINDDEVEL.

Of the 378 “SAMSUNG Galaxy” tablets, only 122 were handed over to the mayors
on 1 June 2022, as requested by UNDP. To facilitate the distribution of the remaining
256 tablets, MINDDEVEL plans to transfer them to the United Councils and Cities
of Cameroon (CVUC) for delivery to the beneficiary mayors against receipt.

In conclusion, the handover of donations to councils, which are supposed to

contribute to the response to the coronavirus pandemic, was completed within a
reasonable timeframe in the case of the anti-COVID kits but was far from being
completed by 1 June 2022 as concerns tablets. Mayors seem not to understand the
usefulness of having a reporting tool. Besides, MINDDEVEL did not specify the
monitoring procedures.

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 PART 5

SLOW AND UNEVEN IMPLEMENTATION

OF MEASURES
 Audit Bench of the Supreme Court

In its first report on the expenditure incurred by MINSANTE, MINRESI and MINFI
under the Special Fund in the 2020 financial year, the Audit Bench pointed out that
the emergency procedures used for contracts were justified at the beginning of the
pandemic. Then, they became counter-productive from July 2020 onwards, with
emergency procedures slower than ordinary ones and a lack of control detrimental
to the proper execution of contracts.

The same observations were made regarding the contracts implemented in 2020 by
the ministries subject to this audit.

13. Financial control of the streamlined circuit: files processed in 36 days

instead of 13

The Minister of Finance entrusted the Finance Controller of the streamlined circuit
with the role of Finance Controller of COVID-19 SAA. Point 2.4 of Circular No.
00000220/C/MINFI of 22 July 2020 of the Minister of Finance stipulates that, “the
finance controller of the streamlined circuit housed in the Ministry of Finance shall
ensure the control of the regularity of the expenditure of COVID-19 SAA. To this
end:

- He shall give prior budgetary approval to draft administrative purchase

orders, jobbing orders, contracts, decisions, agreements or any other
act financed from COVID-19 SAA resources;

- He shall control the conformity of the expenditure package to be sent to

the Specialised Paymaster for payment, bearing the words “expenditure
validated”.

In point 2.14, it is specified that, “in the case of the normal procedure (administrative
purchase orders, order letters, contracts, etc.), the Finance Controller of the
streamlined circuit shall affix the budgetary visa to the regular draft acts and return
the draft expenditure to the Minister concerned, who shall sign the expenditure acts
and make the service provider record them in accordance with the regulations in
force; he shall return them to the Minister in charge of finance who shall issue the
Commitment Certificate (...).”

The aim is to speed up the processing of files.

The same circular underlines the need to speed up the processing of expenditure
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
 Audit Bench of the Supreme Court

files executed under the Special Fund. In point 2.17, the circular states that, “the
actors involved in the management of the Special Fund must strive to comply
scrupulously with the following deadlines:

- From legal commitment to accounting commitment: 10 (ten) days (...) “

The Audit Bench examined a sample of 73 files from MINESEC, 9 files from
MINEDUB and 15 files from MINADER to assess the processing time required to
obtain a prior visa in the department of finance control of the streamlined circuit.
The average processing time for all these files was 36 days, i.e., an average overrun
of 23 days.

According to the Minister of Finance, these delays are due to the extension of
the eligibility validation time, the time needed for stakeholders to adapt to the
procedures and to the PROBMIS CAS COVID-19 software, as well as the reduced
number of staff in the streamlined circuit compared to the number of requests from
administrations.

As a result, the signing of contracts by the contracting authorities was delayed,

which impacted the start of activities, although these were selected in the context
of a health emergency.

In conclusion, the Audit Bench noted bottlenecks at the level of the finance
controller of the streamlined circuit, which resulted in longer deadlines.

14. The notion of urgency largely forgotten during the implementation of

contracts

14.1. Contracts awarded as a matter of urgency yet not implemented 18

months later

AT MINESEC
The Audit Bench noted major disruptions that affected the setting up of multimedia rooms
necessary to develop distance learning. In some cases, the equipment was still not delivered
by March 2022, although the construction was completed and accepted. In other cases, the
equipment was delivered while the construction work was not complete.

In both cases, the equipment was still not operational in March 2022.

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Table VIII. Contracts for the equipment of multimedia

rooms not delivered in March 2022, although
the multimedia rooms have been delivered and
accepted

Status of the
Name of undelivered equipment con-
No. Contractor Amounts buildings await-
tracts
ing equipment
LC N° 64/20/LC/GG/MINESEC/
CIPM/2020 for the equipment of multi-
ETS IDVATION P.O. Construction
media rooms for distance learning at the
1 BOX: 12582 Yaounde 41,000,000 work completed
Government Technical High School of
Phone: 699734589 and accepted
LAGDO and Government High School
of Kollere-Garoua
Construction
LC N° 63/20/LC/GG/MINESEC/
work was com-
CIPM/2020 for the equipment of mul- ETS IMPACT INNO-
pleted and ac-
timedia rooms for distance learning at VATEUR P.O. BOX:
2 41,000,000 cepted in Manen-
the Government High School of Manen- 3309 Yaounde Phone:
gouba, and 80%
gouba and Government Bilingual High 699885302
was completed in
School of Yabassi
Yabassi
LCN° 65/20/LC/GG/MINESEC/
Construction
CIPM/2020 of 14 December 2020 for ETS DYNK’S ENGI-
work completed
the equipment of multimedia rooms for NEERING P.O. BOX:
3 41,000,000 and accepted
distance learning at the Government Bi- 25116 Yaoundé Phone:
(Bayelle-Nkwen
lingual High Schools of Bayelle-Nkwen 695377132
equipped)
and Nkambe
In Bertoua, the
LC N° 61/20/LC/GG/MINESEC/ work has been
CIPM/2020 for the equipment of multi- ETS IMPACT INNO- completed but
media rooms for distance learning at the VATEUR P.O. BOX: has not yet been
4 41,000,000
Government Technical High School of 3309 Yaounde Phone: accepted. Work
Bertoua and Government Classical High 699885302 has not yet start-
School of Yokadouma ed in Yokadou-
ma.
LC N° 67/20/LC/GG/MINESEC/
ETS LEO DESIGN
CIPM/2020 for the equipment of multi- Construction
P.O. BOX: 2197
5 media rooms for distance learning at the 41,000,000 work completed
Yaounde Phone:
Government Technical High Schools of and accepted
694041170
Kribi and Ambam

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LC N° 66/20/LC/GG/MINESEC/
CIPM/2020 for the equipment of mul-
ETS IDVATION P.O. Construction
timedia rooms for distance learning at
6 BOX: 12582 Yaounde 41,000,000 work completed
the Government High School of Baham
Phone: 699734589 and accepted
and Government Classical High School
of Bafang
LC N° 68/20/LC/GG/MINESEC/
CIPM/2020 for the equipment of mul- STE TA ENGINEER- Construction
7 timedia rooms for distance learning at ING SARL Phone: 41,000,000 work completed
CETIC of BIMBIA and Government 677969556 and accepted
Technical High School of Limbé
Total 287,000,000

Furthermore, the contracts signed by MINESEC did not provide an operating

licence for the computer equipment delivered. As a result, even if this equipment
were made available to the beneficiaries within the time limit of the emergency, it
would not have been used for lack of an operating licence.

