Consultation on United Utilities statement of risks, strengths and weaknesses 2015/16 Our 2015-20 annual performance reporting

Consultation on United Utilities statement of risks, strengths and weaknesses 2015/16 Our 2015-20 annual performance reporting

United Utilities performance reporting Consultation on our statement of risks, strengths and weaknesses 2015/16 About this document The purpose of this document is to seek views on this statement which we have produced highlighting the risks, strengths and weaknesses associated with providing performance reporting information to customers and other stakeholders. This statement will form the foundation of our assurance plan that will be prepared (and which we will consult on) in advance of the publication of our 2015/16 Annual Performance Report in July 2016. About us United Utilities is the UK s largest listed water company. Through its subsidiary United Utilities Water Limited, it manages the regulated water and wastewater network in the North West of England, providing services to around seven million people and businesses. Achieving our vision Our vision is to become a leading North West service provider and one of the best UK water and wastewater companies. We will deliver this by providing the best service to customers at the lowest sustainable cost and in a responsible manner. Our customer promises Our business plan is underpinned by the outcomes represented by our customer promises. We promise to: provide great water; dispose of wastewater; give value for money; deliver a service customers can rely on and protect and enhance the environment. Our statement of risks, strengths and weaknesses is a key element of this document and summarises: That we have understood and are responding to the requirements of Ofwat s company monitoring framework; How our regulatory reporting assurance framework is designed to ensure that our reporting meets our stakeholders expectations and exceeds Ofwat s requirements; Our initial assessment of the risks, strengths and weaknesses affecting our 2015/16 reporting; and The key areas where we are seeking feedback to further inform the nature and assurance of our future reporting processes This statement is supported by three appendices, which provide more detail on our plans and proposals. Copyright United Utilities Water Limited 2015 1

How to respond We welcome all views on our statement of risk, strengths and weaknesses and the assurance plans that we are putting in place to manage these risks and are specifically seeking feedback from our North West customers and stakeholder on: Do you have any views on our approach to this risk assessment? Do you have any comments on the risks, strengths and weaknesses highlighted? What areas of our performance are most important to you? Are there any other specific aspects of performance that you would like us to report against? As it is our intention to ensure that we have listened to and reflected this feedback in our Final Assurance Plan and Annual Performance Report, we would appreciate your feedback before 31st December 2015 to us at myview@uuplc.co.uk or you can write to us at: Business Plan 2015-20 Consultation United Utilities Lingley Mere Business Park Lingley Green Avenue Great Sankey Warrington WA5 3LP Foreword from Andrea Cook, Chair of YourVoice United Utilities YourVoice panel plays an integral part in monitoring, challenging and reporting on the delivery of the company s 2015-20 business plan commitments to customers and stakeholders as agreed with the water regulator, Ofwat. The panel also looks at how the company can continue to capture and strengthen the views of its customers in its activities. You can read more about the work of the panel at unitedutilities.com/yourvoice I m pleased to introduce the first customer and stakeholder consultation from United Utilities on how it plans to report its annual performance against its business plan commitments. Myself and my YourVoice panel colleagues are committed to our role as customer representatives, being fully independent from UU and impartial in our views. We ll be examining the proposed approach to the assurance of UU s annual performance reporting very closely, to make sure that the final plans reflect both our own, but also wider customer and stakeholder feedback. We want to ensure everyone in the North West can have confidence in the progress that United Utilities is making against its promises to the communities it serves about the water and wastewater service it provides. I d like to take this opportunity to urge customers and stakeholders to send feedback on this proposal to myview@uuplc.co.uk and the panel will ensure your views are heard. We will do all we can to ensure we are your voice. Copyright United Utilities Water Limited 2015 2

Contents Our statement of risks, strengths and weaknesses Appendix 1: Our monitoring and reporting framework 4 11 1.1 Summary of the requirements of Ofwat s company monitoring framework 11 1.2 Processes for complying with these requirements 13 1.3 Annual review timeline 14 Appendix 2: Our regulatory reporting assurance framework 17 2.1 AMP6 reporting requirements 17 2.2 Additional transparency and publications 18 2.3 Independent challenge and review 21 2.4 Measurement and data capture 22 2.5 Risk based assurance 24 2.6 Governance and accountability 27 2.7 Targeted audit and assurance 30 Appendix 3: Regulatory reporting of risks, strengths and weaknesses 32 3.1 Context 32 3.2 Target areas 32 3.3 Summary of assurance approach for targeted areas 34 Copyright United Utilities Water Limited 2015 3

