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Good Practice Guide

Set out below are examples of good practices in connection with each of the indicators.


AC1 - Has the organisation made a public commitment against corruption and bribery? ESB's Code of Ethics which was available online, states 'We never tolerate bribery or corruption in any form'. ESB's Anti-Bribery, Corruption and Fraud Policy, which was also available online, states 'We have a zero-tolerance policy in relation to bribery, corruption, fraud and other wrongdoing'.
AC2 - Has the senior management and the Board publicly shown support against corruption and bribery? VHI's 2020 Annual Report, which was available online, contains a Directors' Report with a section headed 'Bribery and Corruption' which notes commitments against 'fraud, corruption, bribery and blackmail' and is signed by the Chairperson and a director.
AC3 - Has the organisation published a risk-based anti-corruption and anti-bribery programme? Ervia's Anti-Bribery and Anti-Corruption Policy, published online, outlines various corruption risks, procedures to mitigate against these, and roles and responsibilities. It also provides details on training, reporting, and enforcement.
AC4 - Does the organisation require specific adherence to its programmes against corruption and bribery by all its directors and employees? Ervia's Anti-Bribery and Anti-Corruption Policy, which was available online, states that it applies to 'all Board members and employees of Ervia, including consultants, contractors, volunteers, trainees, work experience students, interns, part-time, full-time, casual workers and agency workers and anyone with whom Ervia may deal directly or indirectly through supply chain activities'.
AC5 - Does the board undertake to monitor the anti-corruption programme for its suitability, adequacy and effectiveness, taking into acccount the results of risks assessments, and implements reviews/improvements as appropriate? ESB's Anti-Bribery, Corruption and Fraud Policy, which was available online, notes that the Board is responsible for 'reviewing the procedures for preventing and detecting fraud' and 'reviewing and monitoring the systems and controls for the prevention of bribery and corruption', complemented by other functions within the company, e.g. management, which is responsible for 'considering exposure to [bribery, corruption and fraud risks] and implementing initiatives to enhance risk management effectiveness'.
AC6 - Has the organisation disclosed details of an anti-corruption training programme for its employees and directors? Ervia's Anti-Bribery and Anti-Corruption Policy, which was available online, includes a specific section on training, noting that 'All employees are required to participate in anti-bribery and anti-corruption training, read communications, use resources and consult where necessary to stay informed about the laws, professional standards and policies that apply to their work'.
AC7 - Has the organisation disclosed a policy and procedures on gifts, hospitality and expenses? CIÉ's Code of Conduct for Employees which was available online, states that employees should 'avoid the giving or receiving of corporate gifts [etc.] which might affect or appear to affect... an independent judgment on business transactions'. The Code includes extensive Guidelines Regarding Gifts or Hospitality, including thresholds and procedures for reporting. The Code of Conduct for Board Members and Directors, which was also available online, includes similar guidelines but also prohibits the acceptance of 'corporate gifts from suppliers or contractors who have worked for the CIE Group'.
AC8 - Has the organisation disclosed a policy and procedures on conflict of interests? DCU's Conflict of Interest Policy which was available online, stating that staff 'should disclose any activity if they suspect it could be perceived as a conflict of interest'. The policy outlines examples of potential conflicts and the procedure for disclosing, managing and recording conflicts of interest. Reports are stored centrally by the Chief Operations Officer.
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? Ervia's Anti-Bribery and Anti-Corruption Policy, which was available online, stipulates that employees 'doing business through consultants, intermediaries, subcontractors, distributors, partners, agents or other third parties must ensure that such parties comply with the rules set out in this Policy' and requires that employees 'be vigilant in monitoring the activities of third parties on an ongoing basis'. This includes requiring that 'all parties tendering... provide detailed company information in order to enable proper assessment of the company and individuals involved' before entering a contract, and that the terms and conditions allow for Ervia to carry out audits thereafter to ensure adherence to policies.
FT1 - Has the organisation published audited financial statements for 2020, including information on annual revenues? Bord na Móna's financial statements for the year ending 31 March 2021 were published online on 21 July 2021.
FT2 - Does the organisation/body make the annual budget and budget commentary for 2021 available online? Greyhound Racing Ireland had published detailed figures and commentary regarding its 2021 budget on its website.
FT3 - Had the organisation disclosed a procedure to ensure asset disposals follow a transparent process and are in accordance with market values? Dublin Port Company’s Procurement Policy, which it shared with TI Ireland, includes asset disposal procedures to ensure market value is achieved. Dublin Port Company also shared a Code of Ethics specific to asset disposal (and procurement), outlining standards in respect of conflicts of interest, gifts, hospitality and sponsorship. TI Ireland recommends that these documents be published online.
FT4 - Does the organisation disclose comprehensive information on its procurement policy and procedures on its website (with the exception of information that is legally protected for reasons such as national security, the protection of intellectual property or other confidentiality criteria)? University College Cork had a dedicated webpage with a range of procurement policies including its purchasing policy and procedures as well as a procurement strategy available on its website.
FT5 - Does the organisation disclose comprehensive information on contracts awarded? The Personal Injuries Assessment Board had published quarterly reports on payments/purchase orders and contracts awarded on its website, under Financial Information and Procurement.
FT6 - Does the organisation disclose information regarding progress and payments of contracts awarded (including dates) on a regular basis? None of the organisations assessed met this indicator. Good practice recommendations from the OECD (II.ii) provide guidelines on providing free, online access to information on procurement performance, including benchmarks and monitoring.
FT7 - Does the organisation publish information on charitable donations and community contributions, including procedures, and reporting on those made? Ervia's subsidiaries Irish Water and Gas Networks Ireland both published funding and sponsorship details including recipients, years and amounts on their websites, under ‘Funding and Sponsorship of Non-Public Bodies’.
OG1 - Has the organisation published comprehensive information about the operational relationship with the state ownership entity and disclosed details of its fully consolidated subsidiaries and other joint ventures and associated undertakings? An Post's website outlined its relationship to the Ministers for Public Expenditure and Reform and Communications, Climate Action and Environment. The website provided links to certain subsidiaries and joint ventures. Further, comprehensive information on subsidiaries and joint ventures was available in An Post's 2020 Annual Report, which was available online.
OG2 - Has the organisation disclosed information on the composition of its Board and Board members’ profiles? VHI had a webpage listing the members of its board, alongside their profiles.
OG3 - Has the organisation/body disclosed the rules by which the Board of Directors operates on its website? The rules by which Trinity College Dublin's Governing Authority operates are set out in the Trinity College Dublin Code of Governance, which was available online.
OG4 - Do available documents indicate that the Audit & Risk Committee enjoys full operational independence? daa's 2020 Annual Report states that the Audit and Risk Committee 'held meetings without management present and also met privately with both the external and internal auditors'. The two members of the Audit and Risk Committee are named, and are both independent, non-executive board members. The report also confirms that daa complies in all material aspects with the Code of Practice for the Governance of State Bodies, which includes rules on Audit and Risk Committee composition/independence.
OG5 - Does the organisation have a comprehensive up-to-date page on its website dedicated to ethics and/or governance? Shannon Foynes Port Company had a dedicated Corporate Governance webpage with links to annual reports, codes of conduct, protected disclosure information and other policies.