AT MINADER

The action aimed at reducing food dependency included five activities, notably the
acquisition, distribution and monitoring of the use of seeds of cereals,vegatables,
roots and tubers, and market gardening for 1000 producers’ organisations (activity
1) and the rehabilitation of seed farms and the production of organic fertilisers in
the areas most impacted by COVID-19 in Cameroon (activity 3)

Two contracts awarded in 2020 were still undelivered in March 2022.

Table IX. Contracts awarded by MINADER in 2020

and not delivered as at 31 March 2022

Amounts
No. References and title of the contracts Holders Status
(In CFAF)
Contract No. 030/M/MINADER/CIPM/2020 of 24
November 2020 after following for Tender No. 019/
AONO/MINADER/CIPM/2020 of 2 September 2020
1 70,716,800 MOS SARL Not delivered
for the supply and distribution of agricultural equip-
ment for wheat cultivation (one (01) tractor, three (3)
power tillers and one (1) combine harvester)

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Contract No. 034/M/MINADER/CIPM/2020 of 1

December 2020 following Call for Tender No. 014/
AONO/MINADER/CIPM/2020 of 16 September 2020 ETS OUM-
for the acquisition of one thousand two hundred and BA
2 ninety-eight (1298) Cobra 2 hybrid tomato seeds in 56,562,000 P.O. Box Not delivered
50g boxes, three thousand (3000) Cobra 26 F1 hybrid 14056
tomato seeds in 5g bags, one thousand (1000) Lindo Yaounde
F1 tomato seeds in 5g bags, one thousand (1000) Na-
dira F1 tomato seeds in 5g bags.

As of April 2020, MINADER launched national invitations to tender under the

emergency procedure and obtained authorisation from the Public Contracts
Authority to award other contracts by mutual agreement. These procedures made
it possible to award contracts as quickly as possible to ensure food and nutritional
security of the population and to increase the supply of food products in urban and
rural markets following restrictions on inter-city travel.

After opening tenders, the internal Tenders’ Board proposed that contracts be
awarded based on the best offer, or in the case of a single bid to the only company
that expressed interest, although it has no experience. This was the case for contract
No. 034/M/MINADER/CIPM/2020 of 1 December 2020, for which delivery was
still expected at the end of March 2022.

14.2. Equipment delivered and accepted, although the construction work is

not complete 

The Audit Bench noted, among the contracts for the construction of multimedia
rooms at MINESEC, abnormal situations where the equipment was delivered and
accepted without the construction work being completed.

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Table X. Uncompleted construction work despite the

delivery and acceptance of multimedia equipment
in March 2022.

No. Title of the contract Contractor Amounts Observation

ETS LA MA-
LC N°108/20/LC/GG/MINESEC/CIPM/2020
TURITE.P.O. Project 92% com-
for the construction of multimedia rooms for
1 BOX: 1668 12,000,000 pleted (finishing
distance learning at the Government Classical
Yaounde Phone: work in progress)
High School of Nanga-Eboko
699483942
LC N°100/20/LC/GG/MINESEC/CIPM/2020 ETS BAM
for the construction of multimedia rooms COMPANY Not started
2 for distance learning at ENIEG Bilingue of P.O. BOX 103 24,000,000 (OS notified on
Ngaoundéré and Government High School of Maroua Phone: 01/02/2021)
Ngaoundéré Mardock 675499096
ETS BAM
LC N° 109/20/LC/GG/MINESEC/CIPM/2020
COMPANY Project 60% com-
for the construction of multimedia rooms for
3 PO. BOX 103 12,000,000 pleted (awaiting
distance learning at the Government Bilingual
Maroua Phone: roofing)
High School of Maroua Domayo
675499096
LCN° 113/20/LC/GG/MINESEC/CIPM/2020
ETS CE & Project executed
for the construction of multimedia rooms for
4 CIE Phone: 12,000,000 at 40% (work at a
distance learning at the Government High
699483942 standstill)
School of Eséka

Source: Follow-up report on the implementation of COVID-19 projects at MINESEC and approval reports.

14.3. Inadequate management of deadlines

14.3.1. Exceeding the time limits for authorizations to award contracts by

mutual agreement

Article 111 (6) of the Public Contracts Code provides as follows, “Except for
contracts awarded by mutual agreement that were included in the contracts award
plan, the Contracting Authority or Delegated Contracting Authority shall, with
effect from the date of the grant of prior authorization by the Authority in charge
of public contracts, (...) have 45 (forty-five) days for the cases referred to in Article
109 b) and c) of this code, to sign and notify the corresponding contract to the
successful bidder, under pain of expiry of the authorization to award the contract
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 Audit Bench of the Supreme Court

by mutual agreement.”

Most contracts and jobbing orders awarded by MINESEC and MINADER as

part of the fight against the pandemic were signed and notified beyond the 45-day
deadline, in violation of the provisions of the Public Contracts Code.

All these contracts were signed without renewal of the authorisation, which had
become obsolete by the Minister Delegate at the Presidency in charge of Public
Contracts.

14.3.2. Delivery or performance of services without obtaining an extension

of time

The Audit Bench notes that a good number of MINEDUB, MINESEC and
MINADER contracts exceeded the contractual deadlines without an extension of
time.

15. Poor store accounting likely to promote misappropriations

As part of the response plan against the COVID-19 pandemic, the Minister of
Finance provided for the appointment of a store accountant per administration
involved. The said store accountant shall be responsible for receiving acquired
products and consumables and recording equipment before they are assigned.
The provisional acceptance of products by the acceptance committee is preceded
by the delivery of supplies by the service provider and the technical acceptance by
a restricted committee.

AT MINESUP

The management account produced by the store accountant of the Special Fund of
the University of Ngaoundéré violates the regulations in force.

The absence of records on the management of various acquisitions made by the

university shows a lack of monitoring of inputs and outputs of the various types of
equipment purchased.

Besides, the authorising officer did not sign the extract from the store accountant’s
books.
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The Audit Bench reiterates the need for stores accounting in accordance with
Circular No. 0000000004/CAB/MINFI/ of 18 May 2012, containing instructions
on stores accounting.

AT MINADER
Poor stores accounting is illustrated in various ways:
- more outflows under COVID-19 SAA than inflows.

