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Indicators

Anticorruption

AC1
Does the company have a publicly stated commitment against corruption and bribery?
Background: 

This indicator requires companies to make a public commitment against any form of bribery or corruption. Committing to a zero tolerance to bribery and corruption practice is considered an important component of company’s communication to their stakeholders, citizens and researchers. Various TI anti-bribery and anti-corruption guides require companies to make public commitments again corruption and bribes. For example, Guideline No. 5 of the “Business Principles for Countering Bribery: A Multi-Stakeholder Initiative led by Transparency International” and TI-UK “Open Business” Report requires a high-level commitment for a zero-tolerance policy against bribery and corruption.

To receive a point: 

This commitment must be posted on the website of the company on the date of assessment. Examples of where this information could be located include corporate governance documents like the Code of Conduct, mission statements and/or within publications such as annual reports and investor relations material.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland researchers at the date of assessment that this information exists in the company’s off-line publicly disclosed documents.

AC2
Does the company state publicly that it will comply with all legislation including those related to anti-corruption?
Background: 

This indicator assesses the company’s undertaking to comply with all law in all countries it operates with particular focus on laws against bribery and corruption. While a public undertaking cannot be equated with companies’ actual performance, it demonstrates their commitment to full legal compliance and improves their credibility and reputation in front of the public, investors, stakeholders and researchers/analysts.

To receive a point: 

This statement must be posted on the website of the company on the date of assessment. Examples of where this information could be located include corporate governance documents like its Code of Conduct, mission statements and/or within publications such as annual reports and investor relations material.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland researchers at the date of assessment that the statement about complying with all laws including those related to anti-corruption exists in the company’s off-line publicly disclosed documents.

AC3
Does the senior management and board demonstrate support against corruption and bribery?
Background: 

This indicator assesses if the company leadership sets the ‘Tone from the Top’ against any form of bribery and/or corruption. Leadership support may include: a zero-tolerance statement authorised by leadership; evidence that the board or a board committee oversee and review the anti-corruption policies; evidence that a senior executive has responsibility for the anti-bribery and corruption programme; and a public commitment to supporting and protecting employees who refuse to act unethically, even when it might result in the loss of business.

To receive a point: 

The company must have posted on the website of the company on the date of assessment a statement/s from the Board or senior management committing against corruption and bribery and/or evidence that a senior executive has responsibility for the anti-corruption and anti-bribery programme.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence of a statement/s from the Board or senior management committing to anti-bribery and corruption and/or evidence that a senior executive has responsibility for the anti-corruption and anti-bribery programme at the time of the assessment.

AC4
Does the company have a risk-based anti-corruption and anti-bribery programme that is regularly monitored?
Background: 

Background: This indicator assesses whether the company has adopted a programme which articulates clearly and in detail the values, policies and procedures to be used to prevent bribery from occurring in all activities under its effective control. Accordingly, to the “Business Principles for Countering Bribery: A Multi-Stakeholder Initiative led by Transparency International” a good Anti-Bribery and Anti-Corruption plan should be designed and improved on the basis of continuing risk assessment. The programme should detail proactive measures to reduce risks pertaining to corruption and bribery. The programme can form part of an overall risk management plan at the company, but must satisfy TI Ireland that it contains sufficient checks, balances, and provisions on addressing the risk of corruption and bribery.

To receive a point: 

This programme must be posted on the website of the company on the date of assessment indicating that the Board and management monitor the anti-corruption and anti-bribery programme.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland researchers, that there was in place at the time of assessment, an anti-corruption and anti-bribery programme and it is regularly monitored by the Board and senior management.

