A Governance Framework for Procurement Policy Reform after Forensic Investigations in Nigerian Energy Companies

Abstract

A procurement investigation identifies weaknesses, but policy adoption does not establish whether those weaknesses have been corrected. This paper develops a conceptual process governance framework for Nigerian energy companies responding to vendor collusion and theft. A purposive synthesis of internal control, decision governance, fraud risk, and procurement literature informs the design. Each supported finding connects to a failure mechanism, a control owner, an operating rule, required evidence, and independent verification. The framework covers supplier onboarding, sourcing, evaluation, receipt certification, payment, emergency exceptions, and corrective action closure. A feedback model specifies when failed verification should return an action for redesign or further implementation. Defined measures assess control operation alongside approval time and supplier participation. A phased pilot and a comparative evaluation protocol support later testing using authorized organizational records. The paper develops propositions concerning the relevance of controls, closure discipline, and documented emergency purchasing. Its contribution is a method for converting investigative evidence into accountable process changes, with closure based on demonstrated operation rather than the announcement of a revised policy.