TableXI. Material outputs under COVID-19 SAA higher

than inputs

No. Material description Input Unit price Output Excess Excess Out-
quantities quanti- output put Value
ties
1 Plastic watering can 11l 605 1450 767 162 234,900
2 Atomizer 69 325,000 82 13 4,225 000
3 Safety boots 220 9488 320 100 948,800
4 Coveralls 123 34,085 360 237 8,078 145
5 Fertilizer NPK 142314, in 3616 22,000 4841 1225 26,950 000
bags of 50kg

6 Fertilizer NPK 201010, in 4034 18,500 4281 247 4,569 500

bags of 50kg
7 Leather gloves 1000 1150 1345 345 396,750
8 Herbicide decagrass 5l 100 17,250 140 40 690,000
9 Cobra tomato seeds 1500 29,900 2500 1000 29,900 000
// TOTAL 75,993 095
Source: Account of MINADER COVID -19 SAA store accountant

- Outputs under COVID-19 SAA omitted from the input sheets.

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Table XII. Materials removed from stock with no

record

No. Description Output quantities

1 Bathing cap 50
2 Chlopyroy 150
3 Chocyrole 1000
4 Carrying case 10
5 Dryer 10
6 Insecticide for vegetables 890 l
Source: Material accounts of the accountant CAS COVID -19 MINADER

Due to lack of space, resources acquired under MINADER’s PIB were stored in the
same stores as those acquired as part of the response to the COVID- 19 pandemic.
As a result, in the rush and multitude of requests, it appears that some goods were
distributed without considering their sources.

Recommendation 8 to MINADER

The Audit Bench recommends ensuring strict separation of stores for different
goods to enable better record-keeping

16. Support from MINADER to reduce food dependency awarded to 64

individuals to the tune of CFAF 424.5 million

In 2020, MINADER allocated CFAF 3.239 billion to reduce food dependency.

However, the effectiveness of this activity depends, first, on the identification of the
beneficiaries of the aid.
However, the Ministry has not been able to produce a procedural manual to direct
this aid to its beneficiaries.

MINADER’s stores accountant’s records show that this aid was distributed mainly
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 Audit Bench of the Supreme Court

to the Ministry’s Regional Delegations, with the task of reallocating it to the final
beneficiaries, i.e., farmers’ associations and community interest groups (GICs),
which are the natural recipients.

However, the aid was also distributed to 64 individuals whose eligibility is

questionable, including a minister, two Parliamentarians, a colonel and a Finance
Controller.

The quantities taken out and the prices shown on the stock entry orders in the
stores accounting show that these individuals were given goods with a total value
of CFAF 424,499,579.

The Audit Bench does not have sufficient evidence that, in the context of an urgent
need to reduce food dependency that justified the distribution of aid, MINADER
defined and applied objective criteria that made it possible to conclude that the 64
individuals benefiting from the agricultural equipment were well suited to achieving
the immediate goal of reducing food dependency.

Furthermore, MINADER did not control the use of these resources nor ask the
beneficiaries how they used them.

The Audit Bench stresses that this situation is harmful and leaves the door
open to misappropriating these resources by individuals who are likely to sell
them.

This situation is likely to be classified as a criminal offence

17. CFAF 225 million still to be paid to young volunteers mobilised to raise
the population awareness

From April 2020, the Ministry of Youth Affairs and Civic Education (MINJEC)
mobilised cohorts of young volunteers to sensitise and inform the population about
the barrier measures to adopt to break the transmission chain of COVID-19.

“Volunteer stipends” to be paid to these outreach workers6, amounting to CFAF 225

million, were still not paid in August 2022.

According to the Minister, the files relating to the payment of these expenses

6
Appendix 12: COVID-19 SAA report foe the 2020 financial year
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experienced many rejections for reasons including the absence of a statement of

payments and the absence of numbers in the “Treasury” accounts of the Regional
Delegations of Youth and Civic Education (DRJEC) into which the funds had to be
transferred.

Given that DRJECs do not have “Treasury” accounts, a request to open such
accounts was sent to MINFI by MINJEC. However, there was no follow-up to this
request.

The Minister of Finance stated that the processing of these expenses was not
completed before the closing date of budgetary operations for the 2020 financial
year due to non-compliance with procedures. He points out that, in accordance with
the provisions of Section 47(5) of Law 2018/12 of 11 July 2018, these appropriations
were carried over to 2021 and that, as at 1 August 2022, the commitment requests
were still not sent to him.

Recommendation 9 to MINFI and MINJEC:

The Audit Bench recommends a concerted action between MINFI and MINJEC
to pay these young people whom MINJEC mobilised from April 2020 to raise
awareness among the population on the barrier measures to adopt against the
coronavirus.

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 PART 6

VAT CREDIT REFUNDS, OTHER

ADMINISTRATIVE MEASURES AND
TAX EXPENDITURE
 Audit Bench of the Supreme Court

18. Numerous tax measures decided by the government

18.1. Measures announced by the Prime Minister in a special statement on

30 April 2020

In a press release issued by the Prime Minister on 30 April 2020, the Government
announced the implementation of 10 tax measures in 2020:

Supporting the finances of companies through the allocation of a special

1 envelope of FCFA 25 billion for the clearance of stocks of VAT credit
awaiting reimbursement
The postponement of the deadline to pay land taxes for the financial
2
year to 30 September 2020
The exoneration from the tourist tax in the hotel and catering sectors for
3
the rest of the 2020 financial year as of March
Exoneration from the discharge tax and from parking fees for taxis and
4 motorbikes as well as from the axle tax for the 2nd quarter. This measure
could be extended to the rest of 2020;

Exoneration for the second quarter from the withholding tax and council
5
taxes (market duty, etc.) for petty traders (bayam sellams)

The suspensions for the second quarter of 2020 of general accounting

6
audits, except in cases of suspected tax evasion
The postponement of the deadline for filing statistical and tax declara-
7
tions, without penalties in case of payment of the corresponding balance
The suspension of forced recovery measures against companies directly
8
affected by the crisis.
Full deductibility to determine the corporate income tax of donations and
9
gifts made by the companies for the fight against the COVID-19 pandemic
The temporary suspension for three months of the payment of parking and
10 demurrage charges in the Douala and Kribi ports for essential goods.
.
Circular No. 20/169/CF/MINFI/DGI/DLRI/L of 13 May 2020 specifies the terms
and conditions for the application of tax measures in response to COVID-19.

The Audit Bench stresses that the principle of fiscal legality enshrined in Section
5 of Law No. 2018/012 of 11 July 2018 relating to the Fiscal Regime of the State
and other Public Entities was not respected since the circular of 13 May 2020
anticipated the provisions of Ordinance No. 2020/001 of 03 June 2020 amending
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and supplementing certain provisions of Law No. 2019/023 of 24 December 2019

to lay down the Finance Law of the Republic of Cameroon for the 2020 financial
year.

However, the health and economic emergency that prevailed between March and
June 2020 and the climate of great uncertainty about the health and economic
consequences of the pandemic explain why the Government did not wait for legal
authorisation before implementing tax measures.

