The tangible transformation of Bord na Móna to a Climate Solutions company is evidenced by the fact that 92% of all CapEx allocated in the financial year is deemed to be Taxonomy Eligible.

The EU taxonomy Regulation, which came into force on 12 July 2020, created the world’s first ‘green list’, a classification system for sustainable economic activities, establishing a common language for investors, companies and other stakeholders when assessing whether goods, services or infrastructural projects deliver a substantial positive impact for the climate and wider environment.

In June 2021 the EU Commission adopted the Climate Delegated Act establishing the criteria that define which activities substantially contribute to the ‘environmental objectives’ of Climate Mitigation and Climate Adaptation.   An ‘economic activity’ qualifies as Taxonomy-Eligible if listed in either Annex I or II of the Delegated Act and must meet the appropriate Technical Screening Criteria, do no significant harm to other environmental objectives and be in compliance with minimum social safeguards to qualify as Taxonomy-Aligned.

For reporting in 2022, the EU Taxonomy Regulation, and in particular the Delegated Regulation (EU) 2021/2178 enacted in July 2021, requires Key Performance Indicators (KPIs) to be disclosed relating to percentage of Capital Expenditure, Revenue and Operational Expenditure associated with Taxonomy- Eligible and Non-Eligible economic activities.  Bord na Móna is reporting these KPIs on a consolidated basis (thus avoiding any double counting) using the company’s existing financial systems.  It must be noted that the categorisation of Bord na Móna’s economic activities and the associated data does not perfectly overlap with the classifications listed in the Taxonomy legislation; Bord na Móna has therefore adapted a prudent and ‘reasonable endeavours’ approach in determining and reporting of the KPIs.  In addition, as this is the first year of reporting, and accepting that the Taxonomy legislation is still evolving, the reported KPIs are best estimates and the calculation methodology employed may itself evolve over time.

Capital Expenditure KPI

The tangible transformation of Bord na Móna to a Climate Solutions company is evidenced by the fact that 92% of all CapEx allocated in the financial year is deemed to be Taxonomy Eligible. The numerator used in the calculation contained CapEx associated with the construction of renewable and low carbon electricity assets as well as plant & equipment deployed in Bord na Móna’s Recycling business.

Operational Expenditure KPI

OpEx for the purposes of the Taxonomy Regulation is defined as non-capitalised costs that relate to research & development, building renovation measures, short-term leases, maintenance and repair, and any other direct expenditures relating to the day-to-day servicing of assets of property, plant and equipment.  Bord na Móna estimate 68% of the group’s spend on operational expenditure can be classified as Taxonomy Eligible.  The Taxonomy Eligible spend arises from maintenance of renewable energy assets and non-hazard waste collection and recovery equipment; while the maintenance of plant and equipment associated with Consumer Products and thermal generation stations was deemed non-eligible.

Revenue / Turnover KPI

At a consolidated level, Bord na Móna is reporting that 57% of Revenue can be attributed to Taxonomy Eligible activities.  These Eligible revenues flow primarily from the sale of renewable electricity and the provision of non-hazardous waste collection and recovery activities.  Revenues from Consumer Products were in the main deemed to be Taxonomy Non-Eligible.

As mentioned, the Taxonomy Turnover calculated was carried out at group level, and the accounting convention adapted resulted in certain ‘below the line’ revenues being excluded from both the numerator and denominator.  These ‘below the line’ revenues were generated from activities which in their own right are Taxonomy Eligible, including shared profits in Renewable Energy projects, and peatlands rehabilitation. If these ‘below the line’ revenues, together with other future ‘circular economy’ activities are included, the eligible taxonomy revenue, labelled  as Revenue* in the graphic below, is estimated at 71%. 

In addition, Bord na Móna has also calculated the company’s Taxonomy Eligible EBITDA, as a percentage of total EBITDA, at 74%.  While Taxonomy Eligible EBITA is not a required KPI under the Regulation, it is nonetheless an informative metric and provides further financial insight into Bord na Móna’s Taxonomy Eligible performance.