Our statement of risks, strength and weaknesses Background and context In June 2015, Ofwat published its company monitoring framework for the 2015-20 period (known as AMP6). This describes how Ofwat will oversee the information that the largest 18 largest water and sewerage and water only companies in England and Wales provide to customers. The framework supports Ofwat s vision for the water sector in England and Wales where customers and wider society have trust and confidence in vital public water and wastewater services. The purpose of the framework is to ensure that stakeholders can rely on the information provided by water companies and to make sure that the assurance of this information is provided in a way that can help to build trust and confidence. There are two distinct elements to the framework; a) the data assurance activities that companies put in place to provide accurate data and b) the wider assurance that they provide to demonstrate that they are listening to customers and delivering services they want and can afford. As part of the development of the framework, Ofwat assessed companies against three categories: selfassurance, targeted assurance and prescribed assurance. The framework requires all companies to provide explicit sign off on the assurance that has been provided; full transparency on the audit procedures and; a summary of the outcome of the assurance that has been carried out. Along with 14 of the 18 water companies in the UK, we were assessed as being in the targeted assurance category, which means that in addition to basic reporting requirements, we re also required to carry out an exercise with stakeholders to establish focus areas to target, and to publish a statement on this in the Autumn of each year, prior to the provision of information. For specific areas that this stakeholder feedback highlights, we are then required to publish a Draft Assurance Plan and engage again with stakeholders before confirming our Final Assurance Plan. Our approach We fully support Ofwat s vision for the water sector in England and Wales, where customers, the environment and wider society have trust and confidence in vital public water and wastewater services. We are accountable to our customers for delivering the services they need and want, at a price that they can afford. We have engaged with over 27,000 customers and worked with our PR14 Customer Challenge Group, now known as YourVoice, to develop a business plan for the AMP6 period (2015-20), which aims to reflects our customers views and strike the appropriate balance between improving service and reducing cost. Our business plan was designed to be challenging, with further substantial cost and performance pressures being added by Ofwat through the price determination process. The target service levels, expenditure levels and resultant customer bill impacts developed through this process are set out in the Final Determination (UU Specific appendix ), which was published by Ofwat in December 2014. Copyright United Utilities Water Limited 2015 4

All water companies in the UK and Wales will report on their financial and operational performance against this determination, in a new annual performance report in July each year, beginning in July 2016. This report will include information that specifically responds to feedback from our customers and stakeholders, together with information that is designed to be comparative across the sector. We believe that reliable measurement, assurance and transparent reporting of our performance is essential to maintain the confidence of our customers, investors, stakeholders and regulators and to support the objectives of Ofwat s company monitoring framework. This statement summarises how we will ensure that the data assurance activities that we have put in place provide reliable, accurate and complete data and that the wider review and assurance activities that we undertake allow us to effectively demonstrate that we are listening to customers and delivering the services that they want and can afford. Our approach to the monitoring and reporting framework 1 We have adopted an approach to ensure that we meet the requirements of Ofwat s AMP6 company monitoring framework. The process is designed to ensure that our Board is provided with robust data in a timely manner that it requires to explicitly sign off the assurance of our data and also to ensure that we will consult effectively with our customers and other stakeholders on the content and format of our reporting. We have established a new annual review cycle, involving the participation of our new customer forum, the YourVoice panel, designed to listen to and incorporate the feedback and priorities of our customers and other stakeholders. When mature, the publication of the new annual performance report will be both the start and finish of this annual reporting cycle. This will allow lessons learnt from the last report to be assessed effectively, new risks to be identified and managed, and a continual improvement cycle to be established. As 2015/16 is the first year in the AMP6 cycle and the planned review process is not yet fully established, the approach adopted for the first year of the AMP, 2015/16 will vary slightly from subsequent years. We have already engaged with the YourVoice panel and have agreed an approach for obtaining its feedback and guidance on the nature of our reporting and on the assurance of the data on which it is based. The views from the YourVoice panel 2, together with the feedback that we receive from our customers and other stakeholders, will be used to develop our Final Assurance Plan and to influence the coverage and format of our 2015/16 Annual Performance Report. Our approach to assurance of our data and reporting 3 Coverage of our reports Our annual performance report will cover key information to demonstrate how we are complying with our regulatory and statutory obligations, and to track our performance against the delivery of our AMP6 business plan commitments 4. 1 See appendix 1 2 See appendix 2 section 2.3 3 See appendix 2 4 See appendix 2 section 2.1 Copyright United Utilities Water Limited 2015 5

