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Indicators
Anticorruption
AC1
Has the organisation made a public commitment against corruption and bribery?
Explanation:
Publicly committing to a zero-tolerance stance on bribery and corruption is an important aspect of an organisation’s communication of its ethical standards to external stakeholders, including contractors and the public, and bolsters an internal organisational culture of integrity. Various Transparency International anti-bribery and anti-corruption guides advise that organisations make public commitments against corruption and bribery, for example, both guidelines No. 5 of ‘Business Principles for Countering Bribery: A Multi-Stakeholder Initiative led by Transparency International’ and No. 5 of TI’s ‘State-Owned Enterprise Healthcheck’.
To receive a point:
A specific commitment to a zero-tolerance stance on bribery and corruption was available through the organisation’s website, either posted on a webpage or published in corporate governance documents/publications such as annual reports and stakeholder relations material.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided TI Ireland researchers with documentary evidence that this commitment to a zero-tolerance approach to bribery and corruption specifically had been made in documents available internally.
AC2
Has the senior management and the board (where applicable) publicly shown support against corruption and bribery?
Explanation:
The ‘tone from the top’ is a critical driver of an organisation’s anti-corruption programme. It demonstrates a high-level commitment to the organisation’s anti-corruption efforts, which builds staff confidence in implementing the organisation’s anti-corruption measures and provides reassurance that acting in line with anti-corruption policies and procedures will be supported.
To receive a point:
A statement from the board (or equivalent) or senior management making a commitment to support measures against corruption and bribery, and/or evidence that a senior executive or similar has responsibility for the anti-corruption and anti-bribery programme, was available through the organisation’s website (either posted on a webpage or published in corporate governance documents/publications such as annual reports and investor relations materials).
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence that relevant material available internally demonstrated high-level support for the anti-corruption and anti-bribery programme.
AC3
Has the organisation published a risk-based anti-corruption and anti-bribery programme?
Explanation:
A publicly available anti-bribery and anti-corruption programme, with concrete provisions for controls and monitoring, gives substance to an anti-corruption and anti-bribery commitment. Such a programme should articulate clearly and in detail all the organisation’s anti-corruption efforts, including its values and detailed policies and procedures around governance, risk management, internal and external communications, training and guidance, advice and whistleblowing channels, internal accounting controls, monitoring, evaluation and improvement efforts.
To receive a point:
A comprehensive anti-corruption and anti-bribery programme was available through the organisation’s website and included details of how it is monitored. (The programme may form part of an overall risk management plan or code of conduct but must contain concrete provisions sufficiently addressing corruption and bribery risks specifically).
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided TI Ireland researchers with documentary evidence that an anti-corruption and anti-bribery programme meeting the criteria outlined was in place.
AC4
Does the organisation require specific adherence to its programmes against corruption and bribery by all its directors (or equivalent) and employees?
Explanation:
By explicitly requiring all employees and directors (or their equivalents) to adhere to its anti-corruption and anti-bribery programme, an organisation makes clear that it expects compliance at all levels and in all activities and transactions, regardless of scale. This requirement sends a strong message about the organisation’s commitment to embedding a culture of ethics and integrity throughout the organisation.
To receive a point:
The organisation included a specific requirement that all employees and directors adhere to its anti-corruption and anti-bribery programme in relevant material available through its website.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided TI Ireland researchers with documentary evidence showing that relevant material available internally required employees’ and directors’ adherence to an anti-corruption and anti-bribery programme.
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?
Explanation:
The anti-corruption context is dynamic, with, on the one hand, changing levels and types of corruption risk and, on the other, increasing expectations around corporate integrity and more stringent regulations on activities. A commitment to ongoing monitoring of an anti-corruption programme, based on internal and external reviews and risk assessments, provides confidence that an organisation takes these issues seriously and is prepared to face new challenges with up-to-date, effective measures.
To receive a point:
Information published by the organisation outlined how the anti-corruption programme is monitored and reviewed for effectiveness in countering evolving corruption risks on a regular basis.
To receive 0.5 points:
The organisation was either partially compliant with the indicator, or provided TI Ireland researchers with documentary evidence showing that material available internally outlined procedures for the regular monitoring and review of the anti-corruption programme.
AC6
Has the organisation disclosed details of an anti-corruption training programme for its employees and directors?
Explanation:
Training on an organisation’s anti-corruption and anti-bribery programme is a key means of communicating corruption risks and procedures to guard against them to staff. To foster an anti-corruption culture that is responsive to changing circumstances, this training should be delivered periodically (annually or biannually), either internally or externally. Given resource constraints, it may not be practicable to give all staff in-depth training. In such cases, TI Ireland recommends incorporating a risk profile assessment to the process of providing training to employees.