Table 1– Taxonomy KPIs for Bord na Móna plc

Bord Na Móna Plc is a public authority for the purposes of the European Communities (Access to Information on the Environment) Regulations 2007-2018 (the “AIE Regulations”).

What Can I Ask For?

Under the AIE Regulations you are entitled to request access to information on the
environment that is held by or for Bord Na Móna Plc. Environmental Information is defined in the AIE Regulations and determines what is available under the AIE Regulations.

What is the definition of Environmental Information?
“Environmental Information” means any information in written, visual, aural, electronic or any other material form on:

• the state of the elements of the environment, such as air and atmosphere, water, soil, land, landscape and natural sites including wetlands, coastal and marine areas, biological diversity and its components, including genetically modified organisms and the interaction among these elements;
• factors, such as substances, energy, noise, radiation or waste, including radioactive waste, emissions, discharges and other releases into the environment, affecting orlikely to affect the elements of the environment;
• measures (including administrative measures), such as policies, legislation, plans, programmes, environmental agreements, and activities affecting or likely to affect the elements and factors referred to in paragraphs (a) and (b) as well as measures or activities designed to protect those elements;
• reports on the implementation of environmental legislation;
• cost-benefit and other economic analyses and assumptions used within the framework of the measures and activities referred to in paragraph (c); and
• the state of human health and safety, including the contamination of the food chain, where relevant, conditions of human life, cultural sites and built structures in as much as they are, or may be, affected by the state of the elements of the environment referred to in paragraph (a) or, through those elements, by any of the matters referred to in paragraphs (b) and (c).

The AIE Regulations do not apply to Environmental Information that is required to be made available under any other statutory provision.

Please note that certain environmental information relating to Bord Na Móna Plc is already publicly available through the Environmental Protection Agency’s website www.epa.ie or requests can be made directly to the Environmental Protection Agency. Similarly, information submitted by Bord Na Móna Plc as part of the planning process is also publicly available through the relevant local authority’s website or An Bord Pleanála’s website www.pleanala.ie or by contacting the relevant bodies directly.

How to make an AIE request to Bord Na Móna Plc?

Write to: AIE Officer, Bord Na Móna Plc, Main Street, Newbridge, Co. Kildare or email:
informationofficer@bnm.ie
All requests should:

• be made in writing or electronic form;
• state that the request is made under the AIE Regulations;
• state your name, address and any other relevant contact details;
• state as specifically as possible, the environmental information that you require; and if you require access to the environmental information in a particular form or manner, specify the form or manner of access desired.

When a request is made to Bord Na Móna Plc under the AIE Regulations and the environmental information requested is not held by Bord Na Móna Plc and Bord Na Móna Plc believes that the information is or may be held by another Public Authority under the AIE Regulations, Bord Na Móna Plc will transfer your requests as soon as possible to the relevant Public Authority under Article 7(6) of the AIE Regulations. In these circumstances, you will be informed that your request has been transferred.

As provided for under the AIE Regulations, Bord Na Móna Plc will try to respond to your request as soon as possible. No later than one month after the receipt of your request we will either respond with a decision, notify you of the transfer of your request to another Public Authority or notify you that an extra month is required (as provided under the AIE Regulations) to deal with your request.

Do I have to pay?

No fee is charged for making of the request under the AIE Regulations. No fee is charged for the internal review process. However, Bord Na Móna Plc may charge a reasonable fee for supplying environmental information in accordance with the AIE Regulations.

Fees may be charged for the cost of supplying the information, including the staff costs associated with compiling, copying, printing and posting of the information. The charges will only relate to the supply of the information. Details of the charges, if any will be advised in the final decision letter.

If I’m denied access to information, can I appeal against the decision?

Yes. You may ask Bord Na Móna Plc for an internal review by a person unconnected with the original decision whose rank is the same as, or higher than that of the original decision-maker. Your request should be made within one month of receipt of notification of the decision. The internal reviewer will inform you of the result of the review within one month.

If you are not satisfied with the outcome of the internal review, you may ask the Commissioner for Environmental Information to review the matter. Your request for appeal must be made within one month of the date that notification of the internal review decision has been, or has required to be, notified to you.

