Transparency and independence
Working in part with the company yet needing to remain at
arms-length is part of the CCG process. It is particularly important
that we remain independent and ward against company ‘capture’.
Independence and accountability
The Group has taken/is taking a number of steps to ensure and
strengthen our own independence and accountability:
These include but are not limited to:
Recruiting an independent Chair and require all members to act
Setting and controlling our own agenda in liaison with South East
Holding private sessions when company representatives are not
present – every meeting has a private session and in addition we
hold full private sessions when assessing the company’s
- The Group maintain an up to date
Terms of Reference
agreed with the company.
Declaration of Interests Policy, a set part of the agenda to declare any conflicts and a
Register of Interests.
Publishing the costs of the CCG
We developed this independent website separate from South East
Keeping a Challenge Log.
recruitment processes and members’ tenure to
ensure the right balance between continuity of expertise and fresh
independent perspectives. This includes ensuring a maximum tenure
of members of two price controls (unless they are a statutory
Membership was last refreshed in 2020.
The introduction of an independence statement at the beginning of
each meeting to remind expert members that there are not
representatives of the organisations they work for in their role
on the CCG.
Seek to hear views from a wide variety of South East Water
employees at all levels.
There is a formal requirement in the Code of Conduct for members to raise if they have a concern about a colleagues independence.
Going forward we have a particular focus on ensuring a wider range
of voices are heard by the CCG e.g. external presentations to the
Group, and hope to build closer relationships with regulators and
external stakeholders that can provide ongoing independent views and
information on company performance.
The processes we adopt are in our
Terms of References.
Improving CCG efficiency and effectiveness
Following the submission of the Group’s
independent assurance report to Ofwat in 2018
the CCG reviewed its effectiveness and carried out a range
of lessons learned activity. This included a desk-based review of other CCGs’
activity and approaches in other sectors; an independent survey of CCG members
and South East Water staff to understand where they believed improvements could be made,
carried out by Creative Sensemaking; reviewed the findings of a cross-CCG Chairs
survey; and held a workshop facilitated by the latter to discuss findings and
recommendations. This was translated into a Challenge Group Improvement Action
Plan by a dedicated working group, which was approved by the whole CCG and South East Water
and was implemented 2019-2021.
We made a number of changes in 2019/20 as part of our Improvement Action Plan:
Introduced a 15 minute slot at the end of all main CCG meetings where both
South East Water and CCG members give views on what we think went well/could be improved
from the meeting and this is applied to our work going forward. We also score
the meeting out of ten to provide a consistent ‘touch point’ (though in practice
expectations rise as improvements are made).
Worked hard with South East Water to improve the quality of presentations, strategic framing and
background material provided to the CCG so as to maximise our effectiveness.
The CCG now pre-specifies areas of interest for each topic under consideration at a main
CCG meeting, with questions raised on circulation of papers, and a meeting focus on issues
and solutions through themed discussions. This has been a very positive change to working
methodology, which can be enhanced in future by having a detailed (and consistent) review
We also took steps to strengthen our audit trail and information management. This included
setting up a shared workspace for the CCG (on Huddle); improvements to the Challenge Log, a
separate Action Log; written feedback to the company following CCG meetings, and separate pre-meeting
We also developed CCG effectiveness criteria in 2019. We review our progress against this framework once
a year. This criteria was based on a model developed by KPMG for Northern Gas Grid’s Customer Engagement
Group. Our thanks to NGN’s Customer Engagement Group Chair for sharing this.
We are also exploring how we can best assess, capture and communicate impact.