Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...

 
Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
Bristol Water’s
Assurance Plan
2019/2020
Information for our customers and stakeholders on our
approach to assurance and on ensuring the data and
information we report and publish on is reliable and accurate.
Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
CONTENTS

Executive Summary...........................................................................................................................................2

Introduction..........................................................................................................................................................5

1. About Bristol Water..........................................................................................................................................5

2. About this document – Our Assurance Plan........................................................................................6

3. Regulatory Requirements.............................................................................................................................9

Our approach to assurance.............................................................................................................................12

4. Taking into Account Regulatory, Stakeholder and Customer Feedback....................................12

5. Targeted Assurance Activities..................................................................................................................15

What this means for our Customers and Stakeholders........................................................................34

6. Governance, Oversight & Culture............................................................................................................34

7. Assurance in the Round.............................................................................................................................35

8. Our Promise – How we propose to move out of Prescribed Assurance......................................37

Glossary...............................................................................................................................................................38

Appendix 1 – Independent Assurance.......................................................................................................40

Appendix 2 – Data Items’ Risk Assessments..........................................................................................43

Appendix 3 – Company Monitoring Framework Assessment 2018................................................49
Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
EXECUTIVE SUMMARY
This document is Bristol Water’s Assurance Plan, which sets out our
approach to assurance of the information that we will publish during
2019/20. The purpose of our Assurance Plan is to give customers and
others with an interest in our business (known as stakeholders) trust
and confidence in our data and in how we use this data to report on
our performance. It covers all the key information that Bristol Water
reports and publishes throughout 2019/20. This includes information
reported for regulatory purposes and that produced for the benefit
of customers.
OVERVIEW                                        Bristol Water takes the trust and     • We have updated the interactive
                                                confidence of customers and           performance graphic on our
                                                stakeholders in our data very         website, to include information
                                                seriously. It is our intention        included in the mid-year
                                                that by publishing transparent,       performance report, as well
                                                accurate and reliable information,    as adding information on our
                                                through the processes set out in      customers’ average bill.
                                                our Assurance Plan, that we will
                                                demonstrate compliance with           • We have continued to ‘dual
                                                our assurance requirements. Our       report’ our leakage performance,
                                                ambition is to ensure that all of     and its impact on per capita
                                                the information we communicate        consumption for 2015-20 so the
                                                externally is assured to be           impact of technical improvements
                                                accurate, timely, appropriate         to the way leakage is calculated
                                                for the intended audience and         is transparent. Our mid-year
                                                transparent. Changes that we have     performance report included this
                                                made to deliver on this ambition      data for the first half of 2018/19.
                                                within the past year include:
                                                                                      • Our tariff and charges
                                                • We have again published a           publications (particularly for new
                                                mid-year performance report1.         connections charges) now include
                                                This provides an update on            more customer-friendly language
                                                performance for a number of data      and user-friendly graphics, to
                                                items, comparative information        improve their readability for
                                                on our performance and forecasts      interested parties. Our Statement
                                                of our future performance, (we will   of Assurance2 on our tariffs also
                                                also follow this approach for our     now includes an engagement
                                                annual performance reporting), as     summary section, setting out the
                                                well as:                              organisations we have consulted
                                                                                      and what changes we have made
                                                1. A statement from our Chief         to the information we present as a
                                                Executive Officer;                    result.
                                                2. A statement from the Bristol
                                                Water Challenge Panel;                • Improvements to the format
                                                3. A statement from our               and contents of our Annual
                                                independent technical assurer,        Performance Report and
                                                Atkins, that our description          Data Assurance Summary,
                                                of performance is fair and            which makes it easier for our
                                                reasonable.                           customers and stakeholders

1
    Bristol Water Mid-Year Performance Report 2018/19
2
    Charges in Detail

                                                                 2
Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
to find information, so that                                    This document provides the following
our performance against our
Assurance Plan is transparent.
                                                                                                The targeted areas of
                                                            An overview of the                  assurance that were
• In addition to the Risk &                               companies’ assurance
Compliance Statement, our                                                                    identified in our Statement
                                                          methods and processes.               of Risks, Strengths and
Board is also committed to
publishing our ‘Trust beyond                                                                    Weaknesses exercise.
water’ statement, which goes
beyond the legal and statutory
commitments. The statement
reflects on the Board’s views                                                                An update on feedback we
                                                          Our plans for addressing
on our operational and                                                                        have received from our
                                                          the risks in the targeted
financial performance,                                                                      customers and stakeholders
                                                            areas of assurance.
assurance activities and long-                                                                on our assurance plans.
term strategy.

This document should be read in conjunction with the Statement of Risks, Strengths and Weaknesses of
Information 2018/193.

ASSURANCE PLAN                                 This Assurance Plan covers             backed dashboard designed to
                                               information reported within:           provide accessible comparative
                                                                                      information for customers and
                                               1. 2018/19 Annual Performance          stakeholders
                                               Report (including our regulatory
                                               accounts and our 2015-2020             We have undertaken an internal
                                               performance commitments) and           risk assessment to determine
                                               2019/20 Mid-Year Performance           which data items we report on in
                                               Report                                 the documents and sources in the
                                               2. 2018/19 Annual Report               list above are at risk of inaccurate
                                               (including our statutory accounts)     reporting. Since the publication
                                               3. 2020/21 Wholesale and Retail        of these risk assessments in our
                                               Charges Schedule, Charging             Statement of Risks, Strengths
                                               Arrangements and Charges               and Weaknesses of Information
                                               Schemes                                consultation in November
                                               4. 2018/19 Guaranteed Standards        2018 we have now reviewed
                                               Scheme (GSS) payments                  our assessments and provided
                                               5. Data on New Connections             and updated view as part of
                                               performance                            this Assurance Plan. We have
                                               6. Complaints reporting to             therefore identified fifteen (15)
                                               CCWater                                data items that require targeted
                                               7. Water quality information           assurance activities throughout
                                               provided to the Drinking Water         the year ahead.
                                               Inspectorate
                                               8. Information provided to             Our detailed risk assessment
                                               the Environment Agency                 methodology can be found in our
                                               (including our Water Resources         Statement of Risks, Strengths
                                               Management Plan and Market             and Weaknesses of Information
                                               Information)                           document. However, in summary,
                                               9. Data reporting for non-             to be identified as either a high
                                               household competition, reported        or critical risk and therefore to
                                               to MOSL                                be included within the targeted
                                               10. Data provided to the Discover      assurance activities, a data item
                                               Water website, an industry-            must reflect one of the following:

3
    Statement of Risks, Strengths and Weaknesses of Information 2018/19

                                                                  3
Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
High probability of inaccurate reporting

                             Complexity of data sources
                              Completeness of data set
                        Extent of manual intervention in data
                      Complexity and maturity of reporting rules