Transparency and publications In addition to publishing the base information set out by Ofwat in our annual performance report, we will also provide appropriate additional commentary to enable customers, investors and other stakeholders to interpret the information within the report effectively, and to analyse our relative and absolute performance. We will also continue to provide additional, wide-ranging and specifically tailored reporting of our performance and are actively seeking to further enhance the transparency of the underlying information and messaging to customers and other stakeholders 5. Independent challenge and review A key part of the role of the YourVoice panel is to provide additional independent review and assurance of our data. Minutes of the panel s quarterly meetings will be shared with our Board, with the YourVoice Chair attending a Board meeting at least annually. At this meeting, the Chair will discuss the panel s independent report and outline the findings of its review and challenge processes 6. YourVoice also has a key role in ensuring that we are listening to customers and delivering services they want and can afford. Measurement and data capture The details of some elements of our business plan, such as outcome performance commitments, the associated measures-of-success and delivery incentives can appear complex. To help clarify, we have developed a series of detailed definition documents that explain how the outcomes, commitments, measures and incentive (where applicable) all work together. These documents will be published on our web site. We have also set out clear, formal accountability for our financial and operational performance information. Data that is required to support our regulatory reporting is measured and assured through a robust and clearly documented process. Performance against our AMP6 commitments is actively monitored, challenged and managed on an ongoing basis 7. Risk based assurance processes We already apply a structured risk assessment approach to underpin the assurance process supporting our regulatory reporting. This is designed to ensure that any potential reporting risks are identified and escalated appropriately. This approach has been refreshed to ensure that it complies with good practice and covers all aspects of the company monitoring framework. Our risk assessment process is used to determine the specific governance and assurance arrangements that are applied to each part of our regulatory reporting. It is also used to ensure that any identified risks are being actively monitored, with mitigating actions designed to address these risks being effectively managed 8. Governance and accountability We are committed to the very highest standards of corporate governance and during the financial year ending 31 March 2015, we have fully complied with the principles and the spirit of the UK Corporate Governance Code and proactively published a long term viability statement. 5 See appendix 2 section 2.2 6 See appendix 2 section 2.3 7 See appendix 2 section 2.4 8 See appendix 2 section 2.5 Copyright United Utilities Water Limited 2015 6

We have also already adopted the principles of transparent reporting. United Utilities Group PLC Annual Report and Financial Statements for the year ended 31 March 2015 was prepared in accordance with the principles published by the International Integrated Reporting Council in December 2013. In recognition of this, the report has been awarded the Building Public Trust award for Reporting Excellence. Our Board is directly accountable for the quality and transparency of the information that we provide on our performance. To support this we have established comprehensive governance and accountability regimes, which fully comply with our statutory and regulatory requirements 9. Audit and assurance The approach we are taking to audit and assure our data and reporting during AMP6 will continue to be based upon the Three lines of defence approach that we have successfully used for our AMP5 (2010-15) regulatory reporting. This will ensure that we can effectively control, monitor and continually enhance the governance and assurance of our regulatory data. For the AMP6 period, our performance and reporting will be also reviewed and challenged by the YourVoice panel. This review will now form an additional part of the third line of defence, with its findings being presented to our Board, alongside the findings of our Corporate Audit team and the external technical and financial auditors 10. Risks, strengths and weaknesses in our reporting 11 We have used our risk assessment and assurance approach to determine the areas of greatest potential risk to our 2015/16 Regulatory Reporting. This review has confirmed that our established systems of governance and control are effective in identifying and managing reporting of risk levels. The risks identified through this process have therefore generally been as a result of external changes in reporting requirements as we make the transition from a reporting regime designed for AMP5 (2010-15) to a new one for AMP6; and from internal change to processes, controls or information systems, as we change our business to better address the future challenges and changes in the water industry. The key target areas identified through this review are summarised below 12. Further details of the risk assessment process, the feedback from this consultation, and our proposals to manage these potential risk areas, will be covered in our Draft Assurance Plan 2015/16 which will be published in December 2015. 1. Outcome delivery incentives (ODIs) (new requirement) In preparation for AMP6 the new outcome delivery incentive performance data was incorporated into 2014/15 business score cards and regulatory reporting at month six, month nine and at year-end. This entailed a review of the end to end ODI reporting process (including definition documents, methodologies, data and performance and commitment statements) to allow us to understand our preparedness for reporting the information in AMP6. This process has allowed us to be well placed for our 2015/16 reporting. However, the reporting of our ODIs will remain a high profile issue and we will set out details of the assurance we are applying to our ODIs in our Draft and Final Assurance Plans. 9 See appendix 2 section 2.6 10 See appendix 2 section 2.7 11 See appendix 3 12 See appendix 3 Copyright United Utilities Water Limited 2015 7

