Sopuruchi Onwuka
The recent fire explosion at an illegal refinery near oilfields in Imo State which claimed over 100 youths illustrate the scale of havoc criminal enterprises wreak on the Nigerian petroleum industry and the implicit plague on the Nigerian economy.
In one fiery incident, which currently forms a graphic and gory index of what obtains in the vast number of Illegal refinery sites in the Niger Delta, over a hundred able bodied youths of prime production status were burnt to death; vehicles and other logistics equipment worth several millions of Naira were also razed; a patch of lush green rain forest was blighted in flash of blistering blast; huge volumes premium crude oil grades worth millions of dollars were flared; and billions of dollars worth of oil and gas exploration and production investments were put at risk.
The refinery fire which drew a spate of public outcry on the worsening security and safety situation in the beleaguered Imo State is actually a regional menace that has become endemic in oil industry host communities in the Niger Delta.
From remote oil and gas installations and flow conduits straddling oil producing communities in the Niger Delta to export trunklines that connect flowstations to terminals, criminal syndicates have taken highly entrenched vantage positions from which they rob the industry of hard earned investment rewards.
The incident which falls into pattern with the parasitic bond of criminal enterprises to the nation’s petroleum industry loudly amplifies the call for cross tier national response to crude oil stealing and associated threats to national economy, industry security, human and environmental safety.
Coordinated national response becomes necessary following visible resilience of criminality against the industry. Since 1999 when Nigeria returned to civilian rule, the petroleum sector has contended with rising cases of vandalism on industry facilities and infrastructure, growing volumes of production losses, worsening disruption on industry operations, and ever increasing value destruction.
The crude stealing operations which evolved from environmental and resource control agitations have not only taken large human tolls, devastate the environment and inflict commercial losses on legitimate commercial investments by licensed operators; it has subsequently spawned the sprawling illegal refining enterprise in the region.
The real cost of oil theft
Loss of lives
The combined activities of oil theft and artisanal refining have are delivering numerous blows on the lives of the people, the environment, petroleum industry, and the country’s economy.
Total cost that comes with petroleum pipeline bursts and associated oil spills, fire blasts, environmental degradation and human tragedy in Nigeria are difficult to calculate.
In the downstream industry, pipeline fire sparked by oil thieves has in innumerable incidents consumed tens of thousands of people who either participated in stealing or ignorantly chanced on free fuel at spill sites created by vandals.
Since the phenomenal 1998 Jesse oil fire tragedy in Delta State which consumed estimated 1086 people within 12 hours, it has been difficult to count the human toll of mishaps arising from desire for free oil in the country. Although the Jesse oil fire did not result from pipeline hacking or truck hijack, it amplifies the common tendency among Nigerians to scramble for free fuel.
It is difficult to count any state of the federation that hosts part of the government’s 5001 kilometers of fuel distribution pipeline which is yet to record a pipeline blast associated with oil theft.
In Lagos and Ogun States which host facilities in the System 2B section of the pipeline, tens of thousands of Nigerians have been carelessly dispatched early graves in countless pipeline explosions that periodically announce product stealing operations.
From micro islands that host the lines from Atlas Cove, through the marshy wetlands that camouflage the right of ways and thick neighborhoods where builders encroach on pipeline routes, it has been blasts, blasts, blasts! And each of them claims invaluable lives and property.
Vandalism across the full length of the distribution pipelines connecting the nations, three refineries, import jetties and storage depots has disabled the 5001 kilometers of distribution infrastructure; limiting the downstream fuel distribution operations to trucking, an inefficient process that has proved vulnerable to road mishaps, spills and losses.
In the upstream petroleum industry, crude oil theft has taken more human lives than all known disasters combined together. From wellheads to pipelines, barges and distillation pots, explosions have kept depleting crews. The crime activities are not regulated and incidents are not reported, workers are never accounted for. Ignorant workers are kept in slave conditions in forests where they periodically meet their sad fate like those in Imo State.
Environmental impact
Secondly, the petroleum industry takes significant environmental responsibility. But the crime side of the industry is not under obligation to curb the footprints on the environment.
Whereas the regulated side of the industry invests in management of wastes, prevention of environmental impacts and guarantee of healthy habitat for flora and fauna; industry bandits are typically ill-equipped, brisk in stealing and totally irresponsible for any fallout from their actions.