Information Point

This website is an information point for the purpose of the AIE Regulations. If you require additional environmental information, you may send an AIE request or contact the information officer as outlined above.

Further information

Further general information on the AIE Regulations, including background information on the legislation, useful publications and links to other relevant bodies, is available in the AIE section of the website of the Department of the Environment, Community and Local Government www.environ.ie/en/Environment/AccesstoInformationontheEnvironment and on the Environmental Protection Agency’s website https://www.epa.ie/

Download a copy of our Code of Conduct Policy – Employees

http://www.bnm.ie/wp-content/uploads/2023/03/220913-BNM-Code-of-Conduct-Employees-2022-FINAL.pdf

Download a copy of our Code of Conduct Policy – Directors

http://www.bnm.ie/wp-content/uploads/2023/03/220921-BNM-Code-of-Conduct-Directors-2022-FINAL.pdf

The Board has overall responsibility for risk management including determining the nature and extent of significant risks that it is willing to accept in pursuit of its strategic and operational objectives. To address this, the Board has established a risk management system that provides for the continuous identification, assessment, implementation of mitigating actions and controls, and the monitoring and reporting of significant risks within Bord na Móna.

The Risk and Audit Committee (“RAC”) is responsible, under delegated authority, for assisting the Board in fulfilling its obligations with regard to assessing, reviewing and monitoring the risks inherent in the business and the control processes for managing such risks. The RAC is supported by an appointed Chief Risk Officer (“CRO”).

The CRO is responsible for overseeing the day to day risk management activities and has responsibility for ensuring that an effective risk management system, proportionate to the nature, scale and complexity of the Group is developed and maintained. Bord na Móna has an enterprise-wide risk management system that places a strong emphasis on strategic risks at a Group level (strategic risk register) and on strategic risks at the business level (business risk registers). In this risk management system, a strong focus is placed on managing risks that management can influence through the risk process as well as an emphasis on future action items and the responsibility for these is of key importance. Risk management is embedded in each business unit at an operating level.

The risk management system provides appropriate governance structures to support risk management practices, formal assignment of risk responsibilities throughout the Group and the procedures to be used, including relevant mitigation actions and controls.

The risk management system includes the following key elements:

• A risk strategy that includes objectives and principles;
• Two risk registers, a strategic risk register and business risk register;
• Assignment of clear mitigating action items and responsibilities for both the strategic risk register and the business risk register;
• A framework and reporting cycle to identify, assess, manage, monitor and report on the risks that Bord na Móna is or may be exposed to;
• A risk monitoring plan that outlines the review, challenge and oversight
  responsibilities of the CRO and the Management team;
• Reporting procedures that ensure that risk information is actively monitored, managed and appropriately communicated at all levels within Bord na Móna. The procedures outline the reporting responsibilities of management, the CRO, the RAC and the Board;
• Embed a strong risk management culture across all levels of the Group; and,
• Develop risk appetite statements in conjunction with the strategic risk process, then monitor and report on these statements.

Principal Risks

The principal risks which have the potential, in the short to medium term, to have a significant impact upon the Group’s strategic objectives are set out below. The Group has developed mitigation measures, to deal with these risks where appropriate.

The list of risks provided below is not exhaustive and will change over time. This represents the Board’s view of the principal risks at the date of this report.

1. Financial (Banking Facilities)
Risk and Impact: The risk of the failure to provide adequate banking facilities to meet refinancing and business needs and the failure to manage interest rate and foreign exchange exposure. It is vital that sufficient funding is provided at an appropriate cost to finance the strategic plan, maintain liquidity to meet future commitments and to provide contingency against unforeseen circumstances.

Mitigating Actions: Group treasury is responsible for the day to day treasury activities across the Group including the placing of specific derivatives. The Board has approved a treasury policy which defines how treasury activities are managed across the Group. The Group takes a risk averse position when deciding foreign exchange and interest rate policy. Certain natural economic hedges exist within the Group and the policy is to match and hedge the currencies across the businesses. In order to ensure stability of cash outflows and hence manage interest rate risk, the Group has a policy of maintaining at least 50 per cent of its long‑term debt at fixed rates. At 25 March 2020, the Group had €125 million of revolving credit facilities in place, none of which was drawn. In the past year, the Group has put non‑recourse project finance in place for wind farms which will become an important source of funding for the Group in the future. Financial instruments are used to manage interest rate and financial risk. The Group does not engage in speculative activity and the treasury operating policy is risk averse.