PE1 - Does the organisation 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)? None of the organisations assessed met this indicator. An example of good practice elsewhere is SSE Airtricity’s Group Political and Regulatory Engagement Policy.

PE2 - Does the organisation disclose information on its lobbying activities? Ervia had published details of its returns under the Regulation of Lobbying Act 2015 on its website. See under ‘Regulation of Lobbying Act’.

PE3 - Are those employed or contracted to lobby on behalf of the organisation periodically informed about and/or trained on the organisation’s responsible political engagement policies and procedures, and required to adhere to this? Ervia had a standalone lobbying policy available online, which 'applies to all Board Members and employees of Ervia including consultants, contractors, volunteers, trainees, work experience students, interns, part-time, full-time, casual workers and agency workers' and with which all must comply. The policy notes that each division's Compliance Officer is responsible for 'promoting awareness of lobbying and the requirements of the [Lobbying] Act' within her/his division.

PE4 - Does the organisation publish details of the organisations/associations of which it is a member that lobby on behalf of member organisations? Dublin Airport, a subsidiary of daa, featured a list of interest groups (among other agencies) with which it is involved on its website.

PE5 - 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? None of the organisations assessed met this indicator. An example of good practice may be found under PE5 on the NII Private Sector 2020 scorecard for the Irish Times.
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? NUI Galway had a Protected Disclosure Policy available online. The policy extended to 'any employee, or any person who works or worked under contract for the University, agency workers for the University, and any individuals provided with work experience by the University' and stated that NIUG 'shall not tolerate or permit any form of detrimental treatment' of a whistleblower.

WB2 - Did the organisation disclose details of internal and external channels available to report wrongdoing? RTÉ's Code of Conduct for staff, which was available online, outlines channels for making a protected disclosure, including contact details for a 'confidential reporting line operated by an independent company, Safecall'.

WB3 - Had the organisation published an annual report detailing the number of protected disclosures made and actions taken in the preceding year by 30 June? University of Limerick had published its Annual Protected Disclosures Report for 2020, dated 30 June 2021, on its website. This covered the period from 1 January to 31 December 2020 and gave details of a number of disclosures received and actions taken in response.
WB4 - Had the company undertaken to train relevant staff on handling whistleblowing reports? Dublin Port Company's Protected Disclosures Policy, which was available online, states that 'The Company will ensure that the Internal Confidential Recipients [of protected disclosures] receive appropriate training to deal with the Disclosure Policy, procedures and issues that might arise as a result thereof'.