                             Weak control framework

                               Level of control activities
                           Experience of personnel reporting
                         Evidence of historical errors with data

                        High impact if risk materialises

                                   On customers
                               On Company reputation
Strength of Outcome Delivery Incentive (in terms of its reputational or financial impact)
                            Used as industry comparator

                          The Company has a strong                 • Prioritising data items and
                          control framework in place for the       areas of reporting that have been
                          majority of data items we report         identified by Ofwat and other
                          on, which helps to mitigate the          regulators as areas of assurance
                          probability of inaccurate reporting      or transparency of reporting risk
                          from occurring. However, even            compared to other companies.
                          with a strong control framework
                          we have a number of the items            We are continually adapting our
                          within the high risk category. This      practices to address areas of
                          has been caused by a range of            data accuracy and transparency
                          factors, including:                      concerns and we know that to
                                                                   improve our assurance status
                          • Recognising the ‘impact’ of            we have to do more than just
                          the risk of inaccurate reporting         meet Ofwat’s expectations,
                          (regardless of the probability of it     but to exceed the regulator’s
                          taking place) and reflecting this        expectations by a clear margin, in
                          impact in our risk assessment.           particular showing how we will
                                                                   boost trust and confidence in the
                          • Our independent technical              Company and in the sector, by the
                          assuror, Atkins’, reports’ for 2017/18   activities that we undertake.
                          year-end and 2018/19 mid-year
                          of our performance commitment            By demonstrating that we have
                          methodologies and data, which            a thorough system of controls
                          has helped identify potential            (both internally and externally) to
                          weaknesses promptly.                     make sure that the information
                                                                   we report and publish achieves a
                          • The inclusion of new data items,       high level of accuracy, our aim is
                          some of which the Company                to help build trust and confidence
                          has little evidence of data or           in Bristol Water and the wider
                          experience in collating data for.        water sector.

                                           4
Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
INTRODUCTION
1. ABOUT BRISTOL WATER                            Bristol Water is a water supply              private water company in 1846 and
                                                  company, responsible for the                 has continued in this role ever since.
                                                  provision of water to 1.2 million            Parts of our network still date from
                                                  people in the city of Bristol and            these early days. Our original aim
                                                  surrounding area.                            then, as it is today, was to supply good
                                                                                               clean drinking water with a high
                                                  Our vision is to meet our customers’         quality service and that is value for
                                                  expectations by providing an                 money. We provide excellent quality
                                                  outstanding water service in a               of water, and some of the lowest
                                                  sustainable and affordable way.              levels of leakage in the country.

                                                  We are one of 17 companies in                In 2014 we published a business plan
                                                  England and Wales who distribute             setting out our priorities for 2015-20.
                                                  water and Bristol Water is one of six        This included a number of key aims
                                                  that focuses exclusively on water,           and outcomes that we want to deliver
                                                  not waste water. In our supply area,         for our customers and stakeholders.
                                                  waste water services are provided by         We published a revised strategy and
                                                  Wessex Water.                                business plan with an updated set of
                                                                                               performance commitments in 2018,
                                                  Bristol Water was founded as a               which will apply from 2020-25.

                                                  performance in 2017/18.                      Bristol Water with a certificate4, in
                                                                                               acknowledgement of:
                                                  Over the last couple of years                • Participating in the programme
                                                  Bristol Water has participated               for at least two consecutive
                                                  in the European Benchmarking                 benchmarking cycles.
                                                  Co-operation (EBC), a water
                                                  industry-based, not-for-profit               • Providing timely and good quality
                                                  benchmarking exercise on costs,              data.
                                                  performance and asset base.
In our mid-year performance                       Benchmarking is most effective               • Participating actively in the
report, published in December                     if we can use the lessons learned            programme, in particular by
2018, we set out our performance                  from the exercise to improve our             attending the annual benchmarking
to date in 2015-18, and included                  own performance and data quality.            workshop and presenting our data at
comparisons to other companies’                   The EBC Foundation has awarded               the workshop.

4
    Further information about this certificate can be found on the website of EBC Foundation

                                                                    5
Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
2. ABOUT THIS                        We regularly publish information      Scheme (GSS) payments
                                     on our performance to                 5. Data on performance on New
DOCUMENT –                           demonstrate to customers,             Connections, reported via Water UK
OUR ASSURANCE PLAN                   stakeholders and our regulators       6. Complaints reporting to CCWater
                                     that we are delivering the            7. Water quality information provided
                                     services expected of us. This         to the Drinking Water Inspectorate
                                     data has been risk assessed           8. Information provided to the
                                     to determine the likelihood of        Environment Agency (including our
                                     inaccurate reporting. If we are       Water Resources Management Plan
                                     well prepared, and have systems       and Market Information)
                                     and controls in place to prevent      9. Data reporting for non-household
                                     inaccurate reporting of data and      competition, reported to the market
                                     information from happening, it        operator MOSL
                                     is less likely that things could      10. Data provided to the Discover
                                     go wrong for our customers.           Water website, an industry-backed
                                     Getting this right first time will    dashboard designed to provide
                                     improve our customers’ trust and      accessible comparative information
                                     confidence in the Company and         for customers and stakeholders
                                     in the water sector. Specifically,
This document is known as            this Assurance Plan covers            A more detailed explanation of
Bristol Water’s Assurance Plan. It   information reported on for the       what these items cover can be
sets out our proposed approach to    following:                            found in the glossary section of
assurance of the information that                                          this document. In summary, this
we will publish during 2019/20.      1. 2018/19 Annual Performance         document provides assurance that
The purpose of our Assurance         Report (including our regulatory      we:
Plan is to give customers and        accounts and our 2015-2020
others with an interest in our       performance commitments) and          • Have processes and procedures
business (known as stakeholders)     2019/20 Mid-Year Performance          in place to reduce the risk of
trust and confidence in how          Report                                inaccurate or incomplete reporting.
we report on our performance.        2. 2018/19 Annual Report (including
By publishing this information       our statutory accounts)               • Are dealing appropriately
annually, we are also ensuring       3. 2020/21 Wholesale and Retail       with any risks and weaknesses
that the economic regulator of       Charges Schedule, Charging            identified in our Statement of
the water sector, Ofwat, will have   Arrangements and Charges              Risks, Strengths and Weaknesses
confidence in our assurance          Schemes                               of Information, by undertaking
activities (section 3).              4. 2018/19 Guaranteed Standards       targeted assurance activities.

Specifically, we will do the following to inform customers of our performance in a way that increases their
trust and confidence in us and in the information that we publish:

       Report accurate, reliable information and, where we identify any issues, we will:
                                    Deal with the issue in a timely way
                Involve customers, stakeholders and the Bristol Water Challenge Panel; and
      Review our risks and Assurance Plans continuously and make sure they reduce the effects of any
                                             areas of concern.