2. Operational (Climate)
Risk and Impact: The overall risk of the inherent uncertainty of various weather patterns on the operating and financial performance of the Group. These include the impact of mild weather on sales volumes during the winter on the Fuels business, the impact of wet springs on sales volumes in the Horticulture business, the financial impact of low wind yields on the wind farms in the Powergen business and the impact of wet summers affecting the level of peat harvested all impact Group profitability. The uncertainty of weather conditions presents a risk to profits generated by the Group.
Mitigating Actions: Developing a balanced portfolio of businesses has given the Group a “hedge” against any one adverse weather condition in a particular business. The Group has also developed contingency plans to protect profitability across the Group if a particularly adverse weather event occurs. It has worked with its employees and trade unions to develop a more flexible workforce.

3. Operational (Planning permission)
Risk and Impact: The risk of the Group not obtaining planning permission for a number of key infrastructural projects which are included in the strategic plan.
Mitigating Actions: The Group has an experienced management team that have a proven capability in planning, executing and delivering large infrastructure projects and has demonstrated the capability of doing so. A proven process is in place to ensure that all the necessary documentation and information is submitted to the relevant authorities with each planning application. In addition, the Group engages in extensive community consultation processes.

4. Operational (Health and Safety)
Risk and Impact: The risk of the failure to comply with health and safety legislation and policies due to a lack of enforcement across the Group, or management and employees not following the correct procedures or lack of training all leading to potential injury or death of an employee or damage to property resulting in financial sanction, financial loss and reputational damage.
Mitigating Actions: Detailed health and safety procedures are in place across the Group and these systems are operated based on the nature and the scale of the risks in each business. The Health and Safety department also carries out training of all staff and this is also augmented with external audits carried out by third parties. Insurance cover is maintained at Group level for all significant insurable risks and our insurer’s conduct extensive audits. The Group’s operations are subject to an increasingly stringent range of regulations and inspections and robust monitoring procedures have been designed to prevent a material breach of statutory or other regulatory obligations

5. Operational (Cyber Security)
Risk and Impact: The risk that the Bord na Móna information technology and, or banking systems are compromised due to being penetrated, hacked or attacked by external or internal parties which results in financial loss and reputational damage. Cyber security risk is now recognised as one of the fastest growing risks for organisations internationally.
Mitigating Actions: The Group has recognised the importance of managing this risk and continually reviews cyber security across the Group with internal and external expertise engaged. Investments in technology and people are made to maintain security around information technology systems to an appropriate standard.

6. Operational (General Electricity Pricing & Biomass and Carbon for Edenderry
Power station (EPL))
Risk and Impact: The risk of the non‑operation of the EPL due to the inability of Bord na Móna to source sufficient volumes of indigenous and imported biomass at commercially viable prices. The risk of the impact of high carbon pricing on the ability of the station to operate profitably. The risk of low power prices in the single electricity market and the adverse impact that these prices can have on the Group’s operating results. Each of these risks could result in significant financial loss to the Group.
Mitigating Actions: The Group has been very successful over the past number of years in sourcing biomass for EPL. A dedicated team has been established to source further indigenous biomass and develop a supply chain for imported biomass to supply EPL. This imported biomass will fill a demand while the market develops further indigenous biomass from the private forestry sector to mature and become available. Future carbon pricing is hedged forward on an annual basis and this along with the forward sale of power generated by the station gives certainty of margin. The Group operates a number of different electricity generating assets which utilise different fuels including biomass, wind, gas and peat. The Group has entered 15‑year power purchase agreements for a number of these plants which guarantee the price of power generated for those assets. The Group has consistently developed a diversified portfolio of generating assets to mitigate the risk associated with any one individual fuel. The Group recognises that high carbon pricing in conjunction with low electricity prices could have a serious impact on the profitability and future viability of EPL.

