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Data Protection Commission
Anti-Corruption and Anti-Bribery Programmes
Has the organisation made a public commitment against corruption and bribery?
Has the senior management and the board (where applicable) publicly shown support against corruption and bribery?
Has the organisation published a risk-based anti-corruption and anti-bribery programme?
Does the organisation require specific adherence to its programmes against corruption and bribery by all its directors (or equivalent) and employees?
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?
Has the organisation disclosed details of an anti-corruption training programme for its employees and directors?
Has the organisation disclosed a policy and procedures on gifts, hospitality and expenses?
Has the organisation disclosed a policy and procedures on conflict of interests?
Has the organisation undertaken to exercise mandatory, properly documented, risk-based anti-corruption due diligence on third parties before entering a contract or transaction?
Has the organisation published audited financial statements for 2020, including information on annual revenues?
Has the organisation/body made the annual budget and budget commentary for 2022 available online?
Has the organisation disclosed a procedure to ensure asset disposal follows a transparent process and is in accordance with market values?
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)?
Does the organisation disclose comprehensive information on contracts awarded?
Does the organisation disclose information regarding progress and payments of contracts awarded (including dates) on a regular basis?
Does the organisation publish information on charitable donations and community contributions, including procedures, and reporting on those made?
Has the organisation published comprehensive information about the relationship with the State and government?
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?
Has the organisation/body disclosed the rules by which its board makes decisions (where relevant) or its corporate governance framework or similar?
Does the organisation publish the minutes of its board meetings (or equivalent)?
Do available documents indicate that the Audit & Risk Committee enjoys full operational independence?
Does the organisation have a comprehensive up-to-date page on its website dedicated to ethics and/or governance?
Responsible Political Engagement
Does the organisation disclose information on regulation of lobbying?
Has the organisation made information available on its funding or membership of think tanks or representative or lobby groups?
Does the organisation proactively publish the diary of the chief executive (or equivalent)?
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?
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?
Has the organisation disclosed details of internal and external channels available to workers who wish to make a protected disclosure?
Had the organisation published an annual report by 30 June detailing the number of protected disclosures made and actions taken the previous year?
Has the organisation undertaken to train relevant staff on handling whistleblowing reports?