2. Price review and segmental reporting (new requirement) The 2015/16 Annual Performance Report will require our income and expenditure to be reported separately against each price control and accounting units. We have recently taken steps to allow us to more effectively capture and report our costs in this way. There are some areas where the rules for separating such costs are still to be fully defined and it would appear that different companies are allocating costs to different accounting units in different ways. We need to allow customers and stakeholders to look at our performance and compare it meaningfully with that of other companies; more work will be required across the industry to achieve this. 3. Prediction of future performance levels (new requirement) The annual performance report will require companies to report actual performance and expenditure for the report year under review and in some areas to also predict future performance levels for the remainder of the AMP6 period. This predicted information will clearly be subject to greater uncertainty than the historic data. 4. Profile of water quality performance (changed expectations) During the year we have experienced two major incidents one at the Sweetloves Water Treatment Works in Bolton, Greater Manchester and one at the Franklaw Water Treatment Works, in Lancashire. These incidents resulted in a loss of water supply (Bolton) and in customers needing to boil their water (both Bolton and Franklaw). As a consequence of these issues, we recognise that there is likely to be greater scrutiny on our ability to provide great water; customers and stakeholders are likely to be more sensitive to our performance around water supply and quality. 5. Business retail market reform (new requirement) Accountability for reporting of billing contacts, written complaints and associated guaranteed service standards (GSS) transferred from Domestic Retail to Wholesale and/or Business Retail during 2014/15. This transfer of responsibilities helps to set clear separation of accountabilities as we prepare for market reform in 2017. This preparation for market reform has also involved the implementation of a new non-household customer management and billing system, Mecoms. With business process and systems changes such as this comes inherent risk, and the business has worked hard to mitigate initial teething problems related to the implementation of the new systems. We continue to closely monitor the situation to ensure the changes we have made are robust and fit for the future, allowing us to deliver on our promises to both household and non-household customers. Summary of our assurance plans We have used our risk assessment approach to target the assurance activities that will apply to our annual performance report. All areas of the report will be subject to a structured three lines of defence governance process 13 with internal in-year review processes being applied to the targeted areas and the reported data being subject to detailed third party audit processes. 13 See appendix 3.3 Copyright United Utilities Water Limited 2015 8

Further details We have published three appendices to support this statement: Appendix 1: Our monitoring and reporting framework sets out the requirements and expectations of Ofwat s AMP6 (2015-20) company monitoring framework; the processes that we are putting in place to meet these requirements and the timeline that we are adopting to develop, consult on and publish the regulatory performance and assurance reports that form part of the framework. Appendix 2: Our regulatory reporting assurance framework sets out the assurance activities that we have put in place to provide reliable, accurate and complete data, together with the wider assurance activities that we are undertaking to ensure that we incorporate our customers and other stakeholders views and continue to deliver the services that they want and can afford. Appendix 3: Regulatory reporting of risks, strengths and weaknesses sets out a summary of the risks, strengths and weaknesses that have been identified through our assurance and consultation processes for our 2015/16 reporting cycle and summarises the actions that we are putting in place to manage these risks. Next steps and feedback This statement of risks, strengths and weaknesses identifies the target areas that we are planning to focus on in our 2015/16 regulatory reporting processes. We will be providing more detail of our plans to ensure that these risks are adequately and transparently managed, in a Draft Assurance Plan 2015/16. This plan will be published in December 2015 and will include: Conclusions of the initial feedback on this statement and demonstration of how this feedback has been incorporated within the Draft Assurance Plan Details of the risk assessment process that has informed the assurance plan Conclusions from the risk assessment of a) the 2014/15 reporting process and b) our ongoing internal reviews of our regulatory reporting, highlighting any changes in risk levels for 2015/16 compared to those in previous years Key assumptions and any caveats affecting this year s (2015/16) reporting Details of the proposed initiatives and action plans that we are implementing to manage or mitigate these target risk areas Details the proposed governance and assurance process that we are implementing to ensure customers can have confidence in our reporting. Copyright United Utilities Water Limited 2015 9

Following consultation on the Draft Assurance Plan, we will publish a Final Assurance Plan 2015/16. This plan will be published before the end of the financial year and in advance of the reporting cycle and will include: Revisions to the risk assessment identified as a result of the internal nine month regulatory reporting exercise Summary of the stakeholder feedback and a demonstration of how this feedback has influenced our Final Assurance Plan A summary of the overall assurance approach that we will apply to our 2015/16 regulatory reporting Details of the specific activities that we are undertaking to manage the potentially higher risk areas. We believe that it is important that our customers and stakeholders have trust in the information that we publish and that there is transparency of our reporting process. We are also keen to ensure that our publications provide the information that our customers and stakeholders want, and is in a format that they will appreciate. We are seeking views and comments on the proposals outlined in this statement and supporting appendices. The results of this feedback will be used to support the development of our assurance plans and also to support the development of our first AMP6 annual performance report, which will be published in July 2016. You can find out more about how to send your feedback on this statement at the front of this document. Copyright United Utilities Water Limited 2015 10