7. Operational (COVID‑19)
Risk and Impact: The risk of the impact of the Corona Virus pandemic on our businesses as a result of significant supply chain disruption, sickness/death of employees, loss of business, recession etc. The true economic impact of these events is not yet known but there is a risk that they will lead to significant financial loss and future implications for the Group.
Mitigating Actions: A cross functional management group has been established to deal with all the issues associated with the COVID‑19 pandemic. Additional investment has taken place on our I.T capability to enable most management and administrative staff to operate from home. Protective equipment has been purchased for staff in various businesses. Some operational equipment has been modified and additional resources deployed to ensure that work practices are safe.

8. Operational (Retaining and attracting staff)
Risk and Impact: The risk of the Group failing to retain, attract and develop the skills, talent and resources required to deliver its business plans, leading to a significant loss of knowledge and potentially gaps in the skill-sets required for delivering the Group strategy, all impacting on the attainment of strategic goals.
Mitigating Actions: The Group maintains a strong focus on this area and has structured succession planning programs in place along with management development programs. A graduate recruitment programme has been in place over the past few years. We are committed to providing quality employment opportunities and are investing in management development programs aimed at achieving greater diversity in senior positions throughout the Group.

9. Operational (New Business Growth)
Risk and Impact: The risk of the Group failing to develop new businesses, markets and infrastructure projects which it requires to replace its traditional businesses which are in decline. This could be due to a lack of management focus, human and financial capital, missed opportunities all leading to a decline in the Group scale, significantly reduced employment levels and financial loss.
Mitigating Actions: A detailed strategy has been approved by the Board for expanding further the new business areas across the Bord na Móna Group. The Group has put in place dedicated teams for business development across its three growth businesses which are Resource Recovery, Powergen Development and New Business. These cross functional teams incorporate engineering, finance, legal and project management. Significant financial capital has been committed to the further development of these existing businesses and the new business division. The Group looks at joint ventures also, as a means to bring in external expertise and share risk.

10. Regulatory (Regulatory/Political)
Risk and Impact: The risk of adverse regulatory changes and the impact that these may have on the financial and business model of the Group. Failure to comply could result in enforcement actions, legal liabilities, damage to the Group’s reputation and loss of shareholder support. Some of the important regulatory risks facing the Group are: the new regulations covering the movement and the extraction of peat, possible imposition of increased carbon taxes on peat briquettes; the trend towards the increased dilution of peat with non‑peat based materials in retail Horticulture products in the UK market; a new Integrated Single Electricity Market (I‑SEM) and the new auction process introduced for capacity payments for power plants; the changing regulatory landscape which is driving increased biomass usage in Edenderry Power station with resulting supply chain and cost implications. The ongoing uncertainty over BREXIT remains a macroeconomic threat to the markets the group operates in.
Mitigating Actions: When developing its strategic plan the Group ensures that plans to deal with the regulatory risks facing the businesses are developed and implemented where possible. Through innovation and supply chain developments, the Group continues to tackle regulatory change that is impacting on the operating performance of the businesses. Capital investment has been approved to address certain regulatory risks. In some cases when dealing with Regulatory risks the Group has no option but to accept these risks. The Group is actively managing any supply chain risks associated with Brexit.

On behalf of the Company, the Directors acknowledge the Board’s responsibility for ensuring that an effective system of internal controls is maintained and operated. This responsibility takes account of the requirements of the Code of Practice for the Governance of State Bodies (2016). The system of internal control is designed to manage risk to a tolerable level rather than to eliminate it. The system can therefore only provide reasonable but not absolute assurance that assets are safeguarded, transactions authorised and properly recorded and that material errors or irregularities are either prevented or detected in a timely way. The system of internal control, which accords with guidance issued by the Department of Public Expenditure and Reform has been in place in Bord na Móna for the period ended 29 March 2023 and up to the date of approval of the financial statements.

