Campaign governance

1. Decision-making structure

The campaign is governed by:

• The Authorising Principal - Peter Gregory Obi, CON. Final decision-maker on all matters of policy, candidacy, and personnel.
• The Campaign Director-General - chief executive of the campaign secretariat, responsible for day-to-day operations, budget execution, and external coordination.
• The Finance Committee - a committee of three (3) - the Director of Finance, the Compliance Officer, and an independent member nominated by the Authorising Principal - which approves all disbursements above the internal control threshold.
• The Compliance Office - independent of operations, responsible for AML/CFT, sanctions, INEC, NDPC, and any other regulatory interface.
• The Audit Committee - a committee of three (3), including at least one independent non-executive member, that supervises the relationship with the external auditor.

2. Conflict-of-interest register

Every member of the campaign secretariat - and the Authorising Principal - completes a conflict-of-interest declaration on appointment, refreshed annually and on any change of circumstances. Declared conflicts are published in summary form in this Section. The full register is held by the Compliance Office.

Where a member declares a conflict in respect of a specific matter, that member recuses from any decision on that matter. Recusals are recorded in the minutes of the relevant decision and reported in the quarterly transparency report.

3. Whistleblowing

We operate an independent whistleblowing channel for any person - employee, volunteer, donor, supplier, or member of the public - who has reasonable grounds to suspect:

• Financial misconduct, fraud, or theft;
• Bribery, corruption, or improper influence;
• Breach of the Electoral Act 2022 or any other applicable law;
• Breach of these published policies;
• Threats to the safety of any person.

Reports may be sent confidentially to contact@peterobi.supportwith “Whistleblowing” in the subject line. We adopt the framework of the Whistleblower Protection Policy announced by the Ministry of Finance and provide protection against retaliation to the maximum extent permitted by law.

4. Vendor management

All vendors above an internal threshold are onboarded through a documented procurement process that includes:

1. A written scope of work;
2. Three-bid comparison where reasonably available;
3. KYC on the vendor and its beneficial owners;
4. Sanctions screening on the vendor and its beneficial owners;
5. A signed contract with confidentiality, anti-bribery, and audit-rights provisions;
6. Approval by the Finance Committee.

5. Anti-bribery and anti-corruption

The Campaign maintains a written anti-bribery and anti-corruption policy compliant with the Corrupt Practices and Other Related Offences Act 2000, the Money Laundering (Prevention and Prohibition) Act 2022, and international standards including the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act. The policy is provided to every employee, volunteer, and vendor and is available on request.

6. Record-keeping and audit access

Campaign records are retained for the periods required by law and the longer of: (a) seven (7) years from the close of the financial year; (b) any period required by INEC, the EFCC, the NFIU, or another competent authority. The Compliance Office, the Audit Committee, the external auditor, and any regulator with statutory power are entitled to full and unrestricted access to all campaign records.

7. Changes

Material changes to the governance structure or any policy referenced in this Section are disclosed in the quarterly transparency report.