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Background and development  

The National Integrity Index (NII) 2021, on semi-states and public universities, 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 distil the elements of a robust anti-corruption system into a set of concrete indicators against which organisations’ performance 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 used also used this tool in its NII studies on local authorities (2018, 2019) and the private sector (2020).

As the aim of the TRAC approach is to assess proactive transparency, the primary focus in this study was relevant information actively made available by each organisation. As such, data collection focussed on each organisation’s website, which is the primary channel of communication to stakeholders. Subsequently, organisations were also offered the opportunity to review the data collected and to supplement this by submitting documentation. This recognises that responding to stakeholder queries is also an important aspect of transparency. Active disclosure of information was weighted more heavily in the scoring scheme than information subsequently submitted, as outlined in this section of the report in connection with scoring.  

Data collection

The online research phase took place in July 2021. 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 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. Information or documents subsequently published on an organisation’s website did not qualify as having been available during the online research phase.


The research assessed the selected bodies against 30 indicators in five categories, as follows:

  1. Anti-corruption and anti-bribery programmes (9 indicators)
  2. Financial transparency (7 indicators)
  3. Open governance (5 indicators)
  4. Responsible political engagement (5 indicators)
  5. Whistleblowing policies (4 indicators)

In respect of each indicator:

  • One point was awarded where information satisfying the requirements was available on/through the organisation’s website during the online research phase (July 2021).  
  • Half a point was awarded where the information available during the online research phase partially satisfied the indicator or where the organisation subsequently provided documentary evidence to TI Ireland demonstrating that internal measures satisfying the indicator were in place at that time (see details of engagement with organisations assessed for further details).
  • 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.

As there were 30 indicators, the maximum score possible was 30 points. In most cases, the overall score for each organisation is the sum of points received out of 30, converted to a percentage and rounded to the nearest whole number. Similarly, the score in each category is the percentage of available points in that category that the organisations achieved. In cases where certain indicators were 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., 28 overall, or three rather than five in a particular category) and converted to a percentage on that basis. The data collected and scores allocated have been cross-checked for accuracy and consistency.  

The ranking tables (overall ranking, and rank in each of the five categories) rank the organisations assessed by the percentage achieved. 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.

Engagement with organisations assessed  

A preliminary scorecard was tailored to each organisation assessed, based on the data collected during the online research phase and the scoring scheme outlined here. TI Ireland contacted each organisation by email on 10 September 2021 to introduce the study and share the relevant preliminary scorecard. All organisations were invited to an online workshop presenting further information on the NII project and the indicators on 24 September, and organisations were also given the opportunity to discuss the research further by email or video/phone call by request.

An initial deadline of 1 October was set for organisations 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. In any such instances, the relevant score was revised to 1. They were also invited to submit any relevant documents for consideration by TI Ireland that they had not made available publicly. In such cases, where material was relevant to an indicator, the score was revised to 0.5. At the request of some organisations, the submission deadline for all was extended to 6 October.  

Some of the organisations assessed did not respond to contact from TI Ireland at any stage, and others acknowledged correspondence but declined to engage with the study, as outlined in Section 2. Nonetheless, all of the organisations that were assessed received second, updated versions of their scorecards later in October 2021 and were given a further opportunity to provide feedback on their scorecards before publication.