           If we are at risk of failing to meet our performance commitments, we will:

                                          Be open about the issue;
                    Give customers and stakeholders a clear explanation of the issue; and
                                 Explain how we will deal with the issue.

                                                      6
Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
This document should be read in       • Independent Assurance
                                               conjunction with our consultation     Assessments and Regulatory
                                               document on the Statement of          Feedback:
                                               Risks, Strengths and Weaknesses       1. We are required to incorporate
                                               of Information 2018/19.               independent external assurance
                                                                                     as part of our assurance plans. In
                                               In common with other water            addition to the requisite statutory
                                               companies in England and              audit and assurance role, we
                                               Wales, we carry out an annual         employ external auditors to audit
                                               Risks, Strengths and Weaknesses       and assure our key financial and
                                               exercise with stakeholders, to        non-financial information. We set
                                               highlight the areas that require      out in appendix 1 the role that both
                                               ‘targeted’ assurance; the areas       our independent technical assurer,
                                               that have the most significance       Atkins, and our financial auditors,
                                               to customers and stakeholders,        PwC, will play in assurance of our
                                               due to their impact on them, or       key submissions
                                               for those that have the greatest      2. We prioritise data items and data
                                               probability of a risk of inaccurate   reporting that have been queried
                                               reporting materialising. The          by Ofwat, and aim to exceed these
                                               exercise provides details of our      minimum expectations for data
                                               methodology for identifying           accuracy and transparency in
                                               any risks that may materialise.       areas that are most important to
                                               As figure 1 demonstrates, the         trust and confidence in our data
                                               Statement takes into account          and performance.
                                               various factors when determining
                                               the risk ratings for the data items   • External Engagement:
                                               the Company reports on, including:    1. Customer and stakeholder
                                                                                     feedback to the Statement of
                                               • Company Risk Assessment:            Risks, Strengths and Weaknesses
                                               1. The Company risk assessment        consultation on whether they
                                               has been carried out by the team      agree with the Company’s
                                               in Bristol Water responsible          assessments
                                               for reporting information to          2. Feedback from the Bristol Water
                                               customers, regulators and             Challenge Panel
                                               stakeholders. This team has           3. Feedback from other
                                               detailed knowledge of our             stakeholders to our published
                                               reporting processes and               consultations
                                               requirements, and the control
     Figure 1 – Factors to determine           framework in place for assurance      We also publish all of our latest
      data items’ risk assessments             of our information.                   assurance plans6 on our website
                                               2. The team has examined the          ahead of reporting to encourage
                                               inherent probability of inaccurate    input from our customers.
                                               reporting this information, the
                                               strength of the control framework     We published a consultation on our
                                               we have in place to mitigate this     Risks, Strengths and Weaknesses
                                               risk and the potential impacts of     exercise on 29 November 2018,
                                               any errors.                           and sought the views of our
                                               3. The methodology for                stakeholders and customers. This
                                               determining the risk was initially    Assurance Plan incorporates the
                                               based on the Data Assurance           results of our consultation on
                                               Guidance for Electricity and Gas      that exercise, which concluded
                                               Network Companies5, published by      on 31 December 2018 as well as
                                               Ofgem in February 2015, which we      the results of our consultation on
                                               amended to ensure it is relevant      our draft Assurance Plan, which
                                               for the key considerations in the     concluded on 28 February 2019
       Assessment of risk for each             water industry.                       (section 4). Following the close
              data item

5
    Data Assurance Guidance for Electricity and Gas Network Companies
6
    Bristol Water Performance

                                                                 7
Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
of these consultations, we have         Report (APR). The APR will be           and Weaknesses of Information)
analysed and updated the results        published in July 2019, alongside       we will demonstrate compliance
of our risk assessment (explained       a statement of board compliance         with our assurance requirements.
in appendix 2) and the controls we      with its statutory and regulatory       Compliance with our Assurance
had put in place to provide targeted    obligations (known as the Risk          Plan will be reviewed by Ofwat
assurance on our information            & Compliance Statement) and             in its Company Monitoring
that is most at risk of being           a summary of the assurance              Framework assessments (its
inaccurately reported (section 5).      activities and improvements             latest assessment can be found
We will set out the level of internal   undertaken throughout the year          in appendix 3), our Board (in its
and external assurance that we          (known as the Data Assurance            Risk and Compliance Statement
propose to apply to each piece of       Summary).                               2018/19) and the Bristol Water
information within this document                                                Challenge Panel (in its Annual
and what these assurance                It is our intention that by             Report 2018/19). The milestones the
activities mean for our customers       publishing transparent, accurate        company will meet as
(section 7).                            and reliable information through        part of this assurance framework is
                                        this Assurance Plan (which has          below.
The feedback we have received           been aided by the identification
will assist our assurance activities,   of the data items most at risk
in advance of the publication           of inaccurate reporting via our
of our Annual Performance               Statement of Risks, Strengths

                                                      Date                                    Published as a
                Document                                                    Publisher
                                                  published by                                 consultation

   Draft Assurance Plan                           31 January 2019           Bristol Water            √
   Assessment of Company Monitoring
   Framework 2018
                                                  31 January 2019              Ofwat
                                                                                                     X
   Final Assurance Plan
   (This Document)
                                                  31 March 2019             Bristol Water
                                                                                                     X
   Annual Performance Report, Data
   Assurance Summary and Risk &
   Compliance Statement
                                                   15 July 2019             Bristol Water
                                                                                                     X
   Statement of Risks, Strengths and
   Weaknesses of Information
                                                30 November 2019            Bristol Water
                                                                                                      √

                                                                                                     X
   Assessment of Company                          Late 2019/ Early             Ofwat
   Monitoring Framework 2019                        2020 (TBC)

If Ofwat considers that we have not met the requirements of our assurance plan it may intervene to prescribe a
greater level of assurance to be applied in future. It may also apply other regulatory remedies, including finan-
cial penalties if it deems that to be appropriate.