18.2 Measures decided by Ordinance No. 2020/001 of 3 June 2020 of the

President of the Republic

Ordinance No.2020/001 of 3 June 2020 amending and supplementing certain

provisions of Law No. 2019/023 of 24 December 2019 to lay down the Finance
Law of the Republic of Cameroon for the 2020 financial year provided a legal
basis for these provisions. Four announced measures are omitted in the ordinance
because they are mere administrative measures.

Suspension for the 2nd quarter of accounting audits except in cases of sus-
1
picious tax behaviour.
The postponement of the deadline for filing statistical and tax declarations,
2
without penalties in case of payment of the corresponding balance
The suspension of forced recovery measures against companies di-
3
rectly affected by the crisis.
The temporary suspension for three months of the payment of park-
4 ing and demurrage charges in the Douala and Kribi ports for essen-
tial goods.
On the other hand, the ordinance incorporates four measures of a fiscal nature that
were omitted in the Prime Minister’s special statement of 30 April 2020:
Exoneration from VAT, equipment purchases, materials and products for the
1
fight against the coronavirus.
Full deductibility to determine the corporate income tax of denotations and
2
gifts made by the companies for the fight against the COVID-19 pandemic
Total exoneration from customs duties and taxes on the import of products
3
and equipment to prevent and fight COVID-19.
The suspension of the collection of interest for late payment of customs duties
4
and taxes.

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19. Implementation of tax measures

19.1. VAT credits refund

VAT credit refund is an activity of action three and comes under programme 972
of the Prime Minister’s Decree No. 2020/3221/PM of 22 July 2020, fixing the
distribution of the allocation of the Special National Solidarity Fund to fight against
Coronavirus and its economic and social impacts

The Minister of Finance funded the VAT escrow account No. 10

311101 1013 opened at BEAC to the tune of CFAF 25 billion,
i.e., CFAF 15 billion, on 11 May 2020 and CFAF 10 billion on
27 May 2020. This sum was intended to clear the VAT stock of
(fifty-eight) of the 69 (sixty-nine) companies whose refund
files had been validated.

In its first report, the Audit Bench had already stressed that, based on the supporting
evidence submitted, there was no doubt about implementing this response measure.
Thus, the stock of VAT debt which was CFAF 25,913,539,948 in May 2020, declined
to CFAF 15,531,802,703 as at 31 December 2020, well below the average amount
of CFAF 35,000,000,000 usually carried over from year to year.

This expenditure was charged as an adjustment to the Special National Solidarity

Fund to fight against Coronavirus and its economic and social impacts after its
establishment by the ordinance of 3 June 2020 and its operational implementation
as of 1 September 2020.

19.1.1. A VAT credit refund scheme provided for in Article 149 of the General
Tax Code

Reforms before the 2020 financial year were implemented to improve the VAT
credit refund system. They notably included:

- An escrow account opened at the BEAC in 2018 to allow the Treasury to

allocate CFAF 6 billion automatically per quarter to the reimbursement
of VAT credits, i.e., CFAF 72 billion per year;

- The dematerialization of the procedures for requesting VAT credits

refunds for entities under the jurisdiction of the Directorate for Large

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Enterprises since July 2017;

- the processing of refund claims by the tax administration according to a

risk-based approach (depending on their tax behaviour, Art. 149 CGI).
The classification shall be made public by decision of the Minister of
Finance.

According to Article 149 of the General Tax Code (CGI), the refund for companies
classified as low risk is made automatically without a prior validation control
procedure. For companies classified as medium-risk, repayment is made at the end
of a credit validation control procedure.

Finally, in the case of companies classified as high-risk, the refund can only be
made after a general accounting audit, which must be carried out within one month
after submission of the application for refund.

19.1.2. The principle of separation of the functions of authorising officer and

accountant disregarded by the Director General of Taxes

By various correspondences in May 2020, the Director General of Taxes instructed

the National Director of BEAC to transfer funds to a list of companies to refund
VAT credits by debiting the VAT Special Account. The Audit Bench obtained
SWIFT documents indicating that BEAC executed these transfer orders.

The Audit Bench notes that in doing so, the Director General of Taxes ignored the
principles laid down by Section79 of Law No. 2018/012 of 11 July 2018 relating to
the Fiscal Regime of the State and other Public Entities, which provides, inter alia,
that, “public resources shall be, irrespective of their nature and source, collected
and managed by public accounting officers. They shall be placed and kept in a
single account opened in the name of the Treasury at the Bank of Central African
States”. Section 71-3 of the same law further provides that, “prior to each payment,
the public accountant shall cross check the validity of the claim and the definite
nature of the payment. Otherwise he may not make the payment”.

Article 4 of Decree No. 2013/160 of 15 May 2013 on the general rules and regulations
governing public accounting states that, “the Public Treasury exercises monopoly
on the collection of all revenues (...)”, while Instruction No. 20/001/I/MINFI/G/
DGTCFM/CL of 10 January 2020 on the nomenclature of Treasury accounts for
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the 2020 financial year further stipulates that only the Central Accounting Officer
of the Treasury (ACCT) shall be empowered to debit account 51241 “VAT escrow
account”.

The Minister of Finance explains this situation by the existence of an agreement

governing the special transit account for VAT signed on 3 February 1999 with the
Governor of the BEAC, which, in his opinion, is a supranational standard.

The Audit Bench does not share this position, especially since this agreement would
have to be ratified to have supranational value.

Recommendation 10 to MINFI

The Audit Bench recommends that the management of the VAT escrow account
be strictly reserved to the Central accounting officer of the Treasury (ACCT) in
accordance with the law.

19.1.3. Failure to record VAT credits, contrary to the principle of recognition

of rights and obligations

No account of the trial balance for the 2020 financial year recorded the amount of
VAT credits still to be paid as at 31 December, so it is not possible to reconcile the
data provided by the General Tax Directorate (DGI) with accounting data. This
situation is the consequence of the management of the VAT escrow account opened
at BEAC by the Director General of Taxes, outside the circuit of public accountants
(see above § 10.1.3.).

It thus appears that VAT credits validated by the competent DGI departments are
not recorded in the accounts of the Department of Public Accounting, although they
generate debts that are binding on the State. At the end of the financial year, the
Director General of the Treasury, Financial and Monetary Cooperation shall send a
letter to the Director General of Taxes to transmit information necessary for budget
coverage.

VAT credits are subject to non-accounting management, which limits the

transparency of their management. The non-accounting of VAT credits validated
by DGI is contrary to Section 75 of the above-mentioned Financial Regime law,
which states as follows, “General accounting shall be based on the principle of
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 Audit Bench of the Supreme Court

acknowledgement of rights and obligations.Transactions shall be considered in the

year to which they relate, independently of their date of payment or collection.”

In this case, the Ministry of Finance is ignoring the principle of recognition of

rights and obligations which governs public accounting.

Recommendation 11 to MINFI

The Audit Bench recommends that the accounting possessing of VAT credit
refund requests be carried out as and when the tax administration validates them.

