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The Irish Times DAC
Does the company have a publicly stated commitment against corruption and bribery?
Does the company state publicly that it will comply with all legislation including those related to anti-corruption?
Does the senior management and board demonstrate support against corruption and bribery?
Does the company have a risk-based anti-corruption and anti-bribery programme that is regularly monitored?
Does the company require specific adherence to its programmes against corruption and bribery by all its directors and employees?
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?
Does the company have in place a risk-based anti-corruption and anti-bribery training programme for its employees and directors?
Does the company have a policy and procedures for gifts, hospitality and expenses?
Does the company have a publicly available procedure for the management of conflicts of interest including interest declarations?
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?
Organisational Structures Transparency Rating:6.00
Does the company disclose a full list, including names of its fully and non-fully consolidated subsidiaries?
Does the company disclose a full list of names and details of percentages owned of each of its fully and non-fully consolidated subsidiaries?
Does the company disclose the countries of incorporation of its fully and non-fully consolidated subsidiaries?
Does the company disclose the countries of operation of its fully and non-fully consolidated subsidiaries?
Does the company disclose its revenues/sales in Ireland and other countries it operates?
Does the company disclose its capital expenditure in Ireland and other countries it operates?
Does the company disclose its corporate taxes paid in Ireland and other countries it operates?
Does the company disclose its charitable donations and community contributions made in Ireland and other countries it operates?
Responsible Political Engagement Rating:0.50
Does the company have a publicly available policy and procedures on responsible corporate political activities (including lobbying; the funding of political think-thanks; revolving doors and the prohibition of political contributions whether made directly or indirectly)?
Does the company disclose full details of its expenditures on lobbying (including payments to third parties to lobby on their behalf) made in Ireland and other countries it operates?
Are those employed or contracted to lobby on behalf of the company periodically informed and/or trained on the company’s responsible political engagement policies and procedures, and required to adhere to this?
Does the company publish full information on its lobbying positions and the topics/policy positions on which it engages?
Does the company publicly disclose how it monitors its corporate political activities and the steps it takes to correct non-compliant behaviour by its staff, contractors or agents?
Does the company have a publicly available policy or standards on party political neutrality?
Does the company 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?
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?
Does the company proactively communicate the availability of internal and external advice and whistleblowing reporting channels for staff, contractors and third parties?
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?
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?
Does the company train relevant staff on how to handle whistleblowing reports?