                                                          8
Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
3. REGULATORY                                  In June 2015 Ofwat published a               provided for the PR14 business
                                               Company Monitoring Framework7,               plan and CMA reference.
REQUIREMENTS                                   which set out how it intended
                                               to oversee the information that              We had remained in the
                                               water companies in England and               prescribed category in the
                                               Wales provide to their customers             assessments undertaken since
                                               and stakeholders. Ofwat expects              the first assessments made in
                                               companies to be transparent                  2015 (with the other assessments
                                               and to provide information that              being undertaken in November
                                               enables them to understand how               2016 and November 2017). However
                                               the Company is performing. This              in January 20198, Ofwat announced
                                               framework is intended to provide             that it was moving Bristol Water to
                                               customers and stakeholders with              the targeted category of assurance.
                                               confidence in the information that           Ofwat noted:
                                               companies produce, and allow Ofwat
                                               to take action where it feels that its       ‘The company has demonstrated
                                               requirements are not being met.              that it has acted upon feedback
                                                                                            that we provided, and has made
                                               The framework sets out the                   significant improvements from
                                               different levels of assurance                the previous year. It has exceeded
                                               to support the information we                our expectations for the risk and
                                               publish, depending on Ofwat’s                compliance statement and met
                                               confidence in the quality of the             our expectations in all but three
                                               information that companies                   of the other specific assessments
                                               produce. Companies are                       areas (financial flows, financial
                                               categorised as ‘self-assurance’              monitoring framework and
                                               where Ofwat has given the                    charges engagement).
                                               most discretion to decide what
                                               assurance is needed above                    ‘The company has met the
                                               the minimum required, and                    requirements for being promoted
                                               have the most trust from the                 to the targeted assurance
       Figure 2 – Ofwat’s Categories
                                               regulator. Ofwat categorises                 category. It has not shown
               of Assurance
                                               companies as ‘targeted’ where                evidence of behaviour that leads
                                               it considers companies have                  to a reduction in the trust and
                                               not consistently met the high                confidence stakeholders can place
                                               standards customers and other                in it. It has had no significant
            SELF-ASSURANCE
                                               stakeholders expect. Ofwat                   problems with its assurance plan
                                               categorises companies as                     and has been in the prescribed
                                               ‘prescribed’ where companies                 category for at least 12 months.
                                               have not provided them with                  Companies in the prescribed
                                               sufficient confidence in their               assurance category in the
                                               ability to deliver, monitor and              previous year can only move up to
                                               report performance. Companies                the targeted category in one year”
                                               within the prescribed category
         TARGETED ASSURANCE
                                               of assurance are therefore those             Ofwat’s latest assessments of the
                                               that Ofwat has the lowest level of           Company’s performance in the
                                               trust in to publish accurate data            Company Monitoring Framework
                                               and information.                             and our plans for improvements
                                                                                            can be found in appendix 3.
                                               In November 2015, Ofwat                      As a ‘targeted’ company we
                                               informed Bristol Water that it               are required to undertake the
                                               intended to move the company                 activities listed below. These
       PRESCRIBED ASSURANCE
                                               into the ‘prescribed’ category               are set within the context of the
                                               of assurance, citing concerns                requirements for the other two
                                               with the quality of our evidence             categories of assessment.

All companies in the prescribed assurance band are required to undertake the requirements identified in figure
3 (next page).
7
    Company monitoring framework – final position
8
    Company monitoring framework: 2018 assessment – Individual company report – Bristol Water

                                                                    9
Assurance Category                              Assurance Requirements

                             Alongside each set of information they provide, the Boards of these
                             water companies must provide:
    Self-Assurance           • explicit sign off on the assurance that they are providing;
                             • full transparency on the audit procedures; and a summary of the
                             outcome of the assurance that their company has carried out.

                             In addition to meeting the requirements for the self-assurance category,
                             companies in the targeted category are required to:
                             • carry out an exercise with stakeholders to target issues to address (the
                             statement of risks, strengths and weaknesses exercise); and
 Targeted Assurance          • publish a statement on this in the autumn of each year in advance of
                             submitting information. For issues a company targets, they are required
                             to publish draft Assurance Plan and speak with and listen to stakeholders
                             before confirming final Assurance Plans, but only in these targeted areas.

                             In addition to meeting the requirements of self-assurance and
                             targeted categories, companies in the prescribed category are required
                             to publish their assurance plans for all information in advance of
                             reporting. This is so that stakeholders (including Ofwat) can gain
                             confidence and, if necessary, provide comments or guidance that
                             the company would need to respond to. The risks, strengths and
 Prescribed Assurance
                             weaknesses exercise that a prescribed company carries out (this
                             document) must highlight the areas of reporting that have the most
                             significance or are of greatest risk to customers (the ‘targeted’ areas).
                             For these areas the company must incorporate independent external
                             assurance as part of its assurance plans.

                           Figure 3 – Targeted Assurance Requirements

       Incorporate independent external assurance (provided by Atkins and PwC).

   Identify the risks, strengths and weaknesses in providing the quality of information that
 stakeholders want and trust and highlight the areas that have the greatest risk to customers.

Publish a Risks, Strengths and Weaknesses Statement on this as a consultation in the autumn
                      of each year (this was published in November 2018).

Consult on a Draft Assurance Plan to ensure that it is sufficient to address the issues identified
                     in the Strengths, Risks and Weaknesses statement.

 Publish a final Assurance Plan, so that stakeholders can gain trust and confidence in all the
        key information that Bristol Water reports and publishes throughout 2019/20.

                                                10
The table below presents an overall comparison of the previous annual assessments Ofwat has taken to date
since the Company Monitoring Framework was introduced.

                                          2016                   2017                     2018
    Area of Assessment
                                       Assessment             Assessment               Assessment

      Financial Monitoring
                                   Meets expectations       Meets expectations        Minor concerns
          Framework

 Charges schemes assurance/
                                    Meets expectations      Meets expectations        Minor concerns
    Charges engagement

      Financial Information         Meets expectations         Not Included             Not Included

   Final 2010-15 reconciliation     Meets expectations         Not Included             Not Included
        data submission

           Outcomes                Meets expectations        Serious Concerns       Meets expectations
   Compliance with principles
      of board leadership,          Meets expectations      Meets expectations         Not Included
 transparency and governance

 Water resources management
                                       Not included            Not included         Meets expectations
 plan and market information

 Long-term viability statement         Not included            Not included         Meets expectations

          Financial flows               Not included           Not included           Minor concerns

       Risk and compliance          Meets expectations Meets expectations           Exceeds expectations
            statement

         Assurance plan               Minor concerns        Meets expectations       Meets expectations
         Targeted reviews             Minor concerns           Not included             Not included
   Data assurance summary             Minor concerns         Minor concerns             Not included
        Cost assessment                Not included           Not included           Meets expectations
             Casework                 Minor concerns         Minor concerns          Meets expectations
      PR19 initial assessment
        of business plans –            Not included            Not included         Meets expectations
         data consistency

  PR19 initial assessment of           Not included            Not included         Meets expectations
 business plans – data quality

       Wider assurance and
                                       Not included             No issues                No issues
          information

This document is intended to meet or exceed the expectations of Ofwat’s Company Monitoring Framework,
and we have welcomed the opportunity to use this exercise as the basis for additional engagement with our
customers and other stakeholders.

