Good Practice Guide

Anti-corruption and anti-bribery programmes

AC1 Has the organisation made a public commitment against corruption and bribery?

Good practice example: A commitment stating that 'The HEA has a zero-tolerance stance on bribery and corruption' was published on the website of the Higher Education Authority.

AC2 Has the senior management and the board (where applicable) publicly shown support against corruption and bribery?

Good practice example: ComReg's website carried a statement that 'ComReg, and its Commission, is committed to a zero-tolerance position in relation to bribery, corruption or fraud'.

AC3 Has the organisation published a risk-based anti-corruption and anti-bribery programme?          

Good practice example: The HSE's Policy on Fraud and Corruption, which sets out a risk-based approach and system of controls, was available through its website.

AC4 Does the organisation require specific adherence to its programmes against corruption and bribery by all its directors (or equivalent) and employees?

Good practice example: Bord Iascaigh Mhara’s Anti-Bribery, Corruption, Fraud and Anti-Theft Policy, which was published on its website, extends to 'all staff, directors and others who transact business with BIM'.

AC5 Does the board (or equivalent) undertake to monitor the anti-corruption programme for its suitability, adequacy and effectiveness, taking into account the results of risks assessments, and implement reviews/improvements as appropriate?

Good practice example: Tusla's website sets out, in a section on anti-corruption and bribery measures, details of annual reviews of controls in place. These include an Annual Control Assurance Survey (for staff above a certain grade as well as 'others, where applicable, who have additional responsibilities with safeguarding against fraud, corruption, and bribery') and an Annual Assurance Report (completed by senior managers, committee chairs and department heads) 'to highlight any control weaknesses, progress made in the year, and any proposals for the following year'. An overall Annual Review of Effectiveness of Internal Controls is then reviewed and approved by the Board'.

AC6 Has the organisation disclosed details of an anti-corruption training programme for its employees and directors?

Good practice example: The Public Appointments Service’s Fraud and Anti-Corruption Policy, which was available on its website, gives details of relevant training for employees, management and the board.

AC7 Has the organisation disclosed a policy and procedures on gifts, hospitality and expenses?

Good practice example: Transport Infrastructure Ireland's Code of Business Conduct, which was available on its website, sets out guidelines for giving and receiving gifts and entertainment, including thresholds and procedures to follow (e.g., a register of gifts). 

AC8 Has the organisation disclosed a policy and procedures on conflict of interests?

Good practice example: The Office of Public Works published its Conflict of Interest policy on its website. The policy outlines several examples of conflicts of interest and sets out the procedure for disclosing and handling conflicts.

AC9 Has the organisation undertaken to exercise mandatory, properly documented, risk-based anti-corruption due diligence on third parties before entering a contract or transaction?

Good practice example: Bord Iascaigh Mhara’s Anti-Bribery, Corruption, Fraud and Anti-Theft Policy, which was published on its website, outlines due diligence measures for third parties, including that BIM engages a 'company search provider' to assess suppliers who submit tenders. Successful suppliers are monitored 'on an ongoing basis'.

Financial Transparency

FT1 Has the organisation published audited financial statements for 2020, including information on annual revenues?

Good practice example: Several organisations including Science Foundation Ireland published their annual report, including financial statements, on their websites.

FT2 Has the organisation made the annual budget and budget commentary for 2021 available online?

Good practice example: The Health Service Executive’s National Service Plan for 2022, which sets out the budget in detail by service area/business unit, was available on the HSE website.

FT3 Has the organisation disclosed a procedure to ensure asset disposal follows a transparent process and is in accordance with market values?

Good practice example: The Citizens' Information Board's Code of Practice, which was on its website, sets out a procedure for the disposal of assets/

FT4 Does the organisation disclose comprehensive information on its procurement policy and procedures on its website (except information that is legally protected for reasons such as national security, the protection of intellectual property or other confidentiality criteria)?

Good practice example: The Valuation Office published its procurement policy on its website, including guidelines, procedures, thresholds and information on etenders.gov.ie. 

FT5 Does the organisation disclose comprehensive information on contracts awarded?

Good practice example: The website of the Environmental Protection Authority had a Public Contracts Award Register updated on an quarterly basis, including contracts worth above €25,000 with a description of the contract, name of the contractor, start and end dates, and value.

FT6 Does the organisation disclose information regarding progress and payments of contracts awarded (including dates) on a regular basis?

Good practice example: Several of the organisations assessed in this study disclosed certain details of payments on a quarterly basis but none had published information on milestones, benchmarks and monitoring of procurement outcomes.