Whereas crude oil theft appears to cause more spills that pollute groundwater, rivers, mangrove forests and marshy wetland; artisanal refining combine all forms of environmental degradation and constitute very grave health risk to the environment and people of the host communities.
Their raw distillation activities cause heavy air pollution and account for huge concentration of carbon monoxide that forms sooth in the atmosphere and inflict residents with health challenges including cough and lung infections that have become prevalent in Niger Delta.
From water pollution to air pollution, wetland and forest devastation, crude oil stealing and illegal refining activities have continued to deeply degrade the environment beyond imagination.
Commercial losses
The loss impact of crude oil and condensate theft on the commercial operations of exploration and production companies is colossal. Rising operating cost, massive production losses, protracted downtime on incidents, cost of repairs and numerous other components prune down margins and create accounting gaps.
Since early 2000s the upstream petroleum operations have coped with derailing work programmes, stalled growth and dwindling operating margins as their production facilities increasingly fall under attack from pipeline hackers that steal crude oil.
Although cases of sheer vandalism have been reported where the lines are just blown up with explosives to register agitation or create local community contracts, resulting in spillages and environmental hazard. However, the key threat to the industry remains massive production theft.
Industry production pipelines, according to incident reports filed to regulators, suffered frequent and so numerous breaches that “on a stretch of 20kilometers pipeline, there were 85 insertion points in three weeks!”
Inspection of damages to pipelines showed that thieves with different levels of skill and capacity are all involved in the fray, reflecting in the size of pipes and level of technical skills used in installing drain pipes on the production pipelines.
Industry incident reports show that whereas some thieves would hurriedly install small pipes that indicate use of low volume barges, others would install large capacity pipes that literally form a proportionate branch out from the original pipeline, indicating large scale thefts that clearly divert capacity production to illegal export vessels.
The industrial scale thieves are also reported to operate with sophisticated equipment and cutting-edge technology, indicating employment of efficient industry professionals and deployment of heavy industry equipment like cranes. The large scale thieves, operating companies lament, pose serious threat to the fate of the industry.
Investor groups have consistently expressed frustration with security situation in the environment where, according to them, security breaches and third party incursions have hampered operations and caused companies huge operating losses.
Nigerian National Petroleum Company Limited stated in operating report that pipeline vandalism associated with stealing for export and illegal refining led to the shutdown of eight oil terminals in the second quarter of 2021.
According to the report, Forcados, Bonny, Odudu, Brass, Yoho, Erha, Ajapa and Aje were shut between August and October, 2021, leading to losses and deferred crude oil production valued at about N556 billion.
According to NPPC, the industry lost production of 4.83 million barrels Mbbls of oil in October, 6.7 Mbbls in September, and 6.4 Mbbls in August of that year.
In its report for the same year, Shell whose onshore assets are exposed and vulnerable to attacks stated that 92 percent of oil spills in its operations were caused by sabotage and oil theft, adding that the incidents have formed a consistent pattern similar to previous years.
The company stated that sabotage incidents often occur in remote areas of the Niger Delta where access is difficult.
In condemning illegal activities that affect its operations, Shell pointed at attacks and breaches of its pipelines and well heads.
On pan-industry scale, losses inflicted on legitimate operations are complex and too complicated to estimate.
Mallam Kyari said production losses at key industry export facilities became so massive that business calculations could no longer justify continued operations under sustained loss conditions. The situation, he explained, forced some operators to shut-in some oilfields and shut down some compromised facilities.
He said some major crude export conduits including the Trans-Niger Pipeline and the Nembe Creek Trunk Line that carry production from onshore oilfields to export terminals started with losing 19,000 bpd until the rate of loss reached over 98 percent of production put through them to the export terminals.
The two trunk lines serve as main export channels from numerous onshore oilfields in Rivers, Abia, Imo and Bayelsa States to the coastal terminals where crude oil is loaded into oceangoing tankers.
According to Mllam Kyari, only 3000 barrels of crude oil per day (bpd) out of 239,000 barrels of production reached the terminals through the Nembe Creek Trunk line at a period in 2021, explaining that the rate of oil theft kept increasing as the price of crude oil was rising in the market until March 2022 when there was zero recovery from all the volumes that was pumped into the line.
“It was no longer economically sustainable to pump crude into the lines and a force majeure was declared,” a report from NNPC Limited stated.