                                                       11
OUR APPROACH TO ASSURANCE
4. TAKING INTO                      We provided details of our 2017/18   We received one response to the
                                    performance to a meeting of          Statement of Risks consultation;
ACCOUNT REGULATORY,                 the BWCP on 9 July 2018. This        from a member from the
STAKEHOLDER AND                     meeting was also attended by         BWCP. We have reviewed and
CUSTOMER FEEDBACK                   our technical reporter from          incorporated the suggestions
                                    Atkins, who gave details of the      provided as appropriate.
We have consulted our customers     assurance assessment on each
and key stakeholders in two         outcome. A further meeting of        Since the publication of our
phases. The first phase was on      the BWCP was convened on 12          Statement of Risks, Strengths
our Statement of Risks, Strengths   December 2018 to review our          and Weaknesses of Information
and Weaknesses of Information,      mid-year performance, assurance      2018/19 we have taken into
which we published on 29            framework and progress against       consideration all the factors
November 2018. The consultation     actions raised from year end         that determine our data items’
closed on 31 December 2018.         reporting.                           risk assessments (as explained
We invited comments through                                              in section 2). In our initial
publishing the document on our      The results of our risk              risk assessment, which was
website and by advertising the      assessments on our reported data     published in our Statement of
consultation on social media,       items can be found in appendix       Risks, Strengths and Weaknesses
particularly via Twitter and        2 of this document. These have       2018/19, we identified seventeen
LinkedIn. We also presented our     been updated to reflect the          (17) data items at either a high
risk assessment methodology         feedback we have received as a       or critical risk of inaccurate
and results to our Board,           result of the Statement of Risk      reporting and therefore had been
including to our independent        consultation and based on the        identified as requiring targeted
non-executive directors, and        comments Ofwat made as part          assurance activities. The table
to a customer sub-group of our      of the 2018 assessment of the        below presents the risk items that
Customer Challenge Panel,           Company Monitoring Framework,        have been updated in our risk
known as the BWCP, on 27            which was published at the end       assessment, based on our final
November 2018.                      of January 2019.                     review of the risk assessments.

                   Initial Risk           Factors            Final Risk                 Factors
                 Assessment in         considered in       Assessment in              considered
Data Item       Risks, Strengths        Initial Risk       Assurance Plan            in Final Risk
                and Weaknesses          Assessment            2019/20                Assessment
                     2018/19

                                                                                       Whilst this is a new
                                                                                   performance measure, this
                                         New data item                            information has previously
    Void                                  included for                            been routinely collected and
 Properties            High                this year’s           Medium             assured as part of annual
                                                                                  property count calculations
                                          assessment
                                                                                      used to support other
                                                                                     performance measures.
                                                                                           measures.

                                                                                  As the Southern Resilience
                                             To be                                     Scheme that this
                                                                                  performance commitment
 Population                             consistent with                             monitors has now been
at risk from           High              previous risk           Medium           completed, the assessment
asset failure                            assessments                                now reflects the lower
                                                                                  probability of inaccurately
                                                                                   reporting the remaining
                                                                                      population at risk.

                                                    12
The second phase was on the              Our posts were designed to           We have reviewed and
approach undertaken in our               encourage two way dialogue           incorporated the suggestions
Assurance Plan, which we published       with customers and to generate       provided as appropriate; the
as a draft on 31 January. The            exchanges on a variety of topics.    feedback received related
consultation closed on 28 February       We received two responses to the     to technical revisions in the
2019. We again invited comments          draft Assurance Plan consultation;   document, particularly in regard
through publishing the document          one from a member from the BWCP,     to information in sections 5 and
on our website and by advertising        writing in a personal capacity and   8, which the final version now
the consultation on social media,        one from the Chair of the BWCP,      addresses. The Chair of the BWCP
particularly via Twitter and LinkedIn.   writing on behalf of all members.    also noted:

  ‘The Bristol Water Challenge Panel is pleased to respond to the consultation by Bristol Water on its
  Draft Assurance Plan. Since 31 January of this year, Bristol Water has been assessed as requiring to
  provide ‘targeted assurance’ to the water regulator Ofwat. We congratulate Bristol Water on achieving
  this promotion. We also welcome the level of detail in the Plan regarding how Bristol Water treats
  its risks, strengths and weaknesses in the draft Plan which is in excess of that required by targeted
  water companies. It is our expectation that Bristol Water, as a mark of transparency and openness,
  will publish the detail contained in the Draft Assurance Plan.

  ‘As a Challenge Panel, we note that Bristol Water has a clear framework for assessing and categorising
  information-reporting risk, that is has controls and mitigations to reduce such risk and that it has
  identified the practices that must be improved in order to meet the requirements of Ofwat. We note
  this level of openness and willingness to take on board queries, amendments and contributions from
  customers, stakeholders and other partners creates trust and confidence in the company.

  ‘The bill payers of Bristol Water have expressed (through various and different customer research
  projects) their wish to be educated, and to know more, about the water sector in general and Bristol
  Water in particular. Bristol Water is stepping up to this challenge by improving the language its uses
  to speak to customers, the production of colourful and informative graphics that interpret data as well
  as by the increase in channels (such as its website and social media) by which it communicates. The
  Challenge Panel has seen a step-change in such methods during this Asset Management Period and
  the Draft Assurance Plan extends this practice further.’
           Mrs Peaches Golding OBE
           For and on behalf of the Bristol Water Challenge Panel

                                                         13
We note the limited level of
customer engagement with our
Statement of Risks, Strengths and
Weaknesses and draft Assurance
                                       Social Media Outreach
Plan consultations. Both were
published on our website and we
kept the consultations open for a
                                       Two - the number of written responses to
number of weeks. We also actively
used social media to encourage a
                                                   the consultation
greater level of engagement with
our customers and stakeholders
(our social media outreach is
included in the graphic opposite).          2,430 - the number of impressions
Rather than a reflection on the
design of our consultations, we
feel that the low response rate is a
result of the technical content of
the exercise itself.                           Three - the number of likes

The low response rate also
reflects the experience of all
companies across the industry;
not surprisingly customers have             21 - the number of engagements
not shown a great deal of appetite
for engaging in the methodology
behind the risk assessments.
However, to help increase
awareness of assurance activities
identified we will continue to use
social media, including promotion
on Twitter and LinkedIn, in order
to encourage greater participation
in the process in future years.