To receive a point:
The organisation made details of an anti-corruption and anti-bribery training programme for its employees and directors (or equivalent), or a specific reference to its implementation, available through its website.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland that the organisation had in place a training programme on countering corruption and bribery for management and relevant staff.
AC7
Has the organisation disclosed a policy and procedures on gifts, hospitality and expenses?
Explanation:
Although often a legitimate aspect of relationship-building and business courtesy, gifts, hospitality and expenses can also be used to circumvent prohibitions against bribes and corruption and to gain undue competitive advantage or favours. A policy and procedures prohibiting the offering, giving, soliciting or receiving of gifts or other benefits where they could influence, or reasonably be perceived to influence, transactions or activities is therefore an important aspect of an organisation’s anti-corruption and anti-bribery measures. This should set out appropriate thresholds and approval processes to ensure that gifts are legitimate, and outline consequences for non-compliance. Such a policy not only provides guidance for employees but, when publicly disclosed, demonstrates to bidders and other stakeholders that the highest standards of probity are expected and enforced.
To receive a point:
The organisation had published on its website a policy and procedures to ensure that gifts, hospitality and expenses are reasonable and legitimate and prohibiting the offering, giving, soliciting or receiving of gifts, hospitality or expenses whenever they could influence, or could reasonably be perceived to influence, the outcome of transactions or activities.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland that it has in place an internally circulated policy and procedures to prevent corruption through the use of gifts, hospitality and expenses.
AC8
Has the organisation disclosed a policy and procedures on conflict of interests?
Explanation:
The impact of conflicts of interest, and perceived conflicts of interest, is particularly significant where any aspect of the public interest is at stake. Having a policy that defines conflicts of interest and procedures to identify, declare and manage them can provide direction to employees and others; protect an organisation’s reputation; ensure compliance with legislation; and reinforce stakeholder and public trust.
To receive a point:
The organisation had published a policy and procedures outlining how conflicts of interest are managed on its website.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland that it had in place an internally circulated policy and procedures to manage conflicts of interest.
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?
Explanation:
Third parties engaged to carry out activities on behalf of, or to provide services or goods to, the public and State sector may not always be bound by to the same high standards and these transactions can present a corruption risk due to opportunities for money laundering, manipulation of bids, false invoicing or kickbacks. All organisations should have in place procedures to carry out thorough, transparent due diligence on contracted third parties to ensure that their anti-corruption standards and controls are sufficiently robust, and to safeguard against any corruption vulnerabilities.
To receive a point:
The organisation must have published details of its due diligence measures in respect of third-party contracts/transactions on its website.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland that it had in place sufficiently robust third-party due diligence measures.
Financial Transparency
FT1
Has the organisation published audited financial statements for 2020, including information on annual revenues?
Explanation:
As noted by the Code of Practice for the Governance of State Bodies (p. 31), ‘The publication of an annual report and audited financial statements is a primary expression of public accountability’, which holds true across all sectors and organisations. Audited financial statements are an important tool for stakeholders, including the public, to monitor the organisations’ activities, both in terms of their commitment to furthering the public interest and, where relevant, their use of public funds. Although the Office of the Comptroller and Auditor General publishes accounts for bodies within its remit, organisations should also publish or link to these in the interests of making the information readily accessible to interested parties. Where feasible, the accounts can be published as part of the organisation’s annual report.
To receive a point:
The organisation must have published its audited financial statements for 2020 on its website.
To receive 0.5 points:
The organisation was partially compliant with the indicator.
FT2
Has the organisation/body made the annual budget and budget commentary for 2022 available online?
Explanation:
Budget transparency is critical to enabling the public to see that public resources and, where relevant, public funds are being managed in the public interest. In addition to budget figures themselves, supporting commentary provides vital context as to the aims and objectives of the organisation. The publication of budget details also provides a benchmark against which stakeholders can monitor actual performance and any deviation from planned expenditure.
To receive a point:
The organisation’s budget and budget commentary for this financial year must have been available via its website.
To receive 0.5 points:
The organisation was partially compliant with the indicator.
FT3
Has the organisation disclosed a procedure to ensure asset disposal follows a transparent process and is in accordance with market values?
Explanation:
Asset disposal can pose a high corruption risk to all kinds of public sector and State bodies. Values may be manipulated and assets bought or sold at non-market values to favour officials’ associates or officials themselves. Bribes and benefits may be offered to officials, politicians or political parties with perceived influence over transactions. Any perception of such activities erodes public trust in institutions and enterprises that are supposed to be handled for the public good. This perception and the risks themselves can be countered by implementing a robust and transparent set of procedures around asset disposal, including requirements for rigorous business cases, ringfencing of functions, due diligence on interested parties, and independent monitoring and review.