AC5
Does the company require specific adherence to its programmes against corruption and bribery by all its directors and employees?
Background: 

This indicator assesses if the companies require all employees regardless of the seniority level to adhere to its programmes against corruption and bribery. According to the 10th Principle against corruption adopted on 24 June 2004, the first Global Compact Leaders’ Summit: “Businesses should work against corruption in all its forms, including extortion and bribery.” By requiring all employees to adhere to its ABAC commitments, companies send a strong signal that they expect compliance and take responsibility against unethical behaviour. This also shows that a company shares responsibility for eliminating corruption and stands ready to play its part against corruption by requesting adherence from all directors and employees.

To receive a point: 

The company must have a specific requirement for adherence to its anti-corruption and anti-bribery programmes to all employees and directors posted on the website of the company on the date of assessment.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland that at the time of assessment, employment contracts agreed upon with employees and directors contained specific requirements for adherence to anti-corruption and anti-bribery policies.

AC6
Does the company require adherence to its policies and/or programmes against corruption and bribery from third party persons or entities providing goods or services under contract such as contractors, subcontractors and suppliers, agents and other intermediaries?
Background: 

This indicator assesses how a company manages the risk of corruption of third parties acting for or on behalf of the company. According to Guideline 5 of the “Business Principles for Countering Bribery: A Multi-Stakeholder Initiative led by Transparency International” companies should prohibit all forms of bribery whether they take place directly or through third parties. This means that a company should use anti-bribery and corruption clauses in its contracts with third parties, and should publicly state that it does so. Ideally a company should also disclose details of how it conducts risk based anti-bribery and corruption due diligence when entering into business relationships with third parties.

To receive a point: 

The company must have posted on the website on the date of assessment that it adopts an integrated and consistent approach for managing risks related to corruption and bribery by third parties across the company’s operations.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide to TI Ireland researchers some evidence of the due diligence conducted either by staff employed by the company or external agencies to address risks related to corruption and bribery by potential and eventual clients, business partners, contractors, and all other relevant parties.

AC7
Does the company have in place a risk-based anti-corruption and anti-bribery training programme for its employees and directors?
Background: 

This indicator assesses if the company has and publicly discloses a programme of training for its employees and directors on ABAC policies which takes into consideration the level of risk that employees are exposed. According to TI-UK “OPEN BUSINESS Summary of principles and guidance for anti-corruption corporate transparency” of March 2020. “A company should publicly state that it conducts training on its anti-bribery and corruption programme. It should also publicly disclose details of how it reviews and measures the effectiveness of this training. In order to create a culture against corruption that is responsive to risks and changing circumstances, such a training programme should be delivered periodically (annually or biannually), either internally or externally, and ideally be tailored to accommodate different risk profiles and lines of business within the company. TI Ireland understands that companies face time and resource constraints, and that all staff may not be afforded such training. Therefore, when decisions are being made regarding which members of staff and management should receive such training, TI Ireland recommends incorporating a risk profile assessment to the process of providing training to employees.

To receive a point: 

The company must have a risk-based anti-corruption and anti-bribery training programme for its employees and directors or a specific reference to its implementation posted on the website of the company on the date of assessment.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland researchers that, at the time of assessment, the company had in place, a system for the delivery of training to management and relevant staff on matters relating to countering corruption and bribery.

AC8
Does the company have a policy and procedures for gifts, hospitality and expenses?
Background: 

This indicator assesses if the company has a policy and procedures on prohibiting the use of gifts, hospitality and expenses to gain undue competitive advantages or obtain favours by influencing decisions of the public officials. This is considered an important aspect of ABAC policies because many companies use gifts, hospitality and expenses as a way to circumvent prohibitions against bribes and corruption. According to Guideline 5.6 of the “Business Principles for Countering Bribery: A Multi-Stakeholder Initiative led by Transparency International” Companies are expected to develop a policy and procedures to ensure that all gifts, hospitality and expenses are bona fide. Therefore; companies should not only prohibit the offer, giving or receipt of gifts, hospitality or expenses whenever they could influence or reasonably be perceived to influence improperly the outcome of business transactions but also have procedures in place to deal with such situations when and they arise. Additionally, as suggested by the TI-UK open businesses report of March 2020, companies should include a clearly defined approval process for gifts and describe consequences for non-compliance with them.