                                       14
5. TARGETED ASSURANCE                           Following our data items’ risks           data to challenge the key data and
                                                assessments, we set out in this           assumptions made.
ACTIVITIES                                      section the targeted assurance
                                                activities which will be undertaken       • Internal review and approval of
                                                in the year ahead. These activities       key data by Executive Management
                                                will help to mitigate the most            Team and the Board.
                                                important risks. We have identified
                                                fifteen (15) data items that require      • External assurance of reporting
                                                targeted assurance activities. These      processes and data associated with
                                                data items have been targeted for         our Annual Performance Report, our
                                                one of the following reasons:             Regulatory Accounts, our Wholesale
                                                                                          and Retail Charges and Charges
                                                • The risk of inaccurate reporting        Scheme, our Guaranteed Standard
                                                has significantly increased               Scheme data and our data on
          Data items that require               compared to 2017/18, to the extent        performance on new connections.
           targeted assurance                   that the data item has deteriorated
                 activities.                    in its overall risk assessment i.e. it    • Review and challenge of our
                                                has moved from a ‘medium risk’ in         performance (at both mid-year and
                                                2017/18 to a ‘high risk’ in 2018/19.      end-year) in 2018/19 against our
                                                                                          performance commitments by the
                                                • The data item was reported as           BWCP.
                                                either ‘high’ or ‘critical risk’ in
                                                2017/18 and has remained within           • Review and challenge of our
                                                either of these categories for            performance by the CEO.
                                                2018/19.
                                                                                          • Our internal audit programme
                                                • The data item is a new reporting        includes periodic reviews of the
                                                requirement for 2018/19 and has           governance process, including sign
                                                been identified as either a ‘high’ or a   off of data quality assurance forms
            High impact if
          risk materialises                     ‘critical’ risk.                          and compliance with governance
                                                                                          and approval methodologies.
                                                Section 7 illustrates the
                                                assurance activities we propose           Our detailed risk assessment
                                                to undertake for the data items           methodology can be found in our
                                                used in our published reports or          Statement of Risks, Strengths
                                                for our regulatory submissions.           and Weaknesses of Information
High probability
 of inaccurate
                                Weak control
                                 framework
                                                In summary the assurance will             document. However, in summary,
   reporting
                                                comprise:                                 to be identified as either a high
                                                                                          or critical risk and therefore to
                                                • Internal governance and control         be included within the targeted
                                                of all information listed in this         assurance activities, a data item
                                                section, including peer review of         must reflect one of the following:

                                       High probability of inaccurate reporting

             Complexity of data sources | Completeness of data set | Extent of manual intervention in data |
                                      Complexity and maturity of reporting rules

                                                 Weak control framework

                              Level of control activities | Experience of personnel reporting |
                                          Evidence of historical errors with data

                                               High impact if risk materialises

  On customers | On Company reputation | Strength of Outcome Delivery Incentive (in terms of its reputational
                            or financial impact) | Used as industry comparator

                                                                   15
The final risk assessment for all risk   the transparency of our data and       for some of our reported data.
items (found in appendix 2) reflects     information, which are intended to     However, we are seeking to continue
our ability to identify the potential    increase the trust and confidence in   to improve the assurance and
for errors and, if necessary, act        which customers and stakeholders       transparency of our reporting and
accordingly to address them.             can place in our reports.              see external assurance for our
                                                                                targeted data items as an important
The additional targeted activities we    Having been promoted from a            part of this process, and as such
intend to undertake in response to       prescribed to targeted assurance       do not propose any changes to our
our risk assessment for specific data    status in the 2018 CMF, we are         approach to assurance of our data in
items are set out in the table below.    no longer required to undertake        2019/20 in response to our change in
This includes steps taken to improve     independent external assurance         classification.

                                                           16
2017/18 Risk      2018/19 Risk   Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
  Data Item
                   Assessment        Assessment     Risk Assessment

                                                                                This measure will replace the current measure, SIM, from 2020/21. Shadow
                                                                                                   reporting will commence in 2019/20.

                                                                                                             Internal Assurance
                                                                                 This data item will follow the same internal reporting requirements that
                                                                                our other performance commitments follow, as outlined in our Statement
                                                                               of Risks, Strengths and Weaknesses of Information. The data item will have
                                                                                  a specific owner and reviewer, responsible for production and updating
                                                                                   the reporting methodology statement. Data owners and reviewers are
                                                                                required to provide signed confirmation that the data has been compiled
Customer measure                                                                 in accordance with the relevant methodology, and that the data is a true
  of experience         N/A             High         New data item – affects   representation of the facts. This form provides the opportunity for the data
                   (new data item)                     control framework        owner and reviewer to identify any concerns with the quality of the data,
     (C-MeX)
                                                                                 for investigation by senior managers and Directors. A data approver (the
                                                                                 Executive Director responsible for the area the data item relates to) then
                                                                               approves the quality of the data, in consultation with Economic Regulation
                                                                                                                    team.

                                                                                                            External Assurance
                                                                                  Our shadow data is to be externally audited in 2019/20 by our technical
                                                                                   assurer, Atkins. Their assurance approach is outlined in appendix 1.

                                                                                Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                               As a result of our assurance activities, we anticipate that this will reduce to a
                                                                                                               medium risk.

                                                                                 This measure comes into effect from 2020/21 with shadow reporting in
                                                                                                               2019/20.

                                                                                                            Internal Assurance
                                                                               This data item will follow the same internal reporting requirements that our
    Developer                                                                   other performance commitments follow, as outlined in our Statement of
services measure        N/A                                                                 Risks, Strengths and Weaknesses of Information.
                                        High        New data item – affects
  of experience    (new data item)                    control framework                                    External Assurance
     (D-MeX)                                                                     Our shadow data is to be externally audited in 2019/20 by our technical
                                                                                  assurer, Atkins. Their assurance approach is outlined in appendix 1.

                                                                                Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                               Due to the complexities in data reporting, we do not anticipate that the risk
                                                                                                     will reduce below a high risk.

                                                             17
2017/18 Risk   2018/19 Risk   Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
  Data Item
                    Assessment     Assessment     Risk Assessment
                                                                             The risk of inaccurate reporting has increased for this data item, compared to last
                                                                                                             year’s assessment.

                                                                                                            Internal Assurance
                                                                                An internal ‘action plan’ has been implemented to improve the logging of
                                                                             unwanted calls. The plan was produced following the 2017/18 year-end audit and
                                                                             updated following the 2018/19 mid-year audit by Atkins. In summary, Atkins has
                                                                                                  identified two areas for improvement:

                                                                             1. Data collation for risks and controls - relating to the collation of monthly data in
                                                                                                             a central spreadsheet.
                                                                                  2. The accuracy of reporting of unwanted calls (which contributes to the
                                                                             quantitative component of the SIM calculation, which is 25% of the overall score).

                                                                                                     Data collation risks and controls
                                                                                 Steps have been implemented to reduce manual data entry by linking the
                                                                              central spreadsheet used to the numerous contributory reports. Further work is
                                                                              being undertaken now to simplify the spreadsheet, provide further tools for data
                                                                                        analysis and to automate data checks and data forecasting.