To receive a point:
The organisation must have published on its website a detailed procedure outlining how asset disposal is handled and protected from corrupt intervention.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland that it had in place an internally circulated procedure on prevention of corruption in asset disposal.
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)?
Explanation:
Procurement carries a significant corruption risk, with the possibility of bribes and kickbacks offered to officials and politicians to award inflated tenders or overlook siphoning of funds. The costs of corruption in procurement are not only financial: It can mean reduced quality and sustainability and poor value in the goods and services delivered, all of which erodes public confidence in institutions. Public sector and State bodies should proactively disclose their public procurement procedures so that all stakeholders, from bidders to members of the public, can have confidence that the mechanisms in place for selecting contractors and suppliers are legitimate and conform to requirements and good practice. In line with this, the organisation should publicise forthcoming opportunities, including details of the tendering procedure, transparently and in good time. Such practice indicates that it is committed to open competition and equal treatment of potential bidders. At a minimum, the website should direct those seeking information to details on how to access tendering documents, the timeline of the procedure and relevant contact information.
To receive a point:
The organisation must have published a comprehensive procurement policy and procedures on its website.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland that it had in place a procurement policy and procedures that meets the criteria outlined.
FT5
Does the organisation disclose comprehensive information on contracts awarded?
Explanation:
As well as being transparent about procedures at the tendering stage, public and State bodies should subsequently disclose details of contracts awarded, including information such as the name of the contractor, the value of the contract, date awarded, signing date, delivery timeline/milestones, and a public version of the contract itself, insofar as possible given commercial sensitivities. This allows stakeholders to scrutinise procurement procedures and their outcomes in a concrete way and to identify the ultimate beneficiaries of public contracts.
To receive a point:
The organisation must have published, through its website, detailed information on contracts awarded.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland of contracts awarded.
FT6
Does the organisation disclose information regarding progress and payments of contracts awarded (including dates) on a regular basis?
Explanation:
Transparency regarding tendering procedures and contracts awarded, as outlined in respect of indicators FT4 and FT5, allows for public accountability at the tendering and awarding stages, but disclosing information on progress and payments made allows stakeholders to monitor the actual performance of contractors and demonstrates accountability through to the completion of a project. The OECD Recommendation on Public Procurement states that there should be free, online access not only to procurement regulations, tenders, and award announcements, but also to information on the performance of the public procurement system, such as benchmarks and monitoring of results.
To receive a point:
The organisation must have published on its website information on the progress of contracts awarded, including dates for milestones and deliverables and details of payments made, including amounts and dates.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland regarding the progress of contracts awarded.
FT7
Does the organisation publish information on charitable donations and community contributions, including procedures, and reporting on those made?
Explanation:
Charitable donations and community contributions, although often a legitimate and important aspect of corporate social responsibility, can be used as a means of bypassing prohibitions on contributions to gain undue advantages. To guard against such activities, or the perception of such activities, all semi-state and public sector organisations should publicly disclose any charitable contributions and sponsorships. Although this information is sometimes given in narrative or aggregate format in annual reports or dedicated webpages, a specific data table detailing specific charitable donations and/or community contributions provides greater transparency and concrete information.
To receive a point:
The organisation must have disclosed on its website specific data on its charitable donations and/or community contributions.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland of its charitable donations and/or community contributions.
Open Governance
OG1
Has the organisation published comprehensive information about the relationship with the State and government?
Explanation:
There should be clarity regarding structures of ownership and relationships between institutions and organisations. The more opaque these structures are, the less the organisation’s stakeholders are able to hold it to account. Public and State bodies should therefore disclose details of their respective relationships with the State, e.g. the government minister or department under which they operate; funding etc.
To receive a point:
The organisation must have disclosed on its website details regarding the nature of its relationship and interactions with the State government.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland.
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?
Explanation:
Most fundamentally, the public should know who is serving on the board of an organisation, as well as relevant details of each member’s background and affiliations. In Beyond the Balance Sheet: IFC Toolkit for Disclosure and Transparency, the World Bank Group’s International Finance Group recommends that organisations ‘concisely present the relevant work experience, education, and other board positions currently held by each board member’, emphasising elements ‘that are particularly relevant in their board roles’. This allows stakeholders to assess whether there may be any conflicts of interest but equally can be an opportunity to provide assurances that board members are suitably qualified. The IFC advises that best practice is to link each board members skills to the functions of the board and the ‘wider strategy and purpose’ of the organisation (p. 62). Where an organisation does not have a board or some equivalent, senior management should be similarly identified.