The scale of commodity stealing in the Nigerian operating environment also explains the massive divestments and capital exportation by multinational energy firms that form traditional investors in the petroleum industry.
Currently, government’s traditional partners and frontline investors that built the Nigerian petroleum industry including Shell, Total, Eni, ExxonMobil and Chevron are rapidly recovering their investments in onshore petroleum asset. The slew of divestments which started in with the onset of industrial scale oil theft in the Niger Delta has morphed into a coordinated movement out of joint venture arrangements.
Nigeria’s biggest joint venture operators, comprising Shell and ExxonMobil, are in the market to sell local affiliates that hold their interests in the ventures. Sell of SPDC would also entail divestment of interests held by partners, including Total and Eni. Chevron is driving a separate divestment of its JV assets.
All the companies have cited security breaches and associated operational losses as key reasons for giving up the businesses.
Whereas the JV packages would eventually be acquired and operated by new investors, the deals would put serious strain on the domestic financial market where foreign exchange funding capacity is very low. The divestments would also entail massive capital exportation from the domestic economy which is currently suffering acute forex liquidity crunch.
Economic impact
According to Mallam Mele Kyari, the combination of crude oil theft, illegal refining and pipeline vandalism has hindered efforts at meeting government’s revenue projections in recent times.
Illegal refining in Nigeria which thrives on brazen stealing of crude oil and condensate pointedly explains the prevailing paradox of Nigeria’s acute foreign exchange scarcity and wider fiscal despair at a time of strong oil prices at the international market.
The illegal enterprise forms the lower arm of more disturbing activities of commodity raiders who steal the proceeds of licensed operating companies, and hijack equity commodity and tax revenues that should ordinarily flow into the nation’s coffers.
Thus, their activities render the domestic operating environment unattractive, deny the country industry contributions to the gross domestic product (GDP) and also drain revenues that fund government’s fiscal spending.
The Oracle Today reports that crude oil and natural gas exports account for over 50 percent of the nation’s total funding support to government’s annual budgets, over 90 percent of the country’s balance of payments and over 80 percent of total commodity export.
The petroleum industry is also responsible some 75 percent of Nigeria’s total foreign exchange revenue, over 60 percent of national capital importation and nearly 35 percent of GDP.
The Nigerian Content Development and Monitoring Board (NCDMB) recently put the local value retention from the industry at over 22 percent, indicating the sector’s rising contribution to the country’s GDP.
The central role of the petroleum industry in the nation’s economic performance heavily depends on the fortunes of the commodity in the international market. Thus, strong prices and volumes of output are central to health of Nigeria’s domestic economy and wellbeing of her citizens.
Like other oil dependent economies of the world, including members of the Organization of Petroleum Exporting Countries (OPEC) and participating coalition members, Nigeria’s economic performance has fluctuated with export prices of crude oil and natural gas in the international market.
Since 2016, Nigeria’s economy has slid into and out of depression in line with price fluctuation in the oil market.
Low revenue returns from the oil market in 2016 and 2020 respectively had translated to acute foreign exchange deficits, mounted pressure on the exchange rate for the Naira and triggered inflationary jumps in the country which relies heavily on imported commodities.
Low oil revenue flow had compelled government to embark on massive borrowing since 2016 and more borrowing since 2020 when oil prices plunged below cost of production following demand destruction inflicted by global lockdowns against covid-19 pandemic. The nation’s worsening debt crisis has sparked a spate of public outcry and triggered warnings from the World Bank, the International Monetary Fund (IMF) and other multilateral lending institutions. It has also dented Nigeria’s credit rating with international financial advisories.
Expectations that rising oil and gas prices propelled by Russian invasion of Ukraine would bail Nigeria from worsening debt crisis and help government curb inflationary trends are currently dashed as the players in the petroleum industry helplessly watch thieving syndicates drain output from production facilities.
So, despite the high prices of oil Nigeria has failed to muster the volumes of output required to optimize the price opportunities in the market place.
Official records show that pipeline vandalism, oil theft and illegal refining accounted for Nigeria’s inability to meet its 1.5 mb/d production quota with the Organization of Petroleum Exporting Countries (OPEC).
The country has unfortunately become an output laggard in OPEC where it had earlier maintained strong production status and contested for bigger production quota.
