BACKGROUND AND DEVELOPMENT
The National Integrity Index 2022 – Public Sector Bodies, Part II builds on Transparency International’s ongoing work internationally to combat corruption and promote best practice in governance and transparency. The methodology is drawn from Transparency International’s Transparency in Corporate Reporting (TRAC) tool, which has been applied by Transparency International and TI national chapters in a variety of research projects since 2008. The TRAC approach aims to distill the elements of a robust anti-corruption system into a set of concrete indicators against which organisations’ transparency can be objectively measured. By adapting the indicators as appropriate, the methodology can be tailored to a particular sector or context and has been applied in TI studies on multi-national corporations, emerging-market multinationals, and the private sector in a particular country or region.
TI Ireland has adapted this methodology for use in its National Integrity Index studies carried out since 2018 on local authorities and the private and public sectors. In adapting the TRAC tool to the Irish context, TI Ireland has consulted international experts and examined applicable legislation on anti-corruption, lobbying and protected disclosures, as well as, in this instance, various guidelines governing public bodies. This study on public bodies assessed the selected organisations against 30 indicators in five categories, as follows:
- Anti-corruption and anti-bribery programmes (9 indicators)
- Financial transparency (7 indicators)
- Open governance (5 indicators)
- Responsible political engagement (5 indicators)
- Whistleblowing policies (4 indicators)
The rationale for focussing on these categories is outlined in Annex II and the scorecard template in Annex III lists each individual indicator and provides an explanation for its inclusion.
The aim of the TRAC approach is to assess proactive transparency. As such, data collection focussed on each organisation’s website, which is the primary channel of communication to stakeholders. The primary focus of the research was the information relevant to each indicator that organisations had actively made available through publication on their websites. Active disclosure of information was weighted more heavily in the scoring scheme than information subsequently submitted to TI Ireland but not published online.
It should be noted that this study did not evaluate any organisation’s actual performance in stopping corruption, and the scores are reflective of disclosure of relevant policies and procedures. The study has not assessed the implementation of policies or verified whether information disclosed on websites or in submissions is complete, correct or true. Verification of policies would require more extensive engagement and resources than the scope of the present study permitted. TI Ireland has therefore not evaluated any organisations’ actual performance in addressing corruption, and as such this report draws no conclusions, either positive or negative, in that regard. Transparency around certain policies, procedures and reports instead gives a picture of an organisation’s stated commitments to the controls required to guard against corruption and the measures they have in place to address it should it arise.
This report should also not be read as an evaluation of whether organisations have met their existing reporting and disclosure obligations under legislation or other guidelines. Although these have been taken into account in researching the context in which these organisations operate, and evidence of compliance or otherwise may have been found in gathering data, the objective of the study is to assess how the organisations’ transparency and stated preparedness to face corruption risks measure up against internationally recognised best practice. In many cases, this bar is higher than that set by existing legal obligations.
INITIAL ONLINE DATA COLLECTION
The online research phase for this second part of the public bodies index took place in April and May 2022. This involved searching each organisation’s website for material satisfying each of the 30 indicators, including statements on webpages, documents hosted on the website, and/or links to relevant material. Documents consulted included, inter alia, annual reports, codes of conduct, anti-corruption/anti-fraud policies, whistleblowing policies, protected disclosure annual reports, and corporate governance webpages. TI Ireland took all reasonable steps to obtain data pertinent to each indicator from the relevant website, including manual searches and consultation of site maps and footers, and use of website search functions as well as search engines. Links to relevant material were recorded, and copies of materials and screenshots saved where relevant.
CONSULTATION WITH ORGANISATIONS ASSESSED
A preliminary ‘scorecard’ (see template at Annex III) was tailored to each organisation assessed based on the data collected through initial online research. TI Ireland contacted each organisation by email to introduce the study and share the relevant preliminary scorecard. Email addresses that organisations had made available online were used to contact them. Organisations were invited to an online workshop presenting further information on the NII project and the indicators were also given the opportunity to discuss the research further by email or video/phone call by request.
The organisations were given two and half weeks to submit any feedback; in case, for instance, of a relevant document on the website having been overlooked during the online research phase, or to correct any errors of fact. They were also invited to publish on their websites any previously undisclosed documents satisfying the indicators, or to submit any relevant documents for consideration by TI Ireland that they had not made available publicly.
TI Ireland contacted all of the organisations assessed a number of times before the publication of this report. Ten of the organisations assessed did not respond to contact from TI Ireland during the research and feedback phases. Nonetheless, all of the organisations that were assessed were sent both preliminary and final versions of their scorecards and were given the opportunity to provide feedback before publication of this report. Organisations that made submissions to TI Ireland are identified on the ranking tables.
In respect of each of the 30 indicators:
- One point was awarded where information satisfying the requirements was available on/through the organisation’s website, either during the online research phase or before the feedback deadline.
- Half a point was awarded where the information on the organisation’s website partially satisfied the indicator, or where organisations submitted unpublished material satisfying the indicator to TI Ireland.
- A score of zero was assigned if no information satisfying the indicator was available, either via the relevant website or through disclosure to TI Ireland.
- ‘Not Applicable’ was entered against any indicator that did not apply to a particular organisation.
The overall score for each organisation is the sum of points converted to a percentage and rounded to the nearest whole number. In cases where an indicator was found not to apply to an organisation, the score awarded has been calculated on the basis of the number of remaining applicable indicators (e.g., 29 overall, or three rather than four in a particular category) and converted to a percentage on that basis. Organisations’ scores in each category are calculated on the same principle. The data collected and scores allocated have been checked for accuracy and consistency.
The ranking tables in this report (overall ranking, and rank in each of the five categories) list the organisations assessed by the final percentage achieved, from highest-scoring to lowest-scoring. Organisations with the same score have been assigned the same ranking, but the rank available to the next highest-scoring organisation(s) is based on the number of organisations at the previous rank, i.e., if four organisations are ranked in position 1, the next rank available is 5.