Appendix 1: Our monitoring and reporting framework This appendix to our statement of risk, strengths and weaknesses 2015/16 sets out the requirements and expectations of Ofwat s AMP6 company monitoring framework; the process that we are putting in place to meet these requirements and the timeline that we are adopting to develop, consult on and publish the regulatory performance and assurance reports that form part of the framework. 1.1 Summary of the requirements of Ofwat s monitoring framework In June 2015, Ofwat published its company monitoring framework for the 2015-20 period, which describes how it will oversee the information that the largest 18 largest water and sewerage and water only companies in England and Wales provide to customers. Under this framework each company has been assigned to one of three categories, implying a different confidence rating and assurance requirements. The categorisation and assurance requirements for each of these categories is set out in figure 1.1 below. Figure 1.1 Ofwat s monitoring framework categorisation and assurance requirements Assurance Category Selfassurance Targeted assurance Prescribed assurance Assessment and assurance requirements Alongside each set of information they provide, the Boards of these water companies must provide: 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 Companies, in conversation with their stakeholders, are best placed to identify where the risks, strengths and weaknesses arise in providing the quality of information that stakeholders want and will trust. 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; and 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 Plans and speak with and listen to stakeholders before confirming final 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 weaknesses exercise that a prescribed company carries out with stakeholders will highlight the areas of reporting that have the most significance or are of greatest risk to customers. For these areas the company will need to incorporate independent external assurance as part of its assurance plans. Company categorisation South West Water Affinity Water Anglian Water, Bristol Water, Dwr Cymru, Northumbrian Water, Portsmouth Water, Severn Trent Water, South East Water, South Staffordshire Water, Southern Water, Sutton & East Surrey Water, Thames Water, United Utilities Water, Wessex Water, Yorkshire Water Dee Valley Water Copyright United Utilities Water Limited 2015 11

Ofwat made its initial assessment in February 2014 against companies performance within the 2014 price review process, and against the broader regulatory framework. This was used to determine its overall level of confidence in each water company s ability to deliver, monitor and report their performance. The assessment was based on the following considerations: the overall quality of companies PR14 business plans; the adequacy of companies subsequent assurance over PR14 business plan revisions, and quality of supporting data; the robustness of companies proposed arrangements for monitoring; reporting and assurance of their outcomes to customers and stakeholders; companies regulatory accounts; the appropriateness of companies draft charges for 2015-16; whether companies have needed to pursue formal enforcement action to investigate or secure companies compliance against their existing obligations; and whether companies have put in place arrangements to meet Ofwat s principles of Board leadership, transparency and corporate governance Observations on the PR14 process were given the greatest weighting for the initial assessment due to the timing of the assessment and the significance of the price review process. The initial assessment of United Utilities placed us in the targeted assurance category, along with the majority of the other UK water companies (see figure 1.1 above). Details of the initial categorisation are set out in Ofwat s company monitoring framework initial assessment. As part of the company monitoring framework, Ofwat requires all targeted or prescribed companies to undertake the activities set out in Figure 1.2 below. Figure 1.2: Specified annual assurance processes Activity Description Engagement on risks Companies proactively engage to give stakeholders the opportunity to provide input to the strengths and exercise weaknesses exercise Publish risks, strengths Companies complete and publish statements on their risks, strengths and weaknesses and weaknesses exercise. They need to publish this before they can publish Draft Assurance Plans. statement Companies must consider how they can effectively engage with stakeholders on assurance plans when deciding on the timing of publication. All statements must be published well in advance of the 30 November Publish Draft Assurance Plans Engagement on assurance plans Revises categorisation on website Publish Final Assurance Plans Companies publish Draft Assurance Plans. They must consider how they will be able engage stakeholders before publishing final plans when deciding on the timing. Companies proactively engage to stakeholders the opportunity to provide comments on assurance plans. By 30 November, Ofwat will revise the categorisation. This will follow the publication of the statement on risks, strengths and weaknesses for each of the companies in the targeted category. The first time that companies will be able to move from the targeted category to the selfassurance category will be 2016. Companies publish Final Assurance Plans, providing responses to any comments they have received Copyright United Utilities Water Limited 2015 12

1.2 Processes for complying with these requirements The process that is being adopted to comply with the requirements of the company monitoring framework, is illustrated in Figure 1.3 below. Figure 1.3: AMP6 risk assessment and assurance process - overview Regulatory information, assurance & audit outcomes from previous reporting year Assurance and risk reduction activity Risk assessment and consultation Final Assurance Plan Targeted assurance requirements Ofwat reviews and re - assesses company assurance category Stakeholder consultation Draft Assurance Plan This diagram illustrates that published regulatory data and information, together with key supporting information, will be subject to a structured risk assessment and consultation process. The results of this risk assessment process are fed into the company s risk management process, to ensure that actions are initiated to reduce, manage or mitigate any identified risks. The risk assessment is also used to inform the risk based governance and assurance plans for both the in-year and year-end regulatory reporting processes. Additionally we will now also be using the output from this risk assessment review to allow us to develop and publish a new, annual statement of risks, strengths and weaknesses (this document) followed by a Draft Assurance Plan. Both these documents will be subject to consultation with our customers and other stakeholders, with the new statement of risks, strengths and weaknesses forming the basis of Ofwat s annual review of our assurance category. The feedback from this consultation will be used to ensure that our assurance activities are proportionate and properly targeted. Copyright United Utilities Water Limited 2015 13