                                                                                                 The accuracy of reporting of unwanted calls
                                                                             In response to the initial findings from Atkins’ 2018/19 mid-year audit, a report has
                                                                               been developed to split the call data logged by individual teams at Bristol Water.
Service Incentive                                 Identified weaknesses in      This allows control processes to be compared to the volume of calls logged on
                      Medium          High
Mechanism (SIM)                                      control framework          our main database, to ensure that they are proportionate and accurate. Having
                                                                              implemented this reporting procedure, our analysis shows that the vast majority
                                                                              of logged unwanted calls (95%) are received via our operational customer support
                                                                                 team and are therefore subject to existing monthly controls activities, which
                                                                              include call listening of a sample of calls by managers responsible for reviewing
                                                                                                        the accuracy of the data logged.

                                                                              We recognise that despite the relatively low call volumes received by the teams
                                                                             outside of our operational customer support team (the remaining 5% of unwanted
                                                                             calls), stronger control activities are required to ensure that these calls continue to
                                                                              be logged accurately. As a result, call recording has now been introduced for our
                                                                               metering, new supply and water regulation teams (which combined are c.4% of
                                                                             logged unwanted calls). A weekly manager review of 10% of the calls is now being
                                                                               undertaken for each team. There has also been an increased focus on training
                                                                              since the 2017/18 audit to ensure that documented processes are being followed.
                                                                                We have also allocated a member of staff to support the roll-out of assurance
                                                                                                             across the other teams.

                                                                             Our analysis suggests that the SIM score calculation is relatively insensitive to the
                                                                             number of unwanted calls. Given the small proportion of calls received outside of
                                                                             the operational customer support team, it is unlikely that under-reporting in these
                                                                                         other teams will have a material impact on the SIM score.

                                                                                                          (continued on next page...)

                                                          18
2017/18 Risk   2018/19 Risk   Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
  Data Item
                    Assessment     Assessment     Risk Assessment

                                                                                                      (continued from previous page...)

                                                                               However, in recognition of the potential customer service impacts of unlogged
                                                                              calls, we will continue to undertake the above processes to ensure that accurate
                                                                                        logging is being adhered to, without exception, by every team.

Service Incentive                                                                Performance information is also included in our interactive performance
                                      High        Identified weaknesses in
                      Medium                                                                           graphic on our website.
Mechanism (SIM)                                      control framework
                                                                                                            External Assurance
                                                                              The data item will continue to be audited by our technical assurer, Atkins. Their
                                                                              assurance approach is outlined in appendix 1. The progress made as part of the
                                                                                 action plan outlined above will be included within the scope of the audit.

                                                                                Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                               As a result of our assurance activities, we anticipate that this will reduce to a
                                                                                                               medium risk.

                                                                                 Our reporting approach for our 2016/17 leakage data was highlighted in
                                                                               Ofwat’s 2017 Company Monitoring Framework assessment (this contributed
                                                                                 to the regulator having ‘serious concerns’ about our outcome reporting).

                                                                                                           Internal Assurance
                                                                               Since that assessment we have agreed with the regulator to dual-report on
                                                                                this performance commitment and provide thorough explanations behind
                                                                                 the methodologies undertaken within our in published reports (which we
                                                                               have done as recently as the 2018/19 Mid-Year Performance Report). We will
                                                       High impact on           continue to dual-report on this performance commitment until the end of
                                                                                                                 2019/20.
    Leakage            High           High        customers, stakeholders
                                                  or company reputation, if      Performance information is also included in our interactive performance
                                                      risk materialises                 graphic on our website to aid transparency to customers.

                                                                                                          External Assurance
                                                                                The data item will continue to be audited by our technical assurer, Atkins.
                                                                                  Their assurance approach is outlined in appendix 1. Both sets of data
                                                                                included in the dual-reporting are included within the scope of the audit.

                                                                                Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                               Due to the complexity of leakage reporting, we do not anticipate that the risk
                                                                                                      will reduce below a high risk.

                                                            19
2017/18 Risk   2018/19 Risk   Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
  Data Item
                   Assessment     Assessment     Risk Assessment

                                                                                                             Internal Assurance
                                                                             This data item will follow the same internal reporting requirements that our other
                                                                             performance commitments follow, as outlined in our Statement of Risks, Strengths
                                                                                                       and Weaknesses of Information.

                                                                             Performance information is included in our interactive performance graphic on our
                                                                                               website to aid transparency to customers.
                                                      High impact on
                      High                       customers, stakeholders                                     External Assurance
  Low Pressure                       High
                                                 or company reputation, if     The data item will continue to be audited by our technical assurer, Atkins. Their
                                                     risk materialises                         assurance approach is outlined in appendix 1.

                                                                                 Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                               The high risk rating for this measure reflects our recognition of the impact on
                                                                               inaccurate reporting, rather than a high probability of inaccurate reporting or
                                                                             specific weaknesses in the control framework. We therefore do not anticipate that
                                                                                                    the risk will reduce below a high risk.

                                                                                                             Internal Assurance
                                                                             This data item will follow the same internal reporting requirements that our other
                                                                             performance commitments follow, as outlined in our Statement of Risks, Strengths
                                                                                                       and Weaknesses of Information.

                                                                             Performance information is included in our interactive performance graphic on our
                                                      High impact on                           website to aid transparency to customers.
                                                 customers, stakeholders
     Bursts           High           High                                                                    External Assurance
                                                 or company reputation, if
                                                     risk materialises         The data item will continue to be audited by our technical assurer, Atkins. Their
                                                                                               assurance approach is outlined in appendix 1.

                                                                                 Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                               The high risk rating for this measure reflects our recognition of the impact on
                                                                               inaccurate reporting, rather than a high probability of inaccurate reporting or
                                                                             specific weaknesses in the control framework. We therefore do not anticipate that
                                                                                                    the risk will reduce below a high risk.

                                                                                                             Internal Assurance
                                                      High impact on
   Unplanned                                                                 This data item will follow the same internal reporting requirements that our other
                                                 customers, stakeholders     performance commitments follow, as outlined in our Statement of Risks, Strengths
Customer Minutes      High           High
                                                 or company reputation, if                             and Weaknesses of Information.
  Lost (UCML)                                        risk materialises
                                                                                                          (continued on next page...)

                                                            20
2017/18 Risk   2018/19 Risk   Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
  Data Item
                   Assessment     Assessment     Risk Assessment

                                                                                                      (continued from previous page...)

