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Independent assurance statement

Independent Assurance Statement for E.ON UK

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The E.ON UK 2007 Corporate Responsibility (CR) Report (the Report), covering January to December 2007, has been prepared by the management of E.ON UK, who are responsible for the selection of content and for the collection and presentation of information.

The Reassurance Network has been commissioned for a second year by E.ON UK to verify the Report and to provide assurance relating to the accuracy, coverage and balance of content. This includes consideration of the extent to which E.ON UK has responded to its own previous commitments and to the expectations of its key stakeholders.

This assurance statement contains our own unabridged opinion. Any reliance that any third party may place on this Statement is entirely at its own risk.

SCOPE AND LEVEL OF ASSURANCE

The scope of assurance covers the content of the web-based Report and the business activities of E.ON UK that support it. We have assured all sections of the Report. Our review did not cover: information presented elsewhere on the E.ON UK website; E.ON's other corporate performance; data relating to the corporate entity, E.ON A.G.

The assurance assignment considered emerging good practice and standards in this area. Specifically, it has been carried out with reference to the AA1000AS assurance standard which requires us to assess the completeness and materiality of information as well as overall responsiveness to the issues, concerns and interests of stakeholders. Our methodology for applying the AA1000 principles is outlined below.

Our level of investigation has been matched to our view of the potential significance of content to E.ON UK's business objectives, its stakeholders and the Report's wider readership. The performance data was checked at a top-level. We did not fully test the accuracy of data capture at the operational level or the robustness of the information management systems that collate it. However, in most cases we were able to rely upon independent checks undertaken by other independent auditors and inspectors.

We have included a separate Assurance Statement in the printed E.ON UK 2007 Corporate Responsibility Review ('Changing Energy').

METHODOLOGY AND WORK UNDERTAKEN

We assessed the overall content and tone of the Report against our understanding of material issues and business performance, taking account of E.ON UK's own approach and processes for determining significance. Where possible, financial and operational content was cross-referenced to the separately audited E.ON Annual Report.

The assurance assignment was carried out between January and June 2008 and consisted of a number of activities, including:

  • 36 interviews with a selection of executives, managers and employees to understand: how corporate responsibility elements are managed; the main elements of strategic focus, priorities and objectives; the degree of implementation across the company; activities that have contributed to 2007 performance; progress against objectives.
  • Review of policies, reports, agendas and minutes to supplement management interviews.
  • Review of a wide range of internal business research, planning and communications documents covering the corporate responsibility agenda.
  • Review of relationships with stakeholders through interviews with key relationship managers and records of stakeholder engagement.
  • Review of the external context for E.ON UK's activities and performance, through a selected review of a selection of external sources and competitors' reports.
  • Visits to the coal-fired power station at Ratcliffe, the biomass combustion plant at Steven's Croft and the underground gas storage site at Holford.
  • Verification of reported data, statements and assertions through: interviews with key authors and providers of data; review of data management systems; sampling of spreadsheets, records, minutes etc.
  • Cross reference of report contents to the Global Reporting Initiative's (GRI's) Sustainability Reporting Guidelines (version 3 - 2006). We did not assess the GRI application level.

We requested a number of changes to the content as part of the assurance process. All significant points raised have been incorporated into the Report to our satisfaction.

CONCLUSIONS

Subject to the limitations noted above, we provide the following conclusions:

  • We are satisfied that the Report provides an accurate and balanced account of E.ON UK's corporate responsibility focus, management activities and performance which are of likely interest to E.ON UK's main stakeholders or that have received management attention during the reporting period.
  • We found the report's underlying processes, systems and competencies to be sufficiently robust for the information to be considered accurate, up-to-date and free from material misstatement or omission.
  • During 2007 there have been major advances in reducing non-operational carbon emissions, health and safety management, customer service, stakeholder engagement and ethical procurement. E.ON UK is increasingly focused on delivering sustainable solutions to current and future energy challenges through its Changing Energy strategic programme.

