Mr. Seamus McCarthy:

There was compliance with the rules of the scheme, in general, but there were some exceptions that related to the rules requiring disclosures to be made or sanction to be obtained. Those would be the key things. The bodies were making the decisions and making the payments without reference to any outside agency, but they were making them within the terms of the schemes that were in place, by and large. The individual circumstances of each payment should have been explained to the Department of Public Expenditure and Reform so that it was aware that the payment was being made and was able to satisfy itself that those circumstances were appropriate. I am not trying to suggest that there is complete laxity in the scheme around this. The difficulty we had with the code of practice as it stood in 2009 was that it was relatively unspecific about how severance payments should be dealt with. One category of payment, across a very broad spectrum, was dealt with in the code. We felt agencies were having to make these decisions without having enough guidance to ensure that there would be consistency in the approach in all Departments and agencies.