With the world calling for more OPEC oil and Russia comes under sanctions for invading Ukraine, it is clear that Nigeria will not be able respond to the opportunity to grab greater market share as global supply dynamic begin to alter.
The NNPC says that over 12 percent of the nation’s crude oil production, translating to over 300,000 physical barrels per day (bpd) stolen!
The national oil company stated in its operating report that the country’s crude oil production has dropped to an all-time low of 1.29 mbd from the 2020 benchmark production average of 2.49 mbd. Condensate production has also dropped from signature benchmark of 600,000 barrels per day to about 200,000 barrels per day.
These numbers form the basis for revenues, taxes and sundry payments that play critical roles in financing government’s fiscal projections and stimulating growth in the domestic economy.
NNPC puts the total volume of crude oil stolen is 2021 at 200,000 per day. At an average price of $55 per barrel, the total loss came was about $4.02 bn.
As at April, 2022, NNPC estimates that the powerful syndicates stole significant 250,000 barrels per day putting the total loss so far in the year at about $1.5 billion.
The Oracle Today reports that the volume of crude oil declared stolen by the NNPC Limited is greater than the total production of some designated oil producing countries in the world. Most of the countries with total production capacity for 250,000 b/d are actually exporters.
The scale of assault
The rising number of production facility breaches and geographical spread of illegal refining sites reflect the scale of hemorrhage inflicted on the industry by criminal parasites.
Currently, Nigeria presents perhaps the worst case of oil stealing activities and also has the most widespread activities of illegal oil refining worldwide. Other countries also suffering oil theft, including Mexico and Colombia, deal with small scale losses and occasional incursions.
The number of illegal refineries has proved difficult to determine as new ones are rapidly established at new sites each time security agencies demolish and dismantle discovered ones.
Minister of State for Petroleum Resources, Chief Timipre Sylva, who led high ranking government officials to inspect demolished illegal refinery sites in the Niger Delta had declared that 128 of discovered 142 illegal refineries had been demolished.
Later, the military announced destruction of another 30 illegal refinery sites across the Rivers, Bayelsa, Delta and Abia States, nullifying earlier estimates of the number of such sites earlier mapped out in the region. The Abaze forest refinery site which detonated in Imo State was not captured by industry security radar.
As amorphous as it has proven, the pervasive artisanal crude oil distillation that remains illegal and unregulated is actually a small branch of larger malaise: scramble for bigger share of crude oil and condensate from the production facilities of licensed operators in the industry.
In a comprehensive evaluation of the sabotage impact on the petroleum industry, the incumbent Group Managing Director of Nigerian National Petroleum Company (NNPC) Limited, Mallam Mele Kyari, declared mid 2019 that number breaches on operated pipeline reached head-turning 45,347 incidents between 2001 and mid-2019.
As expected, Mallam Kyari was responding to a fatal incident of pipeline explosion attributed to activities of oil thieves. More than five people died in the pipeline fire and dozens of others were rushed to hospital.
Mallam Kyari said the explosion occurred after oil thieves worked to install a siphon channel in a live flowline, a common practice in crude oil, refined products and condensate stealing.
He pointed at rising oil pipeline vandalism in Nigeria, adding that the number of breaches in July 2019 was 115 percent higher than the previous month. By December 2019, the incidents jumped by 34 percent from 197 in preceding November to 257.
The incident and subsequent lamentations by Mallam Kyari played just ahead of the disastrous covid-19 pandemic and associated lockdown responses which wiped global demand for oil and pulled prices below profitable levels.
Details of facility breaches and associated incident reported to regulators clearly show that the scale of invasion covers the full petroleum industry spectrum and compromised the complete facility map. From wellheads, flow stations and pipelines in the upstream sector to jetties, depots and pipelines in the downstream in the downstream sector; thieves have sustained massive assault on the nation’s petroleum industry infrastructure.
In the middle of all the destructive activities of the criminal enterprise in the industry are the sprawling illegal refineries that threaten to turn the Niger Delta operating environment into one big environmental mess.
Whereas the pandemic lockdowns dismantled market demand for crude oil and also disabled international logistics oil trade, it created huge opportunity for local suppliers of petroleum products. The situation also created huge market opportunity for illegal refineries in the country as marketers turned inwards for local sourcing of distillates like diesel and kerosene.