OBSERVATIONS AND RECOMMENDATIONS

As part of the assurance assignment, we have prepared a separate report for E.ON UK's management, presenting key observations and recommending areas of potential improvement which could bring benefits to the business and its stakeholders. Some key points from this document are summarised below:

The Report

  • We note that E.ON UK has met or is on course to meet 51 of the 57 commitments made in its 2006 CSR Report.
  • We would welcome the inclusion of further details of stakeholder mapping and engagement, both at a corporate level e.g. relating to energy strategy, and at a local level e.g. relating to engagement with local communities. Ideally future reports will present some of the most important stakeholder views.
  • The ethical aspects of business (Code of Conduct, responsible values, ethical compliance, whistleblowing etc) seem to be well communicated and understood across E.ON's operations. We feel that inclusion of these aspects would bring further value to readers of future CR reports.

Governance and Management

  • Overall we have observed that E.ON UK have been extremely thorough in their distillation of issues, analysis and formulation of strategy.
  • This year we have seen further consolidation of environmental management into strategic planning and business processes, under a dedicated environmental leadership team. All areas are now included within an ISO 14001 programme and a range of initiatives has resulted in significant successes relating both to greenhouse gases and other environmental aspects of the company's activities. The executive team now receives quarterly reports on environmental performance. We have made recommendations on the set of key performance indicators used, both for local impacts and for corporate issues.
  • Though not yet reflected in the 2007 performance data, we have seen evidence in 2008 of a new culture being driven top-down and responded to bottom up, following safety initiatives introduced last year.
  • There has been significant progress with the development of a risk assessment methodology for third party suppliers. All stages of the approach have been piloted and efforts are ongoing to bring further alignment with Group standards and supply chain integration.
  • There is evidence of tight control of operational activities across the businesses, coupled with a healthy culture of improvement based management e.g. in environment, health and safety, customer service.
  • E.ON UK are planning the rapid development of a comprehensive set of dashboard indicators to assist with the tracking of progress against future targets, as part of the Changing Energy programme.

Employee Engagement and Integration

  • Employees are recognised by E.ON as the key to delivering Changing Energy. We have been impressed with the communication of, and internal support for, Changing Energy which was reflected in this year's employee opinion survey and in our interviews.
  • There is a strong "can do" culture, a high calibre of management capability and a shared determination to tackle the environmental and societal aspects of energy production and distribution.
  • This has given rise to a large number of very successful bottom-up initiatives across the business which have been well-supported by senior management.
  • more effective internal communication of E.ON UK's CR practices and performance would provide a useful vehicle for ongoing motivation and a shared reference point across the company's businesses.

Stakeholder Engagement

  • Engagement with key stakeholders remains a significant factor in E.ON UK's ability to move towards a more sustainable means of generating and using energy. We have seen some excellent examples of positive dialogue with local communities relating to site developments.
  • The thinking behind E.ON UK's energy strategy takes into account a wide range of societal issues, needs and constraints. However dialogue with stakeholders is not yet as developed or coordinated as it needs to be. We encourage E.ON to focus further on the coordinated mapping of stakeholder views, proactive engagement and the internal exchange and analysis of feedback.
  • The green tariff options represent a core element of the company's low-carbon services. Other new services and products, such as energy conservation and micro-generation are also being introduced to the retail markets. Future success of these initiatives will depend critically upon communication to stakeholders of their potential value.

INDEPENDENCE

This assurance assignment constitutes approximately 18% of The Reassurance Network's annual turnover. We do not have any other commercial involvement in E.ON UK, or any affiliation with E.ON UK's stakeholders or their specific areas of interest. Malcolm Guy and Paul Wenman are directors of The Reassurance Network with a combined total of over 20 years as independent corporate responsibility assurers and advisors with over 25 blue chip organisations.

Paul Wenman and Malcolm Guy

The Reassurance Network
July 2008


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