Santiago Principles Self-Assessment

Nigeria Sovereign Investment Authority

Fund Details Fund Website Search Assessments PDF version
  • Pillar 1: Legal
  • Pillar 2: Institutional
  • Pillar 3: Investment
Principle 1

1. The legal framework for the SWF should be sound and support its effective operation and the achievement of its stated objective(s).

1.1. The legal framework for the SWF should ensure legal soundness of the SWF and its transactions.

1.2. The key features of the SWF’s legal basis and structure, as well as the legal relationship between the SWF and other state bodies, should be publicly disclosed.

The legal framework for the Nigeria Sovereign Investment Authority (NSIA) is the Nigeria Sovereign Investment Authority (Establishment etc.) Act, 2011 (NSIA Act 2011). NSIA was established by an act of the National Assembly in May 2011. The Act was signed into law by the President of the Federal Republic of Nigeria on May 26, 2011. 

Section 1 of the NSIA Act establishes the NSIA as a body corporate with perpetual succession which may sue and be sued; may acquire, hold, and dispose property; and shall be independent in the discharge of its functions subject to limitations contained in the Act.

NSIA’s legal basis and structure, and legal relationships between the NSIA Governing Council, the Board of Directors and all tiers of government are detailed in the NSIA Act 2011, a copy of which is publicly available from and can also be found documented in its annual reports.

Specifically, NSIA was established pursuant to the NSIA Act with a statutory mandate to receive, manage and invest funds in a diversified portfolio of medium and long-term assets on behalf of the Federal Government, State Governments, Federal Capital Territory, Local Governments and Area Councils. As a result, NSIA is not a Federal Parastatal, Agency or Institution but a Federation Agency owned to varying share proportions by all tiers of Government i.e. Federal, State, and Local governments.

Principle 6

6. The governance framework for the SWF should be sound and establish a clear and effective division of roles and responsibilities in order to facilitate accountability and operational independence in the management of the SWF to pursue its objectives.

The roles and responsibilities of the Governing Council (representing asset owners), the Board and Management (as asset managers) are detailed in the NSIA Act. According to section 7 of the NSIA Act, at the highest level, the NSIA is overseen by a Governing Council. 

The Governing Council’s 55 statutory members consists of the President of the Federal Republic (The Chairman), Nigeria’s 36 state governors, the Minister of Finance and 12 other members representing civil society, Nigerian youths, the academia and the private sector. 

At the next level is the Board of Directors and the related board committees; and at the third level is the Executive Management team.

Further details are provided in five Board charters and three Investment Policy Statements (IPS). See for copies of the Charters and IPS.

Internal policies, procedures and processes have been established to further outline roles and responsibilities at the operational level.

Principle 18

18. The SWF’s investment policy should be clear and consistent with its defined objectives, risk tolerance, and investment strategy, as set by the owner or the governing body(ies), and be based on sound portfolio management principles.

18.1. The investment policy should guide the SWF’s financial risk exposures and the possible use of leverage.

18.2. The investment policy should address the extent to which internal and/or external investment managers are used, the range of their activities and authority, and the process by which they are selected and their performance monitored.

18.3. A description of the investment policy of the SWF should be publicly disclosed.

NSIA’s investment policies are clearly documented in 3 separate Investment Policy Statements (IPS), each IPS represents the investment policy for a ring-fenced fund. See Each IPS provides a framework for the management of the respective funds and sets out to identify each fund’s investment objectives, risk tolerance and constraints.

The IPS also establishes a structure of guidelines and policies within which the executive management can exercise their delegated authority and against which recommendations to the Investment Committee and the Board can be judged.

Annual reports also provide additional insights into NSIA’s investment strategy. These document, along with the IPS address matters relating to Investment objectives, investment principles, asset allocation, as well as the process for appointing, monitoring and disengaging 3rd part managers, advisors, consultants, and co-investors.