It would be recalled that the ubiquitous illegal refineries and very few licensed modular refineries remain the only sources of supply in the country outside importation. And their products which are mainly diesel are commercially deregulated and sold freely in the open market.
Thus, the supply role and rising share of illegally refined fuels in the domestic market, its growing degree of commercial viability and stronger lucre pull indicate the suction force of the crude thieving industry on the nation’s production facilities.
In its operations update, Shell Petroleum Development Company (SPDC) which is the in middle of attacks in the Niger Delta pointed at both crude oil stealing and illegal refineries as twin plagues in the upstream petroleum industry.
The company stated in a recent report that attacks sabotage and breaches of its pipelines and well heads as well as illegal refineries posed major operational glitches to key commercial and environmental targets.
The investor groups in the industry-the Oil Producers Trade Section (OPTS) and the Indigenous Producers Group (IPPG)-have jointly deplored crude oil theft as the leading activity reflecting in industry facility vandalism and illegal refinery operations.
Thus, all the dark activities in the petroleum industry comprising facility vandalism, oil stealing and illegal refinery operations are too heavy to be parasitic on commercial operations of investments that have long registered distress.
Oil price incentives
The covid-19 demand destruction wiped off the market for export arm of the Nigerian crude theft industry and raised commercial incentives for illegal refiners to thrive in the domestic market.
But despite their large numbers, the illegal refiners collectively hold insufficient capacity to absorb the full stealing volume of the upstream thieving syndicates. At the same time, low crude prices also pulled the prices of refined products lowest levels.
Thus, the demand situation in 2020 wreaked havoc on the incentive for crude oil stealing.
Consequently, Nigeria’s crude oil and condensate output suddenly recovered but at a time of low demand and low price in the market. Thus, economic value for the commodity remained low and incapable of save the local economy from slipping into recession.
With a swift intervention by the Organization of Petroleum Countries (OPEC) and its allies in rebalancing the market by draining glut, the reopening of global economies as countries roll out covid-19 vaccines and consequent resurgence of demand; oil prices in the international market have since jumped into peak altitudes.
The recovery of oil prices also restored strong incentives for thieves to return to their act.
Political nexus
Also, the combination of other local factors including the upcoming 2023 elections and the rising cost of political participation present strong incentives for criminal enterprises that yield hard currency.
The Oracle Today reports that surge in pipeline vandalism and associated crude oil stealing are commonplace in years when Nigeria prepares and conducts general elections. At such periods, exigencies of political campaigns understandingly mount financial pressure on politicians that seek positions in government.
It must be pointed out that the power that sustains the dark activities in the petroleum industry exist higher and above the gangs of miscreants that execute the actual hacks on pipelines and operate illegal distillation clusters.
The level of logistics investments, technical skills, security and legal cover that sustain criminal operations in the petroleum industry entail deep pocket investments in acquisition and cost of operations. Our tracking of the battle against oil thieves in Nigeria exposed a pattern of coincidences between political campaign activities and surge in the frequency of attacks and volume of drain from industry pipelines.
The 2019 scenario narrated by Mallam Kyari falls into pattern with similar upsurge in oil stealing in 2002 and 2003; 2007 and 2008; 2010 and 2011; as well as 2014 and 2015 when elections also held.
Although no political big wig has been indicted for oil stealing or proceeds taking, it is common knowledge that political intervention has stalled prosecution of most of the thieves arrested by security forces.
Former militant war lords whose groups relied on oil stealing for funding are known loyalists of powerful political factors in their domains.
Complicity
Similar to the culpability of the political class in the sustained assault on the industry is also the suspected complicity of security agencies and government officials that process oil export for Nigeria.
The suspicion of political cover for oil crime in Nigeria is validated by incidents involving some security agents and officials of national oil company in the busted stealing operations.
It has been previously reported that some security personnel assigned to protect oil infrastructure and facilities ended up colluding with the criminals to perfectly execute their crimes.
A brazen case was the disappearance of the famous MT African Pride from the custody of Nigerian security forces after it was arrested for involvement in illegal export of stolen crude oil.
The scale of crude oil stealing had so escalated that very conspicuous marine vessels including were deployed in the trade which undercuts legitimate investments by licensed operators in the industry.
Former Managing Director of Shell Petroleum Development Company (SPDC) Limited, Mr Mutiu Sumonu, had pointed at the daring boldness of the perpetrators and the level of logistics invested in the illegal operations.
