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The methodology of this NII - Private Sector study builds on TI’s ongoing work in combating corruption in the private sector and publications based on TI’s Transparency in Corporate Reporting (TRAC) standard methodology and adapts it to the Irish context.

The Private Sector study evaluates proactive corporate reporting across four main dimensions:

  • Transparency of anti-corruption and anti-bribery programmes,
  • Organisational transparency (subsidiaries, ownership and country-by-country reporting),
  • Responsible political engagement (lobbying, disclosure of political contributions), and
  • Whistleblowing frameworks (speak up policies and procedures).

Thirty companies were chosen from the 2019 Irish Times’ list of the top 1000 companies in Ireland ( The sample includes companies that are domiciled or have significant operations in Ireland from eight industries. The list includes some of the largest and most successful Irish companies as well as multi-national corporations, which are included in the study based on the number of employees in Ireland in 2019.

The study was based on information made publicly accessible by the companies, for example on their websites and/or in their annual financial statements. TI Ireland chose companies’ websites as the primary source for the data collection because this is the most visible and accessible way to communicate their commitment to counter corruption and bribery. Research was conducted by TI Ireland researchers from May to September 2020. Online data collection took place from 1 June to 31 July 2020. Under each indicator, companies could receive a maximum of one point. The maximum available points for the 30 indicators designed for this study was 30. None of the companies achieved 100% of the available points. 

Preliminary scores were provided to companies for feedback on 5 August 2020. All companies were initially given two weeks (from 5 August 2020 to 23 August 2020) to request clarification, provide feedback or submit evidence of the existence of policies and procedures that were not publicly disclosed on the company website by 31 July 2020. In response to requests by various companies, the deadline for the companies’ feedback was extended to 11 September 2020.

Due to Covid-19 restrictions on large gatherings, TI Ireland invited all companies to a Zoom Workshop to discuss preliminary findings and various matters related to the study on 2 September 2020.The Zoom workshop was attended by 12 participants from eight companies. It was noted that most companies have additional policies and procedures that are not publicly accessible.

Based on companies’ submissions and an audit of all scores, a revised scorecard was sent to each company on 21 April 2021, with any further observations or relevant submissions accepted up to 14 May 2021. Any additional information relevant to this study that may have been made public by companies on their website after the original research period has been excluded from this research but will be considered in any subsequent update. TI Ireland aims to update the findings of the report in late 2021/early 2022.

It should be emphasised that the primary objective was to shed light on what the companies were disclosing online and not how the companies were implementing the provisions of their relevant policies and procedures. To this end, the TI Ireland research team did not investigate the truthfulness or completeness of the publicly available information and did not make any judgement about the integrity of the information or practices disclosed. Such an assessment would require a much more detailed analysis based on, inter alia, interviews with directors, senior management, employees, suppliers, and business partners. Such an analysis was not within the scope of this study.