19.1.4. Fifty-eight (58) beneficiary companies, mostly from the forestry sector

The sum of 25 billion was used to pay fifty-eight (58) companies (see graph 1
below). The forestry sector specifically received 34% of the allocation.

It should be recalled that the VAT mechanism leads to structural tax credits for
exporting companies, whose exports shall be taxed at zero rate, and for suppliers
and service providers to the State, whose VAT invoice shall be withheld at source.

Chart 1 - Breakdown of VAT credit refunds by sector

Equipment; 887 Telephone; 52

321 899; 4% Finances; 570 200
713 878; 0%
775; 2%
Service provider; 931
301 917; 4%
Industrial; 1
118 706 994;
4%
Agro
Industrial; 2
931 751 Forester; 8 459
657; 12% 578 472; 34%
Transporter; 3
273 973 169;
13%

BTP; 6 774 451

239; 27%

Source: MINFI/DGI/CRRIT

VAT credit refunds accounted for 25.2% of domestic debt service in 2020, compared
with 10.7% in 2018.
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19.2. Other administrative measures

19.2.1. Suspension of forced recovery

DGI provided information from 1 August 2020 to 31 December 2021. It pointed

out that 4,386 claims were targeted for a potential of CFAF 117,992,086,146 in
principal, but only 262 claims were recovered for CFAF 56,520,586,153, i.e., a
difference of CFAF 61,471,499,993.

The estimated loss of revenue resulting from this measure, in proportion to the five
(05) months of the 2020 financial year, amounts to CFAF 18.079 billion.

19.2.2. Suspension of tax audits

According to DGI, for 2017, 2018 and 2019, tax auditing showed an average annual
return of FCFA 54.5 billion. In the 2020 financial year, marked by the suspension of
control activities for one quarter, the return was CFAF 39.3 billion.

Under these conditions, the loss of revenue from this measure can be estimated at
CFAF 15.2 billion.

19.3. The lack of response from the Director General of Customs

The Audit Bench referred the matter to the Director General of Customs in a letter
dated 21 February 2022 to ascertain the impact in figures of the implementation of
measures relating to:
- full exoneration from custom duties and taxes on the import of products
and materials for the prevention and control of COVID-19 in the 2020
financial year;

- the suspension of the collection of interest for late payment of customs

duties and taxes.

The Director General of Customs did not respond to the Audit Bench’s request.

19.4. Tax expenditures

According to the OECD7, “tax expenditures are special measures derogating from

7
Organisation for Economic Cooperation and Development, «Tax Expenditures in OECD Countries», 2010, P.
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the reference tax system that generate revenue losses for the State, to encourage a
particular economic behaviour on the part of taxpayers, or of subsidizing certain
social groups”.

Tax expenditures result in a reduction in the tax burden of taxpayers compared to

that which would have resulted from the norm’s application, i.e., the tax provisions
as set out in the General Tax Code (CGI) or the initial Finance Law. They can take
the following formats:

- Exoneration : total exclusion from the tax base;

- Abatement: amount deducted from the tax base before the application
of the tax rate(s);

- Rate relief: reduced tax rate;

- Tax deferral: delay in the time allowed to pay the tax obligation.

Except for VAT credits refund, the other tax measures taken by the Government as
part of the response to COVID-19 are by nature “tax expenditures”.

19.4.1. A lack of impact assessment

Section 9 of Law No. 2018/011 of 11 July 2018 to lay down the Code of Transparency
and Good Governance in the Management of Public Finance in Cameroon, further
states as follows, “Where government decisions, save those falling under defence
secrecy, are likely to have a significant financial impact, the total budgetary impact
amount of such decisions, in revenue and expenditure, shall be made public”.

In May 2020, the Director General of Taxes estimated the cost of tax support
measures at CFAF 114 billion, i.e., CFAF 92 billion from internal revenue and
CFAF 22 billion from customs revenue.

Despite the Audit Bench’s requests, no impact assessment was produced to it.
The urgency of the health situation may, however, explain the government’s swift
decision-making at a time when no one had any real visibility of the health and
economic consequences of the pandemic and when it was necessary to prepare for
the worst-case scenario.

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19.4.2. An a posteriori evaluation carried out at the request of the Audit Bench
Section 7 of Law No. 2018/012 of 11 July 2018, relating to the Fiscal Regime of the State
and other Public Entities provides as follows,  “The budgetary nature and cost of tax
exonerations and waivers shall be presented in detail during the adoption of each
annual budget. An annex finance law shall provide information on such exoneration
and waivers”.

Applying these provisions, the Directorate General of Taxes set up a committee

to study and evaluate the derogatory measures constituting tax expenditure. This
committee produces a “Tax Expenditure Report annually”.

However, the Tax Expenditure Report for the 2020 financial year does not cover the
tax measures taken to support businesses and households as part of the government’s
response to the Coronavirus and its economic and social impacts. In response to the
request of the Audit Bench, the Director General of Taxes emphasised that, “the
evaluation of tax expenditure concerns measures that deviate in a structural and
lasting manner from the general tax scheme. As a result, it excludes in its scope
one-off measures such as those which are the subject of your request. Moreover, as
some measures were renewed in 2021, their evaluation can only be envisaged in
the report to be published in September 2022 and appended to the Finance Law of
2023”.

For the Audit Bench, this interpretation is restrictive and does not meet the
requirements of the law. Accordingly, an Appendix to the Settlement Bill for the
2020 financial law should have presented information on exoneration and waivers
taken in the context of the response to the Coronavirus.

Nevertheless, following the Audit Bench’s request, DGT produced the results of
a study aimed at assessing the impact of the tax expenditure and administrative
measures decided as part of the fight against the pandemic.

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19.4.3. Tax measures under RLAs poorly implemented

19.4.3.1. Lack of monitoring by MINDDEVEL of the implementation of

fiscal measures in RLAs

The implementation of three measures of the government plan is the responsibility

of RLAs, under local taxation8. Section 391 of the General Code of RLAs states
that a local tax is a tax levied by the State’s tax services or the competent services
of the local authority for the latter.

Among the tax measures decided by the Government, local taxes are concerned:
- Exoneration from the discharge tax and from parking fees for taxis and
motorbikes as well as from the axle tax for the 2nd quarter. This measure
could be extended to the rest of 2020;

- Exoneration for the second quarter of 2020 from the discharge tax and
council taxes (market duty, etc.) for petty traders (bayam sellams)

- the postponement of the deadline to pay land taxes for the financial year
to 30 September 2020;

By Correspondence No.°001580/L/MINDDEVEL/SG/DFL/SDFL of 28 May

2020, the Minister of Decentralisation and Local Development sent a letter to all
Mayors to inform them of the implementation of MINFI’s circular specifying the
modalities for applying the fiscal measures to respond to COVID-19.

