Perrigo Company plc

This indicator assesses a company’s disclosure of its organisational structures, namely the list of names of its fully consolidated and non-consolidated subsidiaries and holdings. When companies deliberately do not fully disclose their subsidiaries, it can be very difficult to identify them and understand how they relate to each other. Full organisational transparency is important not only for shareholders but also for other stakeholders who may have an interest in knowing which companies are owned or controlled significantly shared by a certain company operating in their country. This is particularly important for big multi-national companies with large and complex networks of interconnected entities involving subsidiaries, affiliates or joint ventures controlled to varying degrees by the parent companies and operating in various jurisdictions. Organisational transparency enables stakeholders to gain insight into the companies’ controlling interests, to which international networks companies belong and how these companies relate to one another. Moreover, it reveals potential financial flows between the network of companies, intra-group transfers, and government payments such as taxes. Disclosing information about the interconnectedness of companies can further facilitate the process of finding out which parent company is responsible for the businesses in terms of ethical and corruption-free behaviour. Local stakeholders benefit from knowing which companies are operating in their territories, bidding for government licenses or contracts, or having applied for or obtained favourable tax treatment. It also informs local stakeholders about which international networks these companies may belong to and allows them to hold companies accountable for the impacts they have on the communities in which they operate.

This indicator assesses a company’s disclosure of the property interests/shared of all the fully consolidated and non-fully consolidated subsidiaries. As explained above, organisational transparency is important for many reasons: it enables local stakeholders to know which companies are operating in their countries, which type of resources are used, or which favourable investment or tax treatments are granted. Organisational transparency enables stakeholders to gain insight into the companies’ controlling interests, to which international networks companies belong and how these companies relate to one another. Moreover, it reveals potential financial flows between the network of companies, intra-group transfers, and government payments such as taxes. Disclosing information about the interconnectedness of companies can further facilitate the process of finding out which parent company is responsible for the businesses in terms of ethical and corruption-free behaviour. Local stakeholders benefit from knowing which companies are operating in their territories, bidding for government licenses or contracts, or having applied for or obtained favourable tax treatment. It also informs local stakeholders about which international networks these companies may belong to and allows them to hold companies accountable for the impacts they have on the communities in which they operate.

This indicator assesses whether a company discloses the countries in which all the companies it may own completely or significantly are incorporated. This is considered very important to avoid tax forum shopping by companies. These can be registered and operate in several provinces within one country or in different countries, including secrecy jurisdictions or tax havens. According to TI-UK’s principles of corporate disclosure published in the Open Business Report of March 2020 all companies should publicly state that they will not work with businesses which operate with deliberately opaque structures Indicators that a business may be deliberately opaque include: if it has operations in a secrecy jurisdiction, for example, the Cayman Islands; the use of ‘nominee’ directors; the use of a ‘mailbox’ address, where the company is registered at an address but there are no employees or operations there; and the use of corporate directors, partners, members, or shareholders from a secrecy jurisdiction.

This indicator is intended to assess another aspect of organisational transparency - namely the countries of operations for Irish based companies, their fully consolidated and non-fully consolidated subsidiaries. Multinational companies often have numerous subsidiaries in different countries and also other ownership interests such as associated companies, joint-ventures or other holdings. These entities are frequently registered offshore, including in what are considered secrecy jurisdictions or tax havens. For the reasons mentioned above, it is important that observers are able to draw from publicly available documents on the companies’ websites such as annual reports and identify company subsidiaries, affiliates, joint ventures and their countries of operation.

This indicator assesses one of the most important aspects of companies’ Country to Country Reporting - namely the revenues/sales created in Ireland and other countries in which it operates. It is important because it allows stakeholders, public authorities, consumers and civil society actors to scrutinise the company’s commitment to transparency. The level of revenue generated should be in the public domain because it can help public assess the impact of the company’s operations in the communities in which it is present and understand the scale of operations and other aspects of business activity. While this information may be located in various company’s financial statements and/or annual reports, TI Ireland believes that given the importance of these variables for public policy, this information should be made publicly and clearly available online. Ideally, a data table containing basic company performance indicators on a country-by-country basis should be clearly available for inspection on the website of the company.

This indicator assesses the level of disclosure by the company of its expenditures made in Ireland and other countries it operates. According to TI-UK Open Business Report all companies should publicly disclose country-by-country breakdowns of its payments to governments and the expenses made in a certain jurisdiction. Full transparency would require a breakdown of all expenditures which allows stakeholders to scrutinise how much companies are spending in each jurisdiction and identify companies which relocate their revenues in certain jurisdictions but otherwise make no expenditures there.

This indicator is particularly important because many countries, including Ireland, have attracted significant attention due the low tax rates offered to large companies. Transparency over corporate tax payments should be viewed as an integral part of their corporate responsibility. At the same time, higher levels of disclosure on tax payments helps stakeholders determine whether certain companies are being given preferential tax rates over other companies in the same jurisdiction. While this information can be extracted from company’s financial statements and/or annual reports, given the importance of these variables for public policy, a data table containing corporate taxes on a country-by-country basis should be clearly available for inspection on the website of the company.

This indicator assesses how the company discloses its charitable donations and community contributions. While investing in the communities in which companies operate is an important aspect of corporate responsibility, many companies may use donations and other contributions (i.e. community investment projects) as a way to bypass prohibitions on bribery and gain an undue advantage against competitors. This practice is particularly problematic for companies operating in high risk countries where oversight mechanisms are weak but also in highly developed countries with an unregulated charity sector. According to Guideline 5.4 of the “Business Principles for Countering Bribery” all companies should ensure that charitable contributions and sponsorships are not used as a subterfuge for bribery and should publicly disclose all its charitable contributions and sponsorships. While this information can be extracted from company’s financial statements and/or annual reports, TI Ireland believes that given the importance of this information for corporate transparency and business integrity, a data table containing charitable donations and/or community contributions made on a country-by-country basis should be clearly available for inspection on the website of the company.