To receive a point: 

The company must have a policy and procedures to prevent corruption through the use of gifts, hospitality and expenses. It should make it clear that gifts, hospitality and expenses must not be used to influence the decisions of public officials or to confer an undue advantage to the company or its agents, and procedures for the review of those procedures posted on the website of the company on the date of assessment.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland that it has in place a policy and procedures to prevent corruption through the use of gifts, hospitality and expenses that influence the decisions of public officials or confer an undue advantage to the company or its agents at the time of assessment.

AC9
Does the company have a publicly available procedure for the management of conflicts of interest including interest declarations?
Background: 

This indicator assesses how companies deal with Conflict of Interest situations and if they have a formal procedure in place to manage such situations. All business may potentially run into situations involving conflicting interest and having policies that define, identify, declare and manage conflict of interest helps protect their reputation, comply with legislation and also gain the trust of businesses and employees. According to Guideline 5.1 of the “Business Principles for Countering Bribery: A Multi-Stakeholder Initiative led by Transparency International, “these policies and procedures should apply to directors, officers, employees and contracted parties such as agents, lobbyists and other intermediaries. TI Ireland understands that companies may have reasons not to public the CoI statements online but they should be available upon request to the Audit Committee and/or other officers dealing with compliance and legal matters.

To receive a point: 

The company must have policies and procedures to manage conflicts of interests on the website of the company on the date of assessment which provides that declarations of interest are available if requested to the Audit Committee and/or Chief Compliance Officer.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to the TI researchers that there was in place, at the time of assessment, a procedure for the mandatory up-to-date filing of declarations from staff and directors pertaining to conflicts of interest and providing that such declarations of interest are available for review, if requested to the Audit Committee and/or Chief Compliance Officer.

AC10
Does the Board receive regular reports from management on the status of its anti-corruption and anti-bribery programme and does it monitor that policies are updated according to the recommendations made following the review of such programmes?
Background: 

This indicator assesses how the company monitors, reviews and updates its ABAC policies. Continuous monitoring demonstrates that the company does not merely adopt the ABAC policies to comply with legal requirements and treat them as “paper commitments” but that it seeks to improve them based on risk assessment. Periodic reviews by the Board and Audit Committee send a strong signal to all employees, businesses and consumers that a company takes ABAC measures seriously. According to TI-UK Open Business Report of March 2020, companies should explain how they monitor and review their anti-bribery and corruption programmes. This should include details of the extent to which this programme is subject to regular internal or external audit, and assurance that policies are updated according to recommendations. Ideally, monitoring and reviewing procedures should be reflected in specific sections of the annual reports.

To receive a point: 

Company documents posted on the website on the date of assessment must indicate that the Board receives regular reports from management on the status of its anti-corruption and anti-bribery programme and monitors that policies are updated according to the recommendations made following the review of such programmes.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to the TI Ireland researchers to show that at the date of assessment the Board receives regular reports from management on the status of its anti-corruption and bribery programme and monitors that policies are updated according to the recommendations made following the review of such programmes

Organisational Structures Transparency

O1
Does the company disclose a full list, including names of its fully and non-fully consolidated subsidiaries?
Background: 

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.

To receive a point: 

The company must have this information posted on its website at the time of assessment.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase and/or must have disclosed to TI Ireland researchers upon request, a full list, including names and details of percentages owned of each of its fully and non-fully consolidated subsidiaries.

O2
Does the company disclose a full list of names and details of percentages owned of each of its fully and non-fully consolidated subsidiaries?
Background: 

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.

To receive a point: 

The company must have this information posted on its website at the time of assessment.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase and/or must have disclosed to TI Ireland researchers upon request, a full list, to include names of its fully and non-fully consolidated subsidiaries.

