Nigeria Extent and Quality of Labour Stakeholder Consulta­tion and Input During NAP BHR Development The NAP BHR for Nigeria is contained in chapter eight of the broader NAP for the Promotion and Protection of Hu­man Rights in Nigeria(2024–2028). 45 It has been developed to deepen the promotion and protection of human rights following the expiration of an earlier NAP BHR on the Pro­motion and Protection of Human Rights in 2013. The gen ­eral NAP BHR was developed in response to human rights violations and abuses that occurred in Nigeria, especially in the‘90s. The National Human Rights Commission led con ­sultations between ministries, departments, agencies, and civil society groups to review the implementation of the previous NAP BHR on human rights and document lessons learnt. The development of the NAP for the Promotion and Pro­tection of Human Rights in Nigeria and, by extension, the NAP BHR was led by a steering committee and a coordi­nating committee. However, there is no evidence of organ­ised labour representation on these committees for the de­velopment of the NAP BHR. Neither is there any compel­ling evidence of attempts to consult with organised labour to obtain their inputs on the contents of the NAP BHR. However, in an interview with a trade unionist from Nigeria, he stated that the Petroleum Sector Union(NUPENG) and Aviation Sector Union(NUATE) participated in developing the NAP BHR for Nigeria. 46 In addition to this, due to the circumstances surrounding the development of the NAP BHR, there was no national baseline assessment of BHR conducted before the NAP BHR was developed. Thus, we assess the extent of labour stakeholder consultation in the development of the NAP BHR as low . Extent and Quality of Gender Stakeholder Consulta­tion and Input During NAP BHR Development There was no mention of women workers being consulted for the NAP BHR. This is partly because of the NAP BHR not being a stand-alone plan. The consultations that took place were therefore not very specific to BHR in our esti­mation. We therefore conclude that the extent of gender involve­ment in the development of the NAP BHR is also low . Substantive Responsiveness of NAP BHR Content to Labour Rights Deficits and Challenges Since there is no concrete evidence of labour’s active in­volvement in the consultations and development of the NAP BHR, we infer that the influence of labour on the con­tents of the NAP BHR is minimalat best. However, the NAP BHR did identify a number of challeng­es relative to labour, including: → the casualisation of employment, especially in the oil and gas sector, as well as the telecommunications, banking, and financial services sectors; → contradictions in the provisions of the Nigerian Labour Act about freedom from discrimination on the basis of sex at the place of employment; as provided by Section 42 of the Nigerian Constitution; → the cost of litigation as a major impediment to access to remedies for victims of business human rights abuses; → the enforcement of the judgement of the court for suc­cessful litigants in labour rights matters; → the ratification of ILO Convention 176(Safety and Health in Mines 1995); → challenges regarding freedom of association under the Trade Union(Amendment) Act 2005; → the limitation of the Freedom of Information Act 2011 to only public institutions, including a lack of whistleblow­er protection law; → a lack of adequate human rights, conflict, and environ­mental impact assessment when land is being acquired for development or business purposes; → a lack of effective, transparent, and sustainable griev­ance mechanisms for businesses to address conflicts with communities, including the documenting and re­porting of activities of settlement; → businesses not taking the Local Content Act 2010 into consideration in their employment process; → certain laws on business and employment being obso­lete and not aligned with international standards; → a lack of inclusive security coverage for every entity in the business value chain, including business facilities, employees, suppliers, contractors, infrastructure, and the community; → a lack of a realistic, implementable BHR reporting mechanism for businesses to report on their BHR situa­tion; and 45 See the National Action Plan for the Promotion and Protection of Human Rights in Nigeria(2024–2028), available at https://www.nigeriarights.gov.ng/activities/nap/458­national-action-plan-for-the-promotion-and-protection-of-human-rights-2024-2028.html. 46 All the five except one of the labour union representatives that the research team contacted were unwilling to grant interviews on the Nigerian NAP BHR. 24 Friedrich-Ebert-Stiftung e.V.