1.3 Annual review timeline Overview of the annual timeline We have established a new annual review process, to allow us to meet the requirements and expectations of the company monitoring framework. This process involves the active participation of our new customer forum the YourVoice panel 14. When mature, the publication of our new annual performance report will be both the start and the finish of this process. This will allows lessons learnt from the last report to be assessed effectively, new risks to be identified and managed and a continual improvement cycle to be established. However, as 2015/16 is the first year in the AMP6 cycle and the planned review process is not yet fully established, the approach adopted for 2015/16 will vary slightly from subsequent years. Figure 1.4 below illustrates the timing of the key steps in the annual review process that will be adopted following the development and publication of the 2015/16 Annual Performance Report in July 2016. Figure 1.4: AMP6 risk assessment and assurance process timeline from 2016/17 onwards Key steps in the process Publish annual performance report - This new report will include the key information specified by Ofwat to demonstrate how we are performing against our PR14 regulatory contract obligations and to track delivery of commitments. It will also contain additional information to provide an appropriate context and greater transparency on the reported performance levels. Alongside our annual performance report, our Board will provide explicit sign off on the assurance that it is providing, a summary of the audit procedures that have been followed and a summary of the outcome of the assurance that we have carried out. Specific engagement on risks strengths and weaknesses - We will work closely with the YourVoice panel and undertake specific engagement with other key stakeholders, following the publication of each year s annual performance report. This work will identify any areas where we can introduce appropriate changes to further improve the reliability or presentation of our assurance and reporting process. 14 See appendix 2 section 2.3 Copyright United Utilities Water Limited 2015 14

Publish targeted areas assessment - Any areas targeted through this review process will be reflected in the annual statement of risk, strengths and weaknesses in our regulatory reporting, which will be published each October. Ofwat publishes assurance categories 30/11/15 - Following the publication of our statement on risks, strengths and weaknesses, Ofwat will review its assurance categorisation of the company. This review will be published on the Ofwat website by 30 November each year, although the first time that companies will be able to move category will be 2016. Publish Draft Assurance Plan for targeted areas - The output from our review of risks strengths and weaknesses, will be used along with any feedback from Ofwat to develop a Draft Assurance Plan. This will provide an overview of the assurance that we are proposing to adopt for our regulatory reporting and more detail of the assurance being applied to the targeted areas identified within the statement of risks strengths and weaknesses. The Draft Assurance Plan will be published each December. Specific engagement on assurance plans Following the publication of the Draft Assurance Plan, we will continue to engage with the YourVoice panel and engage with customers and other stakeholders on the key areas to be addressed within of the Final Assurance Plan, and the nature and coverage of the following year s annual performance report. Publish Final Assurance Plan for targeted areas The feedback together with the results of the ongoing risk assessment and assurance activity will be used to complete the Final Assurance Plan, which will then be used to ensure that our risk based annual assurance exercises are proportionate and appropriately targeted. Ongoing and year-end risk, assurance and regulatory reporting The detailed processes for developing, reporting and assuring the information and presentation of our regulatory reporting are set out in appendix 2 of this document. Variation to this process for the current financial year Figure 1.5 below illustrates the revision to the process that is being adopted for the current financial year. Figure 1.5: AMP6 risk assessment and assurance process timeline 2015/16 only Copyright United Utilities Water Limited 2015 15

For the current financial year, we do not have a previous annual performance report to use as the basis for the review process. Although we have also recently established the new YourVoice panel and have discussed the requirements of the company monitoring framework with the panel, we have not been able to undertake the depth of review which will be able to be undertake in subsequent years. We have therefore predominantly undertaken our assessment of risks, strengths and weakness in our reporting based upon: feedback from the PR14 Customers Challenge Group (the predecessor of the new YourVoice panel) and other stakeholders in developing our PR14 business plan submission; feedback we have obtained from customers and other stakeholders following the business plan submission and on the risks identified in undertaking a trial run of the new annual reporting data as part of the 2014/15 reporting cycle. We have, however, agreed with the YourVoice panel a process for obtaining their feedback and guidance on the nature of our reporting and on the assurance of the data within this reporting. This feedback will be used to develop our Final Assurance Plan and the coverage and format of our 2015/16 Annual Performance Report. Copyright United Utilities Water Limited 2015 16