Nevertheless, MINDDEVEL’s Local Finance Directorate was unable to produce to

the Audit Bench either the “Annual report on local finances” for the 2020 financial
year or the “Statistics on the taxation of local authorities” for the same financial
year, the annual production of which is made compulsory by article 50 of the decree
of 1 August 20199.

This failure on the part of MINDDEVEL to monitor and evaluate RLAs prevents
it from having a global vision of the impact of the special tax relaxation measures
taken by the Government on local finances. On a more general note, it prevents
it from knowing precisely the fiscal resources available to RLAs. It requires

8
Article 391 of RLAs Code states that a local tax is a tax levied by the State’s tax services or the competent services of the
local authority for the latter
9
Article 50 of the decree of 1 August 2019 on the organisation of MINDDEVEL stipulates that the Directorate of Local
Finance is responsible for the “production of the annual report on local finances and the elaboration (...), the keeping of sta-
tistics on the taxation of the Decentralised Territorial Communities”.
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remedial action, given the importance of these issues in the implementation of

decentralization.

Besides, CONAC received complaints from taxpayers regarding certain councils

not applying government measures. When CONAC submitted the matter to
MINDDEVEL no response was given to the taxpayers’ requests.

Recommendation 12 to the Prime Minister, Head of Government

The Audit Bench recommends to the Prime Minister, Head of Government,

to increase the operational capacities of the Local Finance Department of
MINDDEVEL to ensure an effective follow-up of the taxation implemented by
RLAs

19.4.3.2. A very low impact of RLAs fiscal measures due to the lack of
involvement of councils

From the investigations of the Audit Bench in the councils10, the following findings
emerge:

- Councils did not modify their budgets for the 2020 financial year
following the notification to Mayors on 28 May 2020 by Circular
No. 20/169/CF/MINFI/DGI/DLRI/L of 13 May 2020 specifying the
modalities for applying the fiscal response measures to COVID-19,
although the tax exoneration measures recalled above and the payment
of the government’s grant for hygiene and sanitation required them
to prepare and vote on an amending budget. Given that government’s
allocation for hygiene and sanitation was not considered, council
budgets for 2020 were insincere;

- Tax exoneration were not applied on a general basis but on a case-by-case

basis and according to the requests of taxpayers who were aware of the
government measures, which introduced a de facto inequality before the
tax based on the degree of awareness of taxpayers. No council assessed
the loss of tax revenue caused by the relaxation measures imposed by

10
A questionnaire sent to 130 municipalities, and interviews with 4 mayors and 3 secretaries general of municipalities
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the government;

- payment of the final tax at the Tax Revenue Collector and not in
the coffers of council treasurers in violation of the provisions of the
Joint Circular No.0002335/MINADTD/MINFI of 20 October 2010
specifying the modalities of application of Law No. 2009/019 of 15
December 2009 on local taxation.

In conclusion, even if the financial effect of RLAs fiscal measures was not precisely
assessed, the particularly restrictive conditions of their implementation significantly
reduced their macroeconomic impact.

19.4.4. Low impact of tax expenditure estimated between CFAF 2 and 4 billion

In 2020, tax expenditure can be estimated at CFAF 2,080 billion, according to DGT
calculations. This amount is very far from the sum of CFAF 114 billion resulting
from an evaluation made by the same administration in May 2020.

In detail, these are:

- the exoneration from tourist tax in favour of hotel establishments, the

cost of which is estimated at CFAF 324.155 million;

- the exoneration from the discharge tax and parking fees for taxis and
motorbikes for the 2nd quarter of 2020. This measure was not evaluated
due to a lack of data. It concerns micro-enterprises that are not subject
to the annual summary reporting obligation;

- Exoneration from axle tax for motor vehicles with a payload of at least
3 tones for the second quarter of 2020, the cost of which is estimated at
CFAF 805.9 million;

- the exoneration from the discharge tax and council taxes for petty traders
in the second half of 2020. This measure was not evaluated due to a lack
of data. It concerns micro-enterprises that are not subject to the annual
summary reporting obligation;

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table XIII. Estimated tax expenditure by tax type

(2020 financial year)
Taxes Rating Part
Tax Not rated 0%
Axle tax 805,900,000 38.70%
Parking fee Not rated 0%
Tourist tax 324,155,938 15.60%
Registration fees 950,000,000 45.70%
Council tax Not rated 0%
Total 2,080,055,938 100.00%
Source: DGT

It is unlikely that the unassessed part of the tax expenditure will be substantially
higher than the assessed part. In other words, the tax expenditure can be estimated
with a high degree of certainty as between CFAF 2 and 4 billion, which remains a
very modest amount.

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GENERAL CONCLUSION

Three major findings emerge from this second report on the expenditure
incurred by 20 ministries in the 2020 financial year to respond to the
COVID-19 pandemic.
1°- The bulk of SAA expenditure in 2020, for FCFA 132.883 billion, was
incurred by three ministries (MINSANTE, MINRESI and MINFI) which
were the subject of the first report of the Audit Bench. Expenditure by the
other 20 ministries, which is the subject of this report, is estimated at CFAF
8.512 billion (CFAF 10.799 billion, including the ministries’ own budget
expenditure), which is modest. In reality, this expenditure was incurred only
by four ministries, while 16 other audited ministries incurred no expenditure
in 2020. This is due to strong inertia in implementing urgent measures
explicitly linked to poor information systems and procedures or to the
choice of favouring external financing from public entities or international
organisations rather than from SAA. In conclusion, these 20 ministries were
in the second line of the response to the pandemic.
2°- Tax expenditure was also very low in 2020, between CFAF 2 and 4
billion, far from the initial forecast of CFAF 114 billion.
3°- Changing the rules to attach the expenditure of the 2020 financial year
to the first six months of 2021 had no legal basis or accounting justification.
This undermined the principle of budgetary annuality and compromised
the transparency and accountability underpinning Special Appropriation
Accounts.
Once again, the Audit Bench had to recalculate the expenditure allocated to
this account for the 2020 financial year. Given the difficulty experienced by
MINFI in ensuring that the accounts are monitored following the regulations
in force, the question of maintaining this Special Appropriation Account
deserves to be raised.
The Audit Bench:
- makes twelve (12) recommendations
- decides to initiate one (1) proceeding for management errors.