The principal procedures which have been put in place by the Board include:

• an organisation structure with clear operating and reporting procedures,
  authorisation limits, segregation of duties and delegated authorities;
• a code of conduct that requires all Directors and employees to maintain the highest ethical standards in conducting business;
• clearly defined management responsibilities have been established throughout the Group and the services of qualified personnel have been secured and duties properly allocated among them;
• a statement of decisions reserved to the Board;
• a risk management process which enables the identification and assessment of risks that could impact business performance and objectives and ensures that appropriate mitigation plans are formulated to minimise the residual risk;
• a comprehensive budgeting process for each business, Lean Centre and business services culminating in an annual Group budget approved by the Board;
• a comprehensive planning process for each business, Lean Centre and the business services culminating in an annual Group long‑term plan, approved by the Board;
• a comprehensive financial reporting system with actual performance against budget, prior year, forecasts, performance indicators and significant variances reported monthly to the Senior Leadership Team and Board;
• a set of policies and procedures relating to operational and financial controls including capital expenditure;
• a Protected Disclosures Policy to provide employees and others with a confidential means to report any fraud or ethical concerns;
• procedures for addressing the financial implications of major business risks, including financial instructions, delegation practices, and segregation of duties and these are supported by monitoring procedures;
• management at all levels are responsible for internal control over its respective business functions and provide annual management assurance statements; and
• procedures for monitoring the effectiveness of the internal control systems include the work of the Risk and Audit Committee, management reviews, the use of external consultants and Internal Audit.

Internal audit considers the Group’s control systems by examining financial controls, by testing the accuracy of transactions and by otherwise obtaining management’s assurance that the control systems are operating in accordance with the Group’s policies and control requirements. Internal audit report directly to the Risk and Audit Committee on the operation of internal controls and make recommendations on improvements to the control environment if appropriate. Where weaknesses in internal control systems have been identified action plans for strengthening them are put in place and regularly monitored until completed.

The Group has a framework in place to review the adequacy and monitor the effectiveness of internal controls covering financial, operational, risk management and compliance controls. Formal procedures have been established for monitoring control processes and control deficiencies are communicated to those responsible for taking corrective action and to management and the Board, where relevant, in a timely way.

The Directors confirm that the following ongoing monitoring systems are in place:

• key risks and related controls have been identified and processes have been put in place to monitor the operation of those key controls and report any identified deficiencies;
• reporting arrangements have been established at all levels where responsibility for financial management has been assigned; and
• there are regular reviews by senior management of periodic and annual performance and financial reports which indicate performance against budgets/forecasts.

The Directors confirm that Bord na Móna has procedures to monitor the effectiveness of its risk management and control procedures. Bord na Móna’s monitoring and review of the effectiveness of the system of internal control is informed by the work of the internal and external auditors, the Risk and Audit Committee which oversees their work, and the Senior Leadership Team within Bord na Móna responsible for the development and maintenance of the internal control framework.

The Directors confirm that the Board conducted an annual review of the effectiveness of the internal controls for the period ended 25 March 2020 and up to the date of approval of the financial statements.

The process used to review the effectiveness of the system of internal controls includes:

• review and consideration of the internal audit work programme and consideration of its reports and findings;
• review of the regular reporting from internal audit on the status of the internal control environment and the status of recommendations raised previously from their own reports and reports from the external auditor;
• review of reports from the external auditor which contain details of any material internal control issues identified by them in their work as auditors; and,
• review of the risk register reports, the counter measures in place to mitigate the risk, the remaining residual risk and actions required or being taken to further mitigate the risks.

No material weaknesses in internal control were identified in relation to the reporting period that require disclosure in the financial statements.

As outlined in the Bord na Móna Codes of Conduct, Bord na Móna Plc or any of its subsidiaries and affiliates (the “Group”) is committed to conducting its affairs with openness, honesty and integrity. An important aspect of integrity and transparency is the creation of a workplace culture that encourages the making of protected disclosures, provides protection for disclosures and adopts a mechanism to enable all Workers (which includes employees, contractors, agency workers, trainees, volunteers, directors, shareholders, recruits, tenderers) in the Group to voice concerns, in confidence, in a responsible and effective manner.
It is the duty of all Workers in the Group to safeguard all Group assets in the normal course of their work. However, all organisations face the risk that certain Workers may engage in conduct that, for instance, violates the law, regulations or the policies of the organisation itself.Workers may be concerned that by reporting, or cooperating in investigations of potential misconduct they will be opening themselves up to victimisation, detriment or risking job security.