To receive a point:
The organisation must have disclosed on its website the names and relevant background details of each board member (or equivalent) or members of senior management.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland of the composition of its board (or equivalent) or similar information on senior management.
OG3
Has the organisation/body disclosed the rules by which its board makes decisions (where relevant) or its corporate governance framework or similar?
Explanation:
All public and State bodies should be operated in accordance with the highest standards of governance and with procedures in place to ensure effective and responsible management of the organisation’s affairs in the public interest. They should be transparent about the rules governing decision-making, to demonstrate public accountability, appropriate autonomy, and a commitment to ethical practices.
To receive a point:
The organisation must have disclosed the rules governing high-level decision-making on its website.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland of the rules that were in effect at that time.
OG4
Does the organisation publish the minutes of its board meetings (or equivalent)?
Explanation:
Publication of minutes of the meetings of the organisation’s board (or equivalent) provides transparency around its high-level decision-making and is an important channel through which to communicate the rationale behind decisions to stakeholders.
To receive a point:
The organisation must have published minutes of the meetings of its board (or equivalent) up to the last quarter.
To receive 0.5 points:
The organisation was partially compliant with the indicator.
OG5
Do available documents indicate that the Audit & Risk Committee enjoys full operational independence?
Explanation:
The credibility of an Audit and Risk Committee as a safeguard against corruption and other misconduct in an organisation’s operations rests on its independence from the executive functions of the organisation. The Audit and Risk Committee should be sufficiently independent to be able to challenge management and highlight corruption risks and other deficiencies or vulnerabilities, without the interference (or perception of interference) of any conflicting allegiance or interest. For instance, the Code of Practice for the Governance of State Bodies stipulates that the Audit and Risk Committee should be composed of ‘at least three independent non-executive board members, or in the case of smaller State bodies (less than 20 employees) two independent non-executive board members’. For organisations that do not have a board, analogous arrangements should be put in place to ensure independence.
To receive a point:
The organisation must have disclosed through its website sufficient details regarding the composition of the Audit and Risk Committee (or equivalent) to indicate that enjoys operational independence.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland that it had at that time measures in place to ensure the independence of the Audit and Risk Committee (or equivalent).
OG6
Does the organisation have a comprehensive up-to-date page on its website dedicated to ethics and/or governance?
Explanation:
Transparency means not just making information available but making it readily available to the average person, who may not have the frame of reference or expertise to search for information among a wide range of documents and online locations. A dedicated webpage that shows how the organisation operates, including its procedures and policies, reports, Code of Conduct etc., is not only valuable for external stakeholders, but is a useful resource for the organisation’s own people, as well as a clear statement of the organisation’s commitment to transparency and high ethical standards.
To receive a point:
The organisation must have had a page dedicated to ethics or governance as part of its website.
To receive 0.5 points:
The organisation was partially compliant with the indicator.
Political Engagement
PE1
Does the organisation disclose information on regulation of lobbying?
Explanation:
Many of the organisations assessed for this index have designated public officials (DPOs), i.e., high-level officials who may be lobbied as defined by the Regulation of Lobbying Act 2015. Section 6(4) of the Lobbying Act requires each public body to which it is relevant to publish a list of designated public officials of the body. The Standards in Public Office Commission, which is the lobbying regulator, has requested that all such organisations ‘create a dedicated page entitled “Regulation of Lobbying” [...] in the “About Us” section of their website’, include a link on this page to lobbying.ie (the online register of lobbying), and ‘publish and maintain [...] an up-to-date list of the organisation’s DPOs’.
To receive a point:
The organisation had a Regulation of Lobbying webpage including a link to the lobbying register and a list of DPOs.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence of its lobbying activities to TI Ireland.
PE2
Has the organisation made information available on its funding or membership of think tanks or representative or lobby groups?
Explanation:
Think tanks and representative/lobby groups typically seek to advance certain positions on policy matters and may engage in lobbying as defined under the Regulation of Lobbying Act 2015. All organisations should disclose whether they are affiliated with any such bodies or confirm that they have no such affiliations.
To receive a point:
The organisation had disclosed on its website details of its funding or membership of any think tanks or representative/lobby groups or confirmed that it has no such affiliations.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or subsequently provided relevant documentary evidence to TI Ireland.
PE3
Does the organisation proactively publish the diary of the chief executive (or equivalent)?
Explanation:
The Department of Public Expenditure and Reform’s FOI Model Publication Scheme recommends the publication of ministerial diaries with details of events and meetings attended. This allows the public to see which groups and individuals are communicating with the Minister and to gain an insight into access and potential influence on decision-making. Although chief executives (or the equivalent) of public bodies are not required to publish their diaries, this is best practice in terms of transparency and public accountability.