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Appendix: LIST OF PEOPLE MET

I. CENTRAL AND DEVOLVED SERVICES

N° NAME AND SURNAME FUNCTION

GENERAL DELEGATION OF NATIONAL SECURITY
1 AMOUGUI ATANGANA Elie Serge Deputy Director of Financial Affairs 
2 NNOMOKO née CD BILOUNGA Deputy Director of Health
MINISTRY OF BASIC EDUCATION
3 DOKO EDJIANE Mathieu Alain Director of Financial and Material Resources,
Focal Point
4 BENE Thérèse SDB
5 TSANGA Jean Blaise Regional Delegate, Centre
6 YMGA DJAMEN Léopold Regional Delegate, Littoral
7 BELINGA Gilbert Regional Delegate, South
8 NTAMAK Georgette Regional Delegate, Littoral
9 DJIBRILLA GARGA Regional Delegate, West
10 MBOPI Prosper Patrice Store accountant
11 SIDA L. A. née ETOUNDI NANGA Divisional Delegate, Ocean
12 ABESSOLO NTOUTOU Emmanuel Divisional Delegate, Mvila
13 OTTOU TSALA Marie G. Divisional Delegate, Mfoundi
14 NKOLO Jean-Baptiste Divisional Delegate, Mbam and Inoubou
15 OWONA MESSI Clément Janvier Divisional Delegate, Mbam and Kim
16 NGUELE In Oubou Henri Divisional Delegate, Nyong and So’o
17 NDONG Angéline née ZAMBO Divisional Delegate, Mefou and Akono
18 BIDJO Benjamin Débonnaire Divisional Delegate, Mefou and Afamba
19 EWOLO MBEL Alain B. Divisional Delegate, Haute Sanaga
20 ADAMOU MAÏGARY Divisional Delegate, Vina
21 TASSI TSALA Jeanne Divisional Delegate, Lékié
22 ESSONO Louis-Marie Divisional Delegate, Nyong and Mfoumou
23 EBO’O MVE Headteacher, Eba’a Public School
24 BIBI ATANGANA Headteacher, Ahala Public School
25 NOUMI Ayala Rameline Headteacher, Mballa II Public School
26 ABOMO EDDA Ursule Headmistress, Djoum Public School
27 ONGBWA EKOE Headteacher, Sangmélima Public School, Group
2
28 MVELE NKOUMOU Eloge Yves Headteacher, Kpwe Public School
29 AMOUGOU Alain Joël Headteacher, Ahala Public School
30 OWONA Kwa Zakarie Headteacher, Metet Centre Public School
MINISTRY OF HIGHER EDUCATION
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
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University of Douala
31 Prof. ONDOA Magloire Rector
32 Prof. Fidoline NGO NONGA Director of Infrastructure, Planning and Devel-
opment
University of Dschang
33 Prof. Jean NJOYA Vice-Rector (VREPDTIC)
34 ATANGANA Edmond DAAF/UDS
35 Prof. NJAPGUE François P-SIGAMP/UDS
36 Dr TCHABO SONTANG Hervé M. C/ DAAPA
37 AZANGUE Sidoine Member of SIGAMP
38 Dr LEKEFACK Bonaventure Member of SIGAMP
39 NJIPTA née DJOUMETE Annie R-SIGAMP
University of Maroua
40 Prof. IDRISSOU ALIOUM Rector
41 Prof. GONNE Bernard VRCIE
42 Prof. BOUBA KIDAKOU C.T.
43 Prof. KIOMO KAOGA DIEM/UMa
44 Dr EMEGUEU YOUMBI C/CMS
University of Ngaoundere
45 Prof. FLORENCE UPHIE CHIN- Rector
JE MELO
46 NDONGO Jean Alex Head of the Construction and Equipment Depart-
ment
47 ABAKAR ABRAHAM Accounting Officer
The University of Yaounde I

48 Prof. OWONO Uma Luc C. Vice-Rector

University of Yaounde II - Soa
49 Prof. MACHIKOU Vice-Rector
50 AKEM ZILLI Claude Aristide Accounting Officer
MINISTRY OF TRADE
51 Prof. OMBALLA MAGELAN Focal Point
MINISTRY OF ECONOMY, PLANNING AND REGIONAL DEVELOPMENT
52 FOHOPA KUE Remon Head of Macroeconomic Synthesis Unit

53 NJOH Michelin Coordinator of the Social Safety Net Project

54 BIYICK NDEPPE Jean Claude Targeting officer
55 NTOUBA NGOH Charly Targeting officer
56 Henry Victor LOE TAMGA Targeting officer
57 MBELLA Georges Kevin Targeting officer
58 AGATHA Judicaëlle BONNY Targeting officer
59 NGAN MBODY Louis Jordan Targeting officer
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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
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60 Jocelyn Wilfried MBOUMOUA Targeting officer

MOBE
61 OTELE ALIMA Peter John Targeting officer
62 MAGNE FOMET Anastasie Targeting officer
63 DIBOULE NDEME Charles Deni Targeting officer
64 ZE NTIMA Elvire Targeting officer
65 BISSA NKALE Dany Targeting officer
66 NTENGAM ABILOU Targeting officer
67 KANE Gilles Targeting officer
68 MVONDO Thomas Targeting officer
69 DJUIDJE SOOPTEOOA Ernestine Targeting officer
70 KPWANG EYINGA Alphonse Targeting officer
71 AVOZO’O ANGO Jacques Mérimé Targeting officer
72 KAKA NGOH Marie Targeting officer
73 FONWE TAGUEU Targeting officer
74 KENFACK AZAMO Targeting officer
75 WEMBE Samuel Targeting officer
76 SIMO Patrick Targeting officer
77 TADJUIDJE Jean Paul Targeting officer
78 TCHUENDEM YOUMSI Hélène Targeting officer
79 TAGNE Chamberlin Targeting officer
80 WETCHUENT EGAMNAN Targeting officer
Chanceline
MINISTRY OF TOURISM AND LEISURE
81 HAMADOU ABBO, Director of General Affairs, COVID-19 Focal
Point
82 OUMAROU SANDA ABOUBA- Regional Delegate of Tourism for the Adamawa
KAR
83 NASSERHAMADAMA Regional Delegate of Tourism for the East
84 KODJI DELI Regional Delegate of Tourism for the Far North
85 MBOUA Jacques Regional Delegate of Tourism for the Littoral
86 SAKINATOU SAMIRA Regional Delegate of Tourism for the North
87 NGOUPAYOU née ADIDJA NGOU- Regional Delegate of Tourism for the West
TANE
88 Regional Delegate of Tourism for the Adamaoua

EKOUA FANY
89 MBANLE BAKARY Head of the Budget and Material Department of
MINTOUL
90 TCHANGOU DEMANGA Ludovic Head of Public Contracts, MINTOUL
91 MONEZE Ernestine Store accountant, MINTOUL
MINISTRY OF SECONDARY EDUCATION

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
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92 Prof. NKOA Pierre Director of Financial and Material Resources,

Focal Point
93 FAOUSIATOU Computer science teacher at the Government Bilin-
gual High School of Domayo
Regional Delegation of Adamaoua
94 ASSANA MATHIAS Regional delegate

