CCG PR24 Assurance Role
Ofwat has set an expectation that water companies’ business plans for 2025-30 and long-term delivery strategies reflect the needs, priorities and preferences of their current and future customers and the communities they serve.
To support this expectation, Ofwat developed Standards for high-quality research, customer challenge and assurance of the quality and use of customer and stakeholder engagement evidence.
South East Water’s existing expert Customer Challenge Group was asked by the Company’s board to provide independent, robust, transparent, expert, and comprehensive assurance on:
The quality of the company’s customer and wider stakeholder engagement, as judged against Ofwat’s Standards for high-quality engagement and research. This includes whether its consumer and stakeholder insight is of sufficient quality; and
The use of the company’s engagement evidence – notably does SEW have a meaningful understanding of what is important to its current and future customers and wider stakeholders, and have those diverse views and needs been taken account of in its decision-making and proposals.
The CCG’s final independent research and engagement assurance report, which outlines our conclusions, was provided to South East Water’s Board on 18th of September 2023.
Based on the information shared with the CCG as of 14th September (the cut off point for receipt of evidence), the CCG partially assured Part 1.We were not able to provide full assurance due to the lack of evidence provided and as some engagement was still in progress or had not been reported to the CCG.
The CCG did not assure Part 2 as we had not seen a draft of the Business Plan (BP) (only four very early draft chapters within it), nor any draft of the Long-term Delivery Strategy (LTDS). However we provided feedback to the company and the board based on what we had been able to review. The company continued to develop its business plan (BP), LTDS and accompanying documentation beyond this date.
Please note the CCG did not provide an independent challenge and scrutiny role on the business plan proposals themselves and the Long-term Delivery Strategy as we did not have visibility of the business plan and LTDS prior to publication.
Our assurance activity – how we worked
To perform our assurance role (as distinct from our independent challenge role)the CCG developed an eight staged assurance process (see below) jointly with SEW.
The CCG’s assurance process is outlined in our Assurance Framework Overview. The supporting questions for each assurance stage are here.
A dedicated Engagement Sub-Group was set up to review the design and delivery of the company’s engagement against Ofwat’s high-quality standards for research and engagement. In addition the approach to triangulation and insight capture and analysis.
The full CCG was expected to review the overall quality of the company’s consumer and stakeholder evidence base, once it was developed, and the degree to which customer and wider stakeholder needs and views were reflected in the business plan and long-term delivery strategy.
The Sub-group was designed to include individuals with expertise and experience in quantitative and qualitative research, community and stakeholder engagement; behaviour change and insights. The Chair of the Engagement Sub-group is Helen Fleming and the members are Rachel Lopata, Zoe McLeod, Penny Shepherd and Leslie Sopp.
The scope of the group is outlined in the Terms of Reference. Members reviewed and provided feedback on the company’s proposed research and engagement design, materials and delivery. This included observing engagement.
The Sub-group developed an approach to prioritisation of its work in order to ensure we focus on areas where engagement has the biggest impact and importance for customers, communities and wider stakeholders.
The CCG interpretation of best practice triangulation is here.
Our approach to the Standard ‘neutrally designed’ and bias is outlined here.
Reports to the South East Water Board on company progress are outlined below and in the main CCG feedback notes.
Progress reports
The CCG’s final and interim reports were provided to the company’s board to support their assurance process. They have not been published by South East Water.
Not all stages of the agreed process were able to be completed due to lack of available evidence and time constraints.
Stage 1: Overarching strategy and processes - engagement assurance assessment report
Stage 2: Application of strategy and processes - engagement assessment report
Stage 3: Prioritisation report
Stage 3 & 4: Design and delivery - incomplete (assessment shared with SEW board)
Stage 5: Triangulation – The CCG’s conclusions on the triangulation process are in the final assurance report submitted to SEW.
Stage 6: Review of insight captured and application of triangulation process – incomplete. The following CCG feedback notes provide our views based on evidence provided as of 14th September 2023:
Water quality
Environment
Net zero/sustainable business
Water resources
Water efficiency
Resilience
Retail
Stage 7: Application of insight in the business plan and LTDS- incomplete
Stage 8: CCG research and engagement assurance report – complete and provided to the SEW Board.
Acceptability and affordability testing - CCG observations. Conclusions on quality of A&AT in the final report to SEW's board.