The Group’s Protected Disclosures Policy is designed to inform Workers of their right to make a Protected Disclosure, being a disclosure of Relevant Information which, in the reasonable belief of the Worker, tends to show one or more Relevant Wrongdoings and which came to the attention of the Worker in a Work-Related Context (a “Protected Disclosure”). A Worker who makes a Protected Disclosure will not be penalised by Bord na Móna, even if the concerns or disclosures turn out to be unfounded.

The Protected Disclosures Policy complies with the provisions of the Protected Disclosures Act 2014 and the Protected Disclosures (Amendment) Act 2022 (the “Acts”), and best practice outlined in the Interim Guidance for Public Bodies and Prescribed Persons. The Protected Disclosures Policy contains details of the internal reporting channels and procedures that are in place.

This Policy is intended to assist Workers who reasonably believe they have discovered a Relevant Wrongdoing in a Work-Related Context.
It aims to:
➢ Foster a culture of openness and honest communication;
➢ Ensure the attainment of objectives set out in the Code of Conduct;
➢ Ensure full compliance with all legal, regulatory and other requirements, and
➢ Provide a mechanism to uphold the integrity of all Workers.

Protected Disclosures Reports
Section 22 of the Protected Disclosures Act 2014 requires the publication of a report each year relating to the number of protected disclosures made in the preceding year and any actions taken in response to such disclosures. The latest years reports follow:

Protected Disclosures Annual Report 2024

Bord na Móna received no Protected Disclosure reports in the year ended 31 December 2024. There are no Protected Disclosure investigations opened in the years preceding 2024 which remain open as of the date of this report. In compliance with its statutory obligation under Section 22(1) of the Protected Disclosures Act Bord na Móna will report to the Minister for Public Expenditure, NDP Delivery and Reform in the require format in respect of the year 2023. Bord na Móna has in in place internal reporting channels.  External reporting channels are also available.

Protected Disclosures Annual Report 2023

Bord na Móna received one Protected Disclosure report in the year ended 31 December 2023 (the “Report”).

The Report was received through Bord na Mona’s internal Protected Disclosure procedure.

The Report was the subject of an initial assessment by Bord na Móna in relation to the alleged relevant wrongdoings concerned. Further investigation was recommended under another Group Policy in relation to one of the alleged relevant wrongdoings, that investigation is continuing as of the date of this report.

None of the Reports received have been, as of the date hereof, determined to concern a ‘breach’ within the meaning of section 3(1) of the Protected Disclosures Act 2014 (the “Act”).

There are no Protected Disclosure investigations opened in the years preceding 2023 which remain open as of the date of this report.

In compliance with its statutory obligation under Section 22(1) of the Protected Disclosures Act Bord na Móna will report to the Minister for Public Expenditure, NDP Delivery and Reform in the require format in respect of the year 2023.

Bord na Móna has in in place internal reporting channels.  External reporting channels are also available.

Proposed Protected Disclosures Annual Report 2022
Bord na Móna received 2 protected disclosures in the year ended 31 December 2022. The disclosures were reported and assessed in accordance with our Protected Disclosures Policy. The disclosures did not proceed to full investigation. Each of the disclosures have been closed and where recommendations for improvement were made, appropriate actions have been agreed.

Protected Disclosures Annual Report 2021

Bord na Móna received 2 anonymous protected disclosures in the year ended 31 December 2021. The disclosures were reported and assessed in accordance with our Protected Disclosures Policy. Only one disclosure proceeded to full investigation. The result of that investigation was that no evidence of wrongdoing was found regarding one element of the disclosure and a consultancy review was performed as a result. Each of the disclosures have been closed and where recommendations for improvement were made by Internal Audit, appropriate actions have been agreed.