O3
Does the company disclose the countries of incorporation of its fully and non-fully consolidated subsidiaries?
Background: 

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.

To receive a point: 

The company must have this information posted on its website at the time of assessment.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must have disclosed to TI Ireland researchers upon request, a full list of countries of incorporation of both fully and non-fully consolidated subsidiaries.

O4
Does the company disclose the countries of operation of its fully and non-fully consolidated subsidiaries?
Background: 

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.

To receive a point: 

The company must have this information posted on its website at the time of assessment.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must have disclosed to TI Ireland researchers upon request, a full list of both fully and non-fully consolidated subsidiaries and their countries of operation.

O5
Does the company disclose its revenues/sales in Ireland and other countries it operates?
Background: 

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.

To receive a point: 

The company must have publicly disclosed, on their website, at the time of assessment information on all revenue/sales generation by country, to include at least, data on those revenues generated in Ireland.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland researchers on its revenue/sales generation in Ireland and other countries it operates by the time of the assessment.

O6
Does the company disclose its capital expenditure in Ireland and other countries it operates?
Background: 

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.

To receive a point: 

The company must have publicly disclosed, on their website, at the time of assessment information on its expenditures in Ireland and other countries it operates.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland researchers on its expenditures in Ireland and other countries it operates by the time of assessment.

O7
Does the company disclose its corporate taxes paid in Ireland and other countries it operates?
Background: 

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.

To receive a point: 

The company must have disclosed publicly at the time of assessment, on their website, or made available to TI Ireland researchers upon request, the corporate taxes paid in Ireland and other countries it operates.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland researchers on its corporate taxes in Ireland and other countries it operates by the time of assessment.

O8
Does the company disclose its charitable donations and community contributions made in Ireland and other countries it operates?
Background: 

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.

To receive a point: 

The company must have disclosed, on their website, at the time of assessment data on any charitable donations and/or community contributions made in Ireland and other countries it operates.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland researchers on the charitable donations and/or community contributions made in Ireland and other countries it operates by the time of assessment.

Responsible Political Engagement

Whistleblowing

W1
Does the company have a policy and procedures in accordance with Irish law to promote whistleblowing, specifically including assurances to employees, contractors, subcontractors and suppliers, agents and other intermediaries that no penalisation or reprisal will result from whistleblowing?
Background: 

This indicator assesses if the company publicly discloses a policy and procedures to promote whistleblowing without the fear of reprisal. TI defines whistleblowing as “the disclosure or reporting of wrongdoing, which includes corruption, criminal offences, breaches of legal obligation, miscarriages of justice, specific dangers to public health, safety or the environment, abuse of authority, unauthorised use of public funds or property, gross waste or mismanagement, conflict of interest, and acts to cover up any of the aforementioned. While whistleblowers are invaluable in exposing corruption, fraud and mismanagement; blowing the whistle can also carry personal and professional risks. The policy should, inter alia, include assurances that whistleblowers will not suffer penalisation of any kind as a result of raising concerns in the workplace; that action will be taken in response to those concerns where possible; as well as information on their rights and responsibilities consistent with Irish law.

To receive a point: 

This information, including such assurances to whistleblowers, must be available publicly on the website of the company at the time of assessment.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to the TI Ireland researchers, that there was a company-wide policy in place at the company for whistleblowers at the time of assessment.

W2
Does the company proactively communicate the availability of internal and external advice and whistleblowing reporting channels for staff, contractors and third parties?
Background: 

This indicator assesses how the company enables its staff and third parties to blow the whistle through communicating reporting channels. While adopting an effective whistleblowing framework is essential to stimulate the reporting of corruption, misconduct and fraud, proactive communication of the available channels to raise concerns is essential to making the whistleblowing policy effective in practice. Ideally, companies should have a variety internal and external channels for reporting unlawful and/or unethical behaviour and create a “speak up safely” culture for staff, contractors and third parties. Such examples may include induction and periodic training on whistleblowing, regular reminders to staff via email, internal signposting on company premises, or other similar measures.