Call to action
The lost volumes of crude oil are arguably the least value destroyed in the crude theft enterprise that has projected Nigeria in the global map of hostile business climates for petroleum investments.
Whereas Mallam Kyari emphasizes the revenue losses and overall economic impact on the industry and government partners, oil theft has created settings for regular fire explosions that leave families mourning their loved ones. In some cases, siblings along with their fathers have perished in a flash of blast during oil theft or illegal refining operations.
Devastating impact of spills and discharges into the fragile Niger Delta environment at a time of rising global consciousness for climate change paints an image of self immolation, as communities which should be primarily concerned about the environmental responsibility of the industry participate in far reaching pollution.
And despite the popular misgivings against mismanagement of resource revenue, recent global pandemic lockdown and associated economic recession exposed the criticality of the petroleum industry to the overall fiscal health of all tiers of government in Nigeria. The erosion of oil value in 2020 showed that other revenue inlets into the federation account significantly draw from the petroleum industry.
The biggest tax payers in the country come from the petroleum industry, biggest international maritime traffic into the country are marine tankers exporting or importing crude oil and fuel products respectively.
Biggest foreign exchange earners and account holders with Nigerian banks play in the petroleum industry.
Thus, revenue performance of other government agencies is actually tied back to the oil and gas industry. Therefore, the monthly cash sharing that happen in Abuja among the 36 states, the FCT and 774 local governments in the country is directly and indirectly financed by the petroleum industry. It could then be sustainably argued that petroleum industry values spread through government’s fiscal networks to touch the life of every Nigerian.
Mallam Kyari stated that crude oil theft has posed existential threat to the industry and contribute to the country’s economic woes by making government unable to realize its revenue targets from petroleum industry operations.
So, protecting the industry should and has to involve all stakeholders, including the man on the street. And the need for collective action has become necessary following allegations of conspiracy and complicity of responsible agencies that have failed in combating the menace.
Malam Kyari of NNPC has regularly emphasized the need for every Nigerian to take responsibility of a stakeholder in the petroleum industry, arguing that local community orientation and commitment to the protecting the industry and operating environment would be critical deterrent to criminality in the industry.
He called for full orientation for shared values in the petroleum industry, and urged political leaders across tiers of government drill down the values of the industry to their subjects through integrity, equity and transparency in resource management across every level of the governance.
Apparently pointing at difficulties experienced by security agencies in prosecuting and appropriately punishing oil thieving culprits, Mallam Kyari also called for enforcement of legal provisions on economic sabotage.
The Oracle Today reports that the industry players, before the prevailing mass movement from onshore terrains, had lobbied and enlisted all known security outfits in the country in resolving oil theft but to no avail. From regular policy to DSS, EFCC, the Navy, Joint Task Force et cetera, the industry has exhausted collaboration on security in Nigeria.
However, with the twin menace of oil theft and pipeline vandalism contesting control of the nation’s resource wealth, President Muhammadu Buhari has issued fresh mandate to the Chief of Defense Staff to flush oil thieves from the Niger Delta. Following the charge, a new offensive has led to arrest of some of the criminal elements.
Also, the Economic and Financial Crimes Commission (EFCC) and the National Financial Intelligence Unit (NFIU) have been deployed to track movement of funds relating to the oil theft.
NNPC said it deploying technology based surveillance tools and enlisting the collaboration of community-based security personnel for more effective watch over oil pipelines and sundry facilities.
With all relevant agencies of government and tools deployed in the renewed efforts to retrieve the national resource wealth from criminal syndicates shadowing the industry, what is currently required to complete the cycle of efforts is community participation which is expected to deploy hundreds of million eyes to watch over the industry.
“Apart from the host communities that are directly affected by the environmental degradation, every citizen suffers the loss of national revenue when government does not have enough to provide social amenities and infrastructure to improve the quality of life in the country,” NNPC argues.
“It is, therefore, imperative for all Nigerians to rise up against those behind crude oil theft and pipeline vandalism with a view to stamping them out so that the oil and gas industry can yield the fullness of benefits to the nation and its citizenry,” the company stressed.
It is however imperative to point out that the noble objectives of flushing out criminals from the petroleum industry holds the expectation of smooth interface and collective trust of all stakeholders in the cardinal objectives of cleansing the industry and its operating environment of criminality.