Appendix 2: Our regulatory reporting assurance framework This appendix to our statement of risk strengths and weaknesses 2015/16 sets out the assurance activities that we have put in place to provide reliable, accurate and complete data, together with the wider assurance activities that we have established to ensure that we can take account of our customers and other stakeholders views and continue to deliver the services that they want and can afford. 2.1 AMP6 reporting requirements For the AMP6 period, all UK water companies will report on their financial and operational performance in a new annual performance report 15. This report will include information that is specific to our customers and stakeholders together with information that is designed to be comparative across the sector. The annual performance report will cover key information to demonstrate how we are complying with our statutory and regulatory obligations and to track our performance and delivery of our PR14 business plan commitments. The report will be structured into four main areas. These areas and the intended coverage and purpose of the reporting in these areas is set out in Figure 2.1 below: Figure 2.1: Regulatory reporting risk assessment scoring criteria Area Coverage and purpose 1. Regulatory financial A baseline level of historical cost financial information aligned to reporting the way in which price controls (and associated regulatory performance commitments and incentives) have been set 2. Price control and additional segmental reporting Further disaggregation (i.e. separation) of revenue and costs, to allow stakeholders to review companies performance against final determinations. 3. Performance summary A high-level report of the performance of the appointed business, including outcome delivery and the regulatory financial results of the regulated business. As a minimum it will include reporting on outcomes and delivery service levels and cost performance. 4. Additional regulatory information Additional financial and non-financial information, including (but not limited to), additional accounting policies, financeability statement, current cost reporting, Totex analysis. The more detailed coverage of the annual performance report is shown in Figure 2.2 below, with a link to the tables available via the footnote below. 15 Ofwat regulatory reporting proforma tables, 11 February 2015 Copyright United Utilities Water Limited 2015 17

Figure 2.2: Ofwat s new regulatory report structure AMP6 annual performance report Risk and compliance statement Section 1 Regulatory financial reporting Section 2 Price review and other segmental reporting Section 3 Performance summary Section 4 Additional regulatory information Statutory obligations Income Income and cap contributions Common outcomes (3a) Households and volumes (4b) Licence conditions Financial position Expenditure Totex (4c) Regulatory obligations Cash flow Fixed asset analysis Regulatory capital value (4d) Debt Revenues and charges 2.2 Additional transparency and publications Approach In addition to publishing the minimum information requirements set out by Ofwat and described in section 2.1 above, we are committed to providing regular and transparent reporting on our performance against each measure of success, and to updating customers and other stakeholders on delivery against our Totex 16 baselines, performance commitments and customer promises. We will use a broad range of communications channels to communicate with our customers, with the information in our annual performance report, made available in an engaging manner, via our web site. We will provide a summary of overall company performance covering all aspects of the new annual performance report. Although the focus will be on the current year s performance, the report will also set out information about the accumulation of any potential penalties and rewards resulting from the company s outcome delivery incentives package (i.e. performance based rewards or penalties), or relative performance against the final determination Totex expectations and baselines. A detailed supporting commentary will also be provided for customers, including the most relevant background information and will reflect the detailed review of our performance that some of our stakeholders may seek to undertake. 16 Totex is a combination of our capital and operating expenditure Copyright United Utilities Water Limited 2015 18

The style, coverage and format of these performance reports will be agreed with the YourVoice panel, who will also review and challenge the data and supporting commentary that we include in the reports to help to ensure that the information is a fair reflection of our performance. The relevant sections of the performance data will also be incorporated within our United Utilities Group PLC Annual Report and Financial Statements (published in June), and our online Corporate Responsibility Report updates (appearing quarterly). In addition to these specific and formalised reporting cycles, we will continue to provide a comprehensive range of other customer and stakeholder communications. Listed below are four communication activities we will undertake in AMP6 to communicate performance to stakeholders. a. Online performance report Our existing performance report is designed to provide a balanced high level overview of the company s performance against a suite of common AMP5 key performance indicators. In its place we will develop new engaging and interactive online reporting format to allow customers to access the information contained within the new annual performance report in a compelling and attractive format. Supporting commentary will highlight where performance targets have either been met, exceeded or have not been achieved and will explain some of the key decisions and trade-offs that we have made in the year. The information will also set out our proposed plans and anticipated performance and expenditure levels for the remainder of the 2015-20 period. The financial impact of our performance and expenditure levels through the Totex and outcome delivery incentive schemes will be highlighted in the commentary, along with any additional costs which have arisen in the period. Our annual performance report would be published each July on our corporate website. b. Supporting definition-of-terms We will provide more detailed definition and explanation of our AMP6 measures of success at two main levels. We will develop a simple but engaging format to depict and explain each of the AMP6 measures of success and outcomes. This information will be published on our customer-facing website and would act as a route into our annual performance report and supporting information. In addition, we will publish detailed technical documents to clarify the coverage and detail behind our performance commitments, and any outcome delivery incentives, associated with these performance commitments. These documents will reflect information published in the PR14 final determination and provide greater detail on the purpose, coverage and incentive regimes associated with each measure. Copyright United Utilities Water Limited 2015 19