To receive a point: 

The information on the availability of internal and external advice and whistleblowing reporting channels for staff, contractors and third parties should be made public on the website of the company at the time of assessment.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to TI Ireland researchers on the availability of internal and external advice on whistleblowing reporting channels for both staff, contractors and third parties at the time of assessment.

W3
Does the company record and share data on the whistleblowing reports received, and action undertaken in response to these reports to its Board/Board Committees and/or relevant management or staff?
Background: 

This indicator assesses how the company records the whistleblowing reports and how it reports to its stakeholders on the actions taken. While whistleblowing and Speak Up channels are important, companies are also expected to keep track and act upon disclosures so that employees and third parties can be assured that the Board takes such disclosures seriously. The company must have systems to record the number of whistleblowing reports received, and the corresponding actions taken in response to these concerns, with such data subsequently shared with the board, staff, and shareholders. Ideally, companies must adopt some form of a Case Management System for the recording, investigating and monitoring of reports. This system enables companies to collect and review key statistics of reports on a regular basis and share them with the Board and shareholders. This prevents a company from overlooking reports and makes it easy to give feedback to reporters about the status of their case.

To receive a point: 

The company must have information on the number of reports and actions undertaken posted online on the company’s website at the time of assessment.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to the TI Ireland researchers that it does record the reports received and the corresponding actions undertaken, at the time of assessment.

W4
Does senior management commit to protect whistleblowers from any reprisal, to discipline anyone retaliating or allowing retaliation against a whistleblower, and to take action in response to whistleblower reports?
Background: 

This indicator assesses how the senior leadership commits to protect whistleblowers from any form of retaliation and how acts upon those reports. It is also essential that staff, contractors and third parties see that whistleblowing disclosures and reports are acted upon where appropriate. The company should ideally have in place, a review system that documents each whistleblowing case, including the decision(s) taken in response to the concern(s) raised, and the rationale behind such decision(s). Commitments to prevent reprisal and to take action in response to disclosures should be publicly available on the company’s website. In addition, the annual report and/or dedicated reports should document the work done by the company to implement its whistleblowing policies and to support its speak up culture.

To receive a point: 

The company must have information on the company’s website at the time of assessment confirming that senior management commits to protect whistleblowers from any reprisal, to discipline anyone retaliating or allowing retaliation against a whistleblower, and to take action in response to whistleblower reports.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to the TI Ireland researchers that there was in place, at the time of assessment, a written and publicly available statement confirming that senior management commits to protect whistleblowers from any reprisal, to discipline anyone retaliating or allowing retaliation against a whistleblower, at the time of the of the assessment.

W5
Does the company train relevant staff on how to handle whistleblowing reports?
Background: 

This indicator assesses the training programmes in place for company staff who are responsible for handling whistleblowing reports. As part of their broader integrity training programs, companies should have training programmes in place on the normative frameworks on whistleblowing as well as the procedural aspects of receiving, investigating and handling whistleblowing reports. Such a training programmes should be delivered regularly, either internally or externally, and ideally be tailored to accommodate different lines of business within the company through online and offline means. TI Ireland understands that employers face time and resource constraints, and that all staff may not be afforded such training. Therefore, when decisions are being made regarding which members of staff and management should receive the training, TI Ireland recommends incorporating a risk-based approach to this process.

To receive a point: 

The company publicly discloses on the website at the time of assessment, a commitment to training relevant management and employees on how to process, assess and where relevant, investigate whistleblowing reports as well as any legal responsibilities arising from them.

To receive 0.5 points: 

The company is either partially compliant with the indicator during the online research phase or must provide documentary evidence to the TI Ireland researchers regarding its commitment to train relevant staff on how to handle, process, assess and where relevant, investigate whistleblowing reports as well as any legal responsibilities arising from them, at the time of assessment.