To receive a point:
The organisation had disclosed on its website the chief executive’s diary for the previous month or quarter.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland that the chief executive’s diary is made available.
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?
Explanation:
In the public sector, there may be movement between the organisation and the State administration, or movement between the organisation and the private sector. In either case, procedures should be put in place to avoid actual or perceived conflicts of interest and to prevent an individual from leveraging her previous position and access to the untoward advantage of any party. These may include ‘cooling-off’ periods or provisions prohibiting the relevant individual from working on projects that overlap with previous roles. Although the relevant provisions of the Civil Service Code of Standards and Behaviour may apply, organisations should have a policy and procedures in place showing how these are applied.
To receive a point:
The organisation had disclosed on its website a policy and procedures in place to manage revolving-door movements.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland that there was an internal policy and procedures managing revolving-door movements.
Whistleblowing
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?
Explanation:
Transparency International defines whistleblowing as ‘the disclosure of information related to corrupt, illegal, fraudulent or hazardous activities being committed in or by public or private sector organisations – which are of concern to or threaten the public interest – to individuals or entities believed to be able to effect action’ (A Best Practice Guide for Whistleblowing Legislation, 2018). Whistleblowers are invaluable in exposing corruption, fraud and mismanagement, but blowing the whistle can carry personal and professional risks. The organisation’s whistleblowing policy should therefore, inter alia, include assurances that whistleblowers will not suffer penalisation of any kind as a result of raising concerns in the workplace and that action will be taken in response to those concerns where warranted, as well as information on their rights and responsibilities consistent with Irish law. In particular, organisations should take care not to link protections for whistleblowers to a ‘good faith’ requirement. Although the Protected Disclosures Act 2014 requires that a person making a protected disclosure have a ‘reasonable belief’ that it is true, the term ‘good faith’ is distinct and is not used in the legislation. ‘Good faith’ has been interpreted in case law as referring to a person’s motivation, which the Act states is irrelevant.
To receive a point:
The organisation had publicly disclosed on its website a whistleblowing policy that covers all employees and relevant third parties and undertakes to protect whistleblowers from any reprisal for speaking up.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland researchers that a whistleblowing policy meeting the criteria was in place internally.
WB2
Has the organisation disclosed details of internal and external channels available to workers who wish to make a protected disclosure?
Explanation:
Placing the burden on a concerned party to judge which internal reporting channel is most appropriate, or requiring that contact first be made with another section of the organisation to receive contact details, may have a chilling effect on the making of protected disclosures. Whistleblowing policies should therefore provide information on the channels available to report wrongdoing. Furthermore, details of how to discuss protected disclosures through external channels (including contact details), which is allowed for under the Act (‘a procedure the use of which by the worker is authorised by the worker’s employer’), shows a real commitment to facilitating the reporting of concerns. Sharing details of internal and external channels publicly should ensure that relevant third parties, contractors etc. have access to the necessary details. It also demonstrates that an organisation actively encourages a culture where the highest ethical standards are prioritised.
To receive a point:
The organisation had publicly disclosed on its website details of internal and external channels available to make protected disclosures.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland researchers that information on channels available to make protected disclosures was available internally.
WB3
Had the organisation published an annual report by 30 June detailing the number of protected disclosures made and actions taken the previous year?
Explanation:
Whistleblowing policies should commit to taking appropriate action in response to concerns raised, demonstrating that the organisation takes reports seriously and will not brush legitimate concerns under the carpet. One aspect of transparency in this area is the annual report on protected disclosures that is required under the Protected Disclosures Act 2014. Recording and disclosing the number of reports and actions taken in response to them, as outlined in Section 22 of the Act, provides an objective measure of an organisation’s willingness to act on information received through whistleblowing.
To receive a point:
The organisation had publicly disclosed on its website by 30 June an annual report on the number of protected disclosures received and actions taken during the preceding year, as required under Section 22 of the Protected Disclosures Act 2014.
To receive 0.5 points:
The organisation was either partially compliant with the indicator or provided documentary evidence to TI Ireland researchers that it had kept statistics on protected disclosures received and action taken during the preceding year.
WB4
Has the organisation undertaken to train relevant staff on handling whistleblowing reports?
Explanation:
Organisations should train relevant staff on the receipt, investigation and handling of whistleblowing reports. Such a training programme should be delivered regularly, either internally or externally, and ideally be tailored to accommodate different lines of business within the organisation.
To receive a point:
The organisation had disclosed on its website 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 organisation was either partially compliant with the indicator or provided documentary evidence to 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.