FT7 Does the organisation publish information on charitable donations and community contributions, including procedures, and reporting on those made?

Good practice example: ComReg's website carried a statement confirming that it does not make any charitable donations.

Open Governance

OG1 Has the organisation published comprehensive information about the relationship with the State and government?

Good practice example: Fáilte Ireland's 2020 annual report, which was available on the website, outlines its statutory basis and relationship with the relevant government minister: 

OG2 Has the organisation disclosed information on the composition of its board (or equivalent) and members’ profiles or, where there is no board, information on senior management?

Good practice example: Údarás na Gaeltachta had a webpage listing its board members with profiles for each one. An Garda Síochána, an example of an organisation without a board, included a page on its 'Senior Leadership Team', including members' profiles, on its website.

OG3 Has the organisation/body disclosed the rules by which its board makes decisions (where relevant) or its corporate governance framework or similar?

Good practice example: Teagasc's 2020 annual report, which was published on its website, contains details of the rules governing the board (p. 73 on) and confirms that the board has 'adopted the Code of Practice for the Governance of State Bodies (2016) and has put procedures in place to ensure compliance with the Code'. The Office of the Ombudsman, an example of an organisation without a board, had published its Corporate Governance Framework, which sets out the rules around decision-making and governance structures.

OG4 Does the organisation publish the minutes of its board meetings (or equivalent)?

Good practice example: The National Transport Authority had published board meeting minutes up to the quarter before this study was carried out on its website.

OG5 Do available documents indicate that the Audit & Risk Committee enjoys full operational independence?

Good practice example: CSO's Corporate Governance Standard, which was on its website, confirms the composition and independence of the Audit Committee.

OG6 Does the organisation have a comprehensive up-to-date page on its website dedicated to ethics and/or governance?

Good practice example: Bord Bia had a webpage on corporate governance, with links to the Code of Practice for the Governance of State Bodies, Bord Bia's code of conduct and material on protected disclosures, FoI, procurement etc.

Responsible Political Engagement

PE1 Does the organisation disclose information on regulation of lobbying?

Good practice example: The Valuation Office's website had a page on Regulation of Lobbying, including a list of DPOs and a link to lobbying.ie.

PE2 Has the organisation made information available on its funding or membership of think tanks or representative or lobby groups?

Good practice example: ComReg's website carried a statement confirming its membership of IBEC (Irish Business and Employers' Confederation). The Higher Education Authority published the following statement on its website: 'The HEA is not a member of any think tanks, lobbying or representative groups nor does it fund any'.

PE3 Does the organisation proactively publish the diary of the chief executive (or equivalent)?

Good practice example: The Central Bank had published the Governor's diary on an annual basis up to the last quarter of 2021. Board diaries had been published on the website of the Revenue Commissioners up to Q1 2022.

PE4 Does the organisation have a publicly available policy and procedures that manages ‘revolving door’ movements of directors and senior members of staff to and from public sector positions or roles elsewhere in the private sector?

Good practice example: The Higher Education Authority’s Code of Business Conduct, which was published on the website, includes an appendix setting out the policy on appointments after leaving the employment of the Higher Education Authority, where a potential conflict of interest may arise.

Whistleblowing Policies and Procedures

WB1 Has the organisation published a comprehensive protected disclosures policy and procedures, specifically including assurances to employees, contractors, subcontractors and suppliers, agents and other intermediaries that no penalisation or reprisal will result from whistleblowing?

Good practice example: The Land Development Agency had published its Protected Disclosures Policy on its website. The policy applies to ' current and former workers of the Agency whether permanent or temporary, retired workers, ex-workers, independent contractors, consultants, trainees and agency workers' (p. 5) and states that 'penalisation of employees who make a disclosure will not be tolerated' (p. 10).

WB2 Has the organisation disclosed details of internal and external channels available to workers who wish to make a protected disclosure?

Good practice example: The Land Development Agency’s internal whistleblowing policy, which was published on its website, outlines internal and external channels to make a protected disclosure.

WB3 Had the organisation published an annual report by 30 June detailing the number of protected disclosures made and actions taken the previous year?

Good practice example: Tusla publishes its protected disclosures annual reports on a dedicated page of its website, with details of the number of disclosures received and actions taken.

WB4 Has the organisation undertaken to train relevant staff on handling whistleblowing reports?

Good practice example: The Central Bank's whistleblowing policy, which was published on the Central Bank website, states that training on the policy will be given to the management teams of all divisions.