Acona verification statement

Acona Ltd has been asked by the Corporate Responsibility Committee of Pennon Group (the Group) to undertake an independent review of its Corporate Responsibility Report (the Report) for 2009 and provide assurance that:

  • The quantitative data is materially accurate
  • The qualitative statements can be supported by evidence and properly represent activity across the company
  • The Report gives a balanced picture of performance
  • Performance in respect of its previously published target is accurately reported

Responsibilities of Pennon Group Plc and Acona Ltd

The information and statements contained within the Report are the responsibility of Pennon Group Plc. This statement is the responsibility of Acona Ltd and represents our independent opinion of the content of the Report and is addressed to Pennon Group Plc's Corporate Responsibility Committee.

Scope and process

The review covered Pennon Group Plc's operations for the period specified in the Report and embraced those sections of the Report relating to the Group's activities and those of its two principal subsidiaries, South West Water Limited and Viridor Limited. Information subject to verification by other third parties - such as financial data included within the Annual Report and Accounts and information provided to regulators such as OFWAT - was outside our scope. However, we have relied on it in forming our conclusions.

In performing our work we adopted the following approach:

  • Desk-top evaluation and detailed analysis of the raw data used to construct the Report, including comparisons with previous years.
  • Review of internal and external documents relating to Corporate Responsibility management, including policies, procedures and stakeholder comments, particularly ensuring that evidence was made available to support substantive comments and claims made in this Report.
  • Detailed interviews with employees involved in compiling the Report to test the accuracy of the data and underlying processes.

Additionally, we drew upon our knowledge of reporting within the sector and Corporate Responsibility reporting more broadly.

Opinion

Based on our work we conclude that:

  • The Report correctly identifies the company's material social and environmental impacts and provides a balanced and comprehensive account of its performance in these areas.
  • The data, and inferences drawn from them, and substantive statements are materially accurate and are supported by a range of evidence from internal and external sources. Any inaccuracies identified during the verification process were of a minor nature, were readily rectified and the report was amended accordingly.
  • Progress against Pennon Group's Corporate Responsibility target was accurately presented.

This Report provides a comprehensive and balanced description of the Group's approach and performance across a number of social and environmental impact areas. It gives due regard to the activities of its two main subsidiaries - South West Water and Viridor - as well as explaining how key corporate responsibility issues, such as Climate Change, are being addressed at Group level. With regard to the latter, it highlights the increasing amount of renewable energy generated by the principal operating companies and the fact that the Group continues to export more electricity than it consumes.

In response to comments we made last year, the Group has developed a number of Corporate Responsibility objectives for the 2009-10 reporting cycle and identified how each of the main subsidiaries will contribute to their achievement.

Our comments on South West Water and Viridor's corporate responsibility reports can be found in the relevant sections of their documents.

Recommendations for future reporting

Our comments on the reporting process and report itself, together with suggested areas for improvement, will be raised in a letter to Pennon Group's Corporate Responsibility Committee. Neither the comments nor recommendations contained therein affect our opinion on the Report as set out in this statement. Our main recommendations are provided below.

  • The Group should consider explaining, in greater detail, the scope of its stakeholder engagement and how the latter influences the Corporate Responsibility strategy and specific actions and activities undertaken in furtherance of it.
  • The Group should develop a small number of high-level indicators that are aligned with its main social and environmental impacts, which can be used by both the Corporate Responsibility Committee and stakeholders to assess overall performance.

Additional recommendations relating to South West Water and Viridor can be found in the relevant sections of our reports on the two subsidiary companies.

Paul Burke signature

Paul Burke
Senior Partner

30th July 2009

Acona Ltd

Acona Ltd is an independent consultancy, based in London but with staff all over the UK. We have broad expertise and advise large, mainly corporate, clients on the full range of social, environmental and ethical matters. The team members who undertook this work have extensive experience of both assurance and CR reporting and biographical information can be found on our website - www.Acona.com/cr

With the exception of this work, Acona has no commercial relationship with Pennon Group and/or its subsidiaries. The total fees payable in respect of this work accounted for less than 10% of Acona's annual turnover.


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