95 NTYAN AFANE JEAN JOEL Head of Equipment

96 RAMANI PIERRE Head of Budget Department

97 APOUAMOUN JEAN JACQUES Dean of Studies at the Government Bilingual High

School of Malang

98 LANGSI MILYCENT née Vice Principal, the Government Bilingual High

KUGAHME School of Malang

99 SOUADATOU MOHAMADOU Discipline master at the Government High School of

Ngaoundéré Mardock

Regional Delegation of East

100 BEDJABO SIMPLICE Regional delegate

101 MINYEM NARCISSE Head of the School Equipment, Infrastructure and

Materials Department

102 ENGUENE MARIE Store accountant

103 EBANGA SAMUEL Principal

104 KOULBOUT REINE Principal

105 SANDA DIM Representative of the Service Provider

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences
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106 DERENG MOUENGUI Principal at the Government Bilingual High School

of Bonis

107 MOHAMED AZIZ Discipline master at the Government Bilingual High

School of de Bonis

Regional Delegation, Far North

108 WANGBOUSSOUM PIERRE Regional delegate

109 YOUALISSAM Headmaster of the Government Bilingual High

School of Domayo

110 FAOUSIATOU Computer Science Teacher, the Government Bilin-

gual High School of Domayo

Regional Delegation of North

111 SAIDOU née HADJIDJATOU SAD- Regional delegate
JO

112 AMADOU HAMAN Principal at the Government Bilingual High School

of Garoua

113 MOHAMADOU née AISSATOU Dean of studies at the Government Bilingual High
YAOUBA School of Garoua

114 DANGUE RICHARD Dean of studies at the Government Bilingual High

School of Kollere

MINISTRY OF STATE PROPERTY, SURVEYS AND LAND TENURE

Divisional Delegate, Bertoua
115 NKPWATT JEAN CLAUDE Divisional Delegate

116 TCHAMBA MBIYA MICHAEL Head of the Heritage Department

MINISTRY OF YOUTH AFFAIRS AND CIVIC EDUCATION

117 TERRESTRA NANG Jacques Ad- Regional Delegate, Littoral
elain

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118 SALI BEDI Subdivisional Delegate, Douala 1

119 WAFO Joséphine Subdivisional Delegate, Douala 2
120 TCHUEN Nicole Subdivisional Delegate, Douala 3
121 TCHENGANG Olive Head of the General Affairs Department at the
Regional Delegation of West
122 KENENC TAWAMBA Albert Head of the Department of Civic Education and
National Integration in the West
123 EBINEBENYE Marie-Cécile Subdivisional Delegate, Bafoussam I
124 MATOU Mévéline Subdivisional Delegate, Bafoussam II
125 FANGUE NZEUGAH Hubert Subdivisional Delegate, Bafoussam III
126 METTOU Marie Annick épse EYA Regional Delegate, South
127 MBAZOA Georges Subdivisional Delegate, Ebolowa II
128 MELI Arnaud Ghislain Subdivisional Delegate, Ebolowa I
MINISTRY OF DECENTRALISATION AND LOCAL DEVELOPMENT
129 ANTIBE Alain Michel Director of General Affairs, Focal Point
130 MVOGO Alain Thierry Deputy Director of Local Taxation
MINISTRY OF MINES, INDUSTRY AND TECHNOLOGICAL DEVELOPMENT
131 ZEMBES Olivier Head of Department
132 IPODA Sylvio Executive of the Production Directorate, Focal
Point
MINISTRY OF AGRICULTURE AND RURAL DEVELOPMENT
133 FOUDAMA Focal Point 
134 Pélitique MEGUERE Store accountant 
MINISTRY OF LIVESTOCK, FISHERIES AND ANIMAL INDUSTRIES
135 Dr TAÏGA Minister
136 BESSONG Laura EGBE Focal Point 
137 Dr ERAYAVAI BOUBA FRAN- Regional delegate
COISE

138 Dr Abel WADE General Manager LANAVET

139 Dr ABDOU MAHAMAT Production Manager LANAVET

140 DICKSON JUMBO S. Deputy Production Manager LANAVET

141 POUEME NAMEGNI RODRIQUE Deputy Production Manager LANAVET

MINISTRY OF SOCIAL AFFAIRS

142 AMBE AGELICA DPPHPA
143 BALOG Politiquera Joseph C. DAG
144 SANDJOK Annie P S/D

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145 ANDA ABANG Christian C. C/SMP

146 DONGMO Augustin CM/CAB
147 BEFOMBO Théophile Executive worker

MINISTRY OF WOMEN’S EMPOWERMENT AND THE FAMIILY

148 NDZANA BILOA Alain Sym- Director of General Affairs, Focal Point
phorien

MINISTRY OF TRANSPORT
149 BIKANDA Eric Benoît Director of General Affairs
MINISTRY OF FINANCE
DIRECTORATE GENERAL OF TAXES
150 EBOUNE Bertrand Head of the Legislation Unit
151 AMADOU MOHAMAN Head of the Legal Division
152 MBUWIR TAANKAR Head of the Taxes Refund and restitution unit
CRRIT)
153 MENGUELE Jean Paul Director of the DGE
154 EVINA EYA Tax Revenue Collector, DGE
155 WARA MBOG Jean Herbert Power of Attorney No. 1 DGE
156 DJAMEL Olivier Tax Revenue Collector CIME / Bonanjo
DIRECTORATE GENERAL OF THE TREASURY, FINANCIAL AND MONETARY CO-
OPERATION
157 MBAZOA Alice Pancrace Special Paymaster of the COVID-19 SAA
158 Dr SOROK A BOL Patrick Gérard Authorized Agent No. 1

Central Treasury of Maroua 1

159 MOUSTAPHA GARGA Treasurer Paymaster General, Maroua 2

DIRECTORATE GENERAL OF THE BUDGET

160 EDOU ALO’O CYRILLE Director-General of the Budget
161 TABENYANG née Augusta NJOCK Head of the Budgetary Control, Audit and Qual-
ARREY ity of Expenditure Division, Financial Controller
of the Lean Circuit
MINISTRY OF PUBLIC WORKS
Regional Delegation of Far North
162 WASSAH ALBERT Deputy Director of Roads

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OFFICIALS OF REGIONAL AND LOCAL AUTHORITIES

N NAMES AND SURNAMES FUNCTION LOCAL AUTHORITIES

163 LENGUE MALAPA Mayor Douala 1
164 NDEFONKOU Daniel Mayor Bafoussam 3
165 MFEUNGWANG Richard Mayor Douala 5
166 MAPTUE FOTSO Mayor Bandjoun
167 NGO BIEND Perpétue Secretary General Bafoussam 1
168 NGASSOP FAMMEGNE Secretary General Bayangam
169 JIOF Edouard Secretary General Njombe-Pendja

III. COMPANY MANAGERS

N NAMES AND SURNAMES FUNCTION INSTITUTION

170 AMOBE Janvier Customer Service Of- SESAME SARL
ficer
171 KENFACK Robert General Manager TRANSATOU SARL
172 Alexandre DAVOULT DAF CIFM Sarl / PALLISCO Sarl

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Audit of the Special National Solidarity Fund for the Fight against Coronavirus and its Socio-economic Consequences