c. Additional regulatory publications and communications To allow the YourVoice panel to review and challenge our performance and to review and scrutinise our reporting effectively, we will provide it with detailed and regular updates on performance. We will provide actual performance levels against targets at least quarterly, and will clearly indicate the current and predicted future performance levels relative to expectations and ODI parameters. We also provide Ofwat with a copy of the 2015/16 Annual Performance Report with specific additional commentary to describe our performance against any non-green measures and would discuss any material risks or issues with Ofwat ahead of publication of the report and provide any other information as requested. We will also work with our other regulators, such as the Environment Agency, Drinking Water Inspectorate, Consumer Council for Water, Public Health England and the Health and Safety Executive, continuing with our programme of regular liaison meetings and providing all relevant regulatory data, as and when required. d. Additional customer communication channels We will continue to use both new and existing communications channels to share and seek feedback on our performance with our customers and stakeholders. We recognise that one size does not fit all when it comes to communication, so there will be a range of tailored communications activities targeted at our North West audiences, to ensure that we are as transparent as possible about our progress against our promises. Alongside our dedicated web pages highlighting annual performance reporting, our communications strategy will engage both customers and stakeholders. In preparation for AMP6, we put in place a new stakeholder engagement team, whose role is to work across a specific patch, to coordinate engagement about our activities in that area. In addition, we have a customer communications team who support by creating materials which help promote understanding of the projects that are underway, and offer opportunities to give regular feedback as we deliver our plans. We will continue to run campaigns such as Great Value, which uses an experiential approach to focus on one-to-one engagement with customers about what do you get for your money? We will use this as an opportunity to help customers understand their water bill, and importantly, be reassured about how we spend money on their behalf by sharing our performance reporting. Being able to help our customers link paying their water bill to our annual performance is a vital part of our communications over coming years. We ll also use the activity of our external affairs team to engage with our local MPs, local authorities, key media and influential bloggers to give added cut-through for our communication on outcome delivery performance. Copyright United Utilities Water Limited 2015 20

2.3 Independent challenge and review Approach To ensure that our reporting is independently challenged we have established a new independent stakeholder forum called: the YourVoice panel. This forum builds upon the work of the Customer Challenge Group (CCG) established to support the development of our PR14 business plan submissions. The forum now has increased representation for the voice of the customer and will both monitor and challenge us on the delivery of our business plan, review and assure our reporting and scrutinise our customer engagement on the development of future business plans. Role of the YourVoice panel As described in section 1 of appendix 1 to our statement of risks, strengths and weaknesses, we will provide the panel with regular updates on our performance against each of our performance commitments. We would also review and discuss potential actions the company has taken or is planning to take to deliver the current or target performance levels, together with the impacts that these actions could have upon potential financial penalties and rewards. This forum provides the ideal opportunity to have detailed and transparent reviews of the risks, issues and opportunities facing the company with customer representatives and to have open and honest two way conversations with them to help to ensure that our plans reflect our customers views and that we continue to deliver the services that we promised. We will work with the YourVoice panel to ensure that we provide information for customers and stakeholders that is reliable, timely, appropriate to the audience, and that we are seen to be transparent with customers and stakeholders about the data assurance that we have put in place. This work will also ensure that the information that we publish is transparent, easy to understand and navigate, and is relevant to and provides an appropriate context for the audience which it is aimed at. We will also work with the YourVoice panel to help to tailor the type and extent of engagement to each particular type of stakeholder and ensure that we are timely in carrying out this engagement. We will also seek to target our review of specific or more specialist issues with relevant stakeholder groups, to ensure that we can get effective and representative feedback and ensure that any decisions that we make as a result of this feedback are made on the basis of what is in all our customers best interests. The terms of reference of YourVoice are: Quarterly meetings, providing quarterly minutes to the United Utilities Water Board Chair to attend our Board meeting annually Review progress against AMP6 performance commitments, including contractual rewards and penalties, and to challenge the company to continue to deliver to plan Advise and challenge us on how to deal with the financial impact of over- or under-performance against outcome commitments Review of our annual assessment of risks, strengths and weaknesses in its reporting against each measure of success Advise on the timing and sharing of cost of new obligations with customers Provide a forum for supporting on-going engagement activities, helping to develop and monitor customer research and providing constructive feedback of business-as-usual activities Contributing to the design and presentation of new performance reports (content and format), to be used to inform customers of progress against outcome commitments, during AMP6 Copyright United Utilities Water Limited 2015 21