Protected Disclosures Annual Report 2020

Section 22 of the Protected Disclosures Act 2014 requires the publication of a report each year relating to the number of protected disclosures made in the preceding year and any actions taken in response to such disclosures.

Bord na Móna received 5 anonymous protected disclosures in the year ended 31 December 2020.  The disclosures were reported and assessed in accordance with our Protected Disclosures Policy. Only one disclosure proceeded to full investigation. The result of that investigation was that no evidence of wrongdoing was shown. Each of the disclosures have been closed and, where recommendations for improvement were made by Internal Audit, appropriate actions have been agreed.

Protected Disclosures Annual Report 2019
Bord na Móna received 2 protected disclosures in the year ended 31 December 2019. The disclosures were reported and assessed, and investigated where required, in accordance with our Protected Disclosures Policy. Both disclosures have been closed and, where required, appropriate actions have been agreed.

Protected Disclosures Annual Report 2018
Bord na Móna received 2 protected disclosures in the year ended 31 December 2018. The disclosures were reported and assessed, and investigated where required, in accordance with our Protected Disclosures Policy. Both disclosures have been closed and, where required, appropriate actions have been agreed.

Protected Disclosures Annual Report 2017
No protected disclosures were received by Bord na Móna in the year ended 31 December
2017.

The Irish Human Rights and Equality Commission Act 2014 introduces a positive duty on public bodies to have due regard to human rights and equality issues. This is a legal obligation and is contained in Section 42 of the Act.

Section 42 (1) states: A public body shall, in the performance of its functions, have regard to the need to:

• Eliminate discrimination;
• Promote equality of opportunity and treatment of its staff and the persons to whom it provides services; and
• Protect the human rights of its members, staff, and the persons to whom it provides services.

The objectives and functions of Bord na Móna align directly with the promotion of equality and the protection of human rights including freedom of expression, the protection of minors, accessibility and disability equality, the right to privacy, the right to an effective remedy, the right to education, and the right to protection from discrimination. The promotion of equality and a wide range of human rights are therefore at the heart of our work and reflected in our organisational values of fairness, independence, expertise, and accountability. Bord na Móna is committed to an inclusive culture of respect, dignity, equality, and fairness in how we engage with the public, our stakeholders and between our staff.

In addition to Codes of Conduct for Directors and Employees, and the company’s adherence to the Code of Practice for the Governance of State Bodies, Bord na Móna has also developed an array of policies, plans and actions that cut across the protection and enhancement of human rights for staff, stakeholders and workers in the company’s value chain. Taking cognisance of the Employment Equality Act 1998 (as amended) and the Equal Status Act 2000 (as amended), these policies, plans and actions include but are not limited to Bord na Móna’s Equal Opportunities & Dignity at Work Policy; Equality, Diversity and Inclusion Policy; Gender Identity Policy; Reasonable Accommodation and Disability Policy; Modern Slavery Statement; Protective Disclosures Procedures; and Anti-Bribery, Corruption and Fraud policy.

To give effect and to comply with Section 42(2) of the Human Rights and Equality Act 2014 Bord na Móna has conducted an assessment of the human rights and equality issues it believes to be relevant to its functions and purposes.  Three discrete stakeholder categories have been identified where potential human rights and equality issues could arise.  Commensurate with each stakeholder category, policies, plans and actions are in place (or planned to be) to address the potential human rights and equality issues that could subsequently arise in each of the categories identified in the assessment.

Bord na Móna reports annually on its website (which is accessible to the public) on developments and achievements in respect of policies, plans and actions in place or proposed to be in place to address issues identified in its assessment of Human Rights and Equality issues. The Bord na Móna Annual Report also references these developments and achievements.

Specifically, in terms of reporting, as per the requirements of Section 42(2) of the Act,  Bord na Móna has detailed the developments and achievements in the area of human rights and equality issues during the last financial year, FY24, in its FY24 Sustainability Update across pages 22 – 25.  In addition, Bord na Móna’s CEO Mr Tom Donnellan, committed the organisation to the Ten Principles of the UN Global Compact in August 2024.  These Ten Principles are derived from: the Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, and the United Nations Convention Against Corruption.