                                                                             Performance information is included in our interactive performance graphic on our
                                                                                               website to aid transparency to customers.
                                                      High impact on                                         External Assurance
   Unplanned                                     customers, stakeholders
                      High           High                                      The data item will continue to be audited by our technical assurer, Atkins. Their
Customer Minutes                                 or company reputation, if                     assurance approach is outlined in appendix 1.
  Lost (UCML)                                        risk materialises
                                                                                 Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                               The high risk rating for this measure reflects our recognition of the impact on
                                                                               inaccurate reporting, rather than a high probability of inaccurate reporting or
                                                                             specific weaknesses in the control framework. We therefore do not anticipate that
                                                                                                    the risk will reduce below a high risk.

                                                                                The risk of inaccurately reporting PCC has deteriorated over the years (it was
                                                                              assessed as a low risk in 2016/17). Our approach to reporting our 2016/17 PCC data
                                                                             was highlighted in Ofwat’s 2017 Company Monitoring Framework assessment (this
                                                                             contributed to the regulator having ‘serious concerns’ about our outcome reporting).

                                                                                                              Internal Assurance
                                                                                  Since that assessment we have agreed with the regulator to dual-report on
                                                                                this performance commitment and provide thorough explanations behind the
                                                                              methodologies undertaken within our in published reports (which we have done as
                                                      High impact on           recently as the 2018/19 Mid-Year Performance Report). We will continue to dual-
  Per Capita                                     customers, stakeholders               report on this performance commitment until the end of 2019/20.
 Consumption          High           High
                                                 or company reputation, if
    (PCC)                                            risk materialises       Performance information is included in our interactive performance graphic on our
                                                                                               website to aid transparency to customers.

                                                                                                             External Assurance
                                                                               The data item will continue to be audited by our technical assurer, Atkins. Their
                                                                             assurance approach is outlined in appendix 1. Both sets of data included in the dual-
                                                                                            reporting are included within the scope of the audit.

                                                                                  Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                                Due to the complexity of measuring PCC, we do not anticipate that the risk will
                                                                                                          reduce below a high risk.

                                                          21
2017/18 Risk   2018/19 Risk   Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
  Data Item
                    Assessment     Assessment     Risk Assessment

                                                                                   The risk of inaccurate reporting has increased for this data item, compared to
                                                                                 last year’s assessment. The high risk rating is primarily in recognition of omitted
                                                                                   specific disclosure information that we should have included in our regulatory
                                                                                  accounts notes, which was not included in our Annual Performance Report and,
                                                                                           consequently, led to a number of queries being raised by Ofwat.

                                                                                                                 Internal Assurance
   Regulatory                                                                   A review of all required disclosures will now be included in our approval process for
                      Medium          High        Identified errors last year                                      the 2018/19 APR.
   Accounts
                                                                                                               External Assurance
                                                                                   The data item will continue to be audited by our financial auditor, PwC. Their
                                                                                                  assurance approach is outlined in appendix 1.

                                                                                    Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                                   As a result of our assurance activities, we anticipate that this will reduce to a
                                                                                                                   medium risk.

                                                                                                                Internal Assurance
                                                                                 This data item is reviewed by two teams at the company – Economic Regulation
                                                                                                                   and Finance.

                                                                                Our tariff and charges publications (particularly for new connections charges) now
                                                                                 include more customer-friendly language and user-friendly graphics, to improve
                                                                                                       their readability for interested parties.

                                                                                   Our Statement of Assurance on our tariffs also now includes an engagement
                                                       High impact on             summary section on who we have spoken to and what changes we have made
                                                  customers, stakeholders        to the information we present in our tariffs and charges publications as a result,
Tariffs & Charges      High           High
                                                  or company reputation, if                      which brings it in line with industry best practise.
                                                      risk materialises             External Assurance We will continue to assure the information via external
                                                                                 financial auditors, to ensure accuracy and reliability. The data item is audited by
                                                                                  our financial auditor, PwC. Their assurance approach is outlined in appendix 1.

                                                                                    Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                                  The high risk rating for this measure reflects our recognition of the impact on
                                                                                  inaccurate reporting, rather than a high probability of inaccurate reporting or
                                                                                specific weaknesses in the control framework. We therefore do not anticipate that
                                                                                                       the risk will reduce below a high risk.

                                                           22
2017/18 Risk   2018/19 Risk     Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
  Data Item
                          Assessment     Assessment       Risk Assessment

                                                                                                                           Internal Assurance
                                                                                           A process map will be introduced as part of the reporting methodology, in order
                                                                                           to reduce the probability of inaccurate reporting from materialising for this data
                                                                                         item. This approach is already included in the methodologies for our performance
                                                                                                                             commitments.

                                                               High impact on                                          External Assurance
   Guaranteed                                                                            The data item will continue to be audited by our technical assurer, Atkins. Their
                             High           High          customers, stakeholders
Standards Scheme                                                                         assurance approach is outlined in appendix 1. The scope of the audit will include
                                                          or company reputation, if
 (GSS) Payments                                                                          a review of the process map and its effectiveness in identifying any risks in our
                                                              risk materialises
                                                                                                                       reporting processes.

                                                                                             Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                                           The high risk rating for this measure reflects our recognition of the impact on
                                                                                           inaccurate reporting, rather than a high probability of inaccurate reporting or
                                                                                         specific weaknesses in the control framework. We therefore do not anticipate that
                                                                                                                the risk will reduce below a high risk.

                                                                                                                     Internal Assurance
                                                                                        Our new connections charges now include more customer-friendly language and
      Service Incentive                                        Identified weaknesses in
                                Medium             High                                               user-friendly graphics to improve transparency.
      Mechanism (SIM)                                             control framework
                                                                                           We have continued to expand upon our tailored engagement activities with our
                                                                                            developers to ensure that their voices are heard alongside our stakeholders in
                                                                                          the wider Bristol area. We established our Market Engagement Days in 2017 as an
                                                                                         on-going engagement activity to bring together developers and self-lay providers
                                                                                         (SLPs) to build relationships, communicate information, and receive feedback. We
                                                               High impact on              have used our Market Engagement Days as part of our consultation on the new
Developer Services                                        customers, stakeholders          charging approach for developer services, which we successfully introduced in
      Data                   High           High                                              April 2018. We will continue to undertake similar engagement activities.
                                                          or company reputation, if
                                                              risk materialises
                                                                                           We also continue to undertake quarterly reporting on our developer services
                                                                                         performance to Water UK and the SIM action plan includes the processes our new
                                                                                         supplies team and Kier will undertake to ensure accurate complaints reporting is
                                                                                                                            addressed.

                                                                                                                        External Assurance
                                                                                         Atkins’ audit scope of the SIM data item is linked to the information for this data
                                                                                                                                item.

                                                                                            Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
                                                                                          Due to the complexities in data reporting, we do not anticipate that the risk will
                                                                                                                     reduce below a high risk.

                                                                     23
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