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[]
[]
[null,"Version"]
[]
[null,"Reference"," Date"]
[null,1,"2024-09-01"]
[null,1.1000000000000001,"2025-09-03"]

{"sheet":"Change Log","index":1,"n_rows":9,"n_cols":9,"rows_kept":9,"cut":false,"hidden":true,"merged":[[1,1,1,8]]}
[]
[null,"Change Log"]
[]
[null,"Change\nReference","Description of change request","Requested by","Date request received","Rationale for Change","How request was processed","Rationale"," Date"]
[null,25.01,"Add details of panel oversight of risk mitigation","SP ENW","Aug '25","Allows the panel to track its oversight of the risk mitigation activities","Approved by DSO Panel 03/09/2025"]
[null,25.02,"Add \"DSO risk framework\" tab","SP ENW","Aug '25","Allows easier review of risk scoring by removing risks that are n/a to DSO:DNO conflicts eg safety","Approved by DSO Panel 03/09/2025"]
[null,25.03,"Risk scoring reviewed post Governance Framework review\nRisk 1 - impact 2 to impact 3 (total risk from 3 to 6)\nRisk 1a - impact 2 to impact 3 (total risk from 3 to 6)\nRisk 1c - both 1 to both 2 (total risk from 1 to 4)","SP ENW","Aug '25","Scoring amending pending finalisation of detailed processes and compliance assurance review","Approved by DSO Panel 03/09/2025"]
[null,25.04,"Additon of conflict tracking framework","SP ENW","Jan '26"]
[null,25.05,"Addition of risks 4,5,6,7","Panel/ SP ENW","Jan '26"]

{"sheet":"Guide","index":2,"n_rows":17,"n_cols":2,"rows_kept":17,"cut":false,"hidden":false,"merged":[]}
[]
[null,"Guide to Conflicts of Interest risk log"]
[]
[null,"1. Introduction"]
[null,"This document is a risk log for SP ENW's DSO activities in RIIO-ED2. It captures the pre-identified conflicts of interest which could arise and compromise the DSO's ability to reach best outcomes as well as conflicts of interest that have been raised by SP ENW employees and relevant third parties "]
[]
[null,"Comments and input by any parties are welcome, please send them to dso@enwl.co.uk"]
[]
[null,"2. Definitions"]
[]
[null,"Conflict of interest :  A situation that has the potential to undermine the impartiality of DSO decision-making/outputs/activities"]
[]
[null,"3. About the processes"]
[]
[null,"Full details of SP ENW's DSO Conflict of Interest Policy and process can be found here:  https://www.enwl.co.uk/globalassets/future-energy/dso/reports/dso-governance/dso-conflicts-of-interest-policy-and-process-march-2026.pdf"]
[]
[null,"This is an internal document, published for transparency.The document is live and is updated by the DSO Compliance Officer on an ongoing basis. The live version of this document is stored on the SP ENW corporate database. Any copy in electronic or printed format may be out of date. "]

{"sheet":"Pre-identified risks","index":3,"n_rows":15,"n_cols":16,"rows_kept":15,"cut":false,"hidden":false,"merged":[]}
[]
[null,"ID","Process Area","Topic","Entities","Description of risk and/or conflict of interest","Impact","Likelihood","Risk rating","Owner","Mitigation strategy","Related outputs","Impact","Likelihood","Controlled risk rating","Next steps"]
[null,"R1","Planning & Network Development","Strategic Regional Planning","DNO-DSO-Connecting customers","The Regulatory Framework incentivises DNOs to be cautious in investment planning to minimise the risk of over-build and stranded assets. There is a risk that this encourages \"incremental\" network build driven by high certainty connection requests, rather than designing for longer-term strategic network development which may be more efficient in the long run and enable faster connections.",4,3,{"$f":"G3*H3","v":12},"Head of DSO","1. The DSO and DNO work together in collaboration with stakeholders such as Local Authorities to build a strategic view of likely system development and  to inform a long-term view on system needs\n\n2. DSO support to Local Authorities for development of Local Area Energy Plans assists in building the evidence base to support regional plans.\n\n3. DSO and DNO working together with a joint sign-off requirement enables assessment of plans from two independent perspectives balancing different needs.","Network Development Plan (NDP)\n\nLong-Term Development Statement (LTDS)\n\nDSO:DNO governance framework and supporting process documents",3,2,{"$f":"M3*N3","v":6},"Need to decide whether to capture next steps for each line"]
[null,"R2","Planning & Network Development","Forecasting generation and demand - scenario development","DNO-DSO","There is a risk that the DSO adopts an overly cautious approach to generation and demand uptake scenarios whilst seeking to manage costs to consumers and scenario risk, resulting in a slower than necessary network build and slower connections.",4,2,{"$f":"G4*H4","v":8},"Head of DSO","1. Broad annual stakeholder engagement in DSO development of Distribution Future Energy Scenarios (DFES), including DNO review and feedback.\n\n2. DSO support to Local Authorities for development of Local Area Energy Plans assists in building the evidence base to support DFES.\n\n3. Emerging NESO tRESP / RESP interaction will provide top-down triangulation of national needs.","Distribution Future Electricity Scenarios (DFES)",2,1,{"$f":"M4*N4","v":2}]
[null,"R3","Planning & Network Development","Forecasting generation and demand - national vs. local plan alignment","DNO-NESO","There is a risk that NESO tRESP/RESP top-down plans may not align with local stakeholder views captured in the SP ENW DFES, or with SP ENW's internal views and risk appetite, leading to misaligned investment planning at the national and local level and reducing efficiency.",3,4,12,"Head of DSO","1. Proactive participation in tRESP process interactions, and discussions for evolution and development of enduring RESP.\n\n2. Continued development of high-quality DFES in collaboration with local stakeholders to produce best view of local / bottom-up requirements.\n\n3. Identification of any material differences in scenarios to be discussed with NESO and transparently reported.","Distribution Future Electricity Scenarios (DFES)",3,3,9]
[null,"R4","Planning & Network Development","System and network needs assessment","DNO-DSO","There is a potential for conflict of interest in the role of the DNO in determining system and network needs whilst also financially benefitting from RAV growth. The implied risk is that assessment of system and network needs may result in a higher level of investment than necessary to deliver capacity for connections and system resilience and reliability, driving higher costs for consumers.",4,3,12,"Head of DSO","1. Functional separation of DSO and DNO roles and accountabilities\n\n2. Clear, published methodologies and accountabilities for forecasting, planning and decision-making, in which:\n\n(a) The DSO facilitates the Load-Related Expenditure Planning (LRE) process and owns the budget for LRE expenditure.\n(b)The DNO integrates LRE needs with Asset Health and Resilience \n(c) Joint sign-off is required, subject to escalations through governance in the event of areas of misalignment in views.","Distribution Future Electricity Scenarios (DFES)\n\nDSO:DNO governance framework and supporting process documents\n",3,2,6]
[null,"R5","Planning & Network Development","Network Options Assessment","DNO-DSO","There is a potential for conflict of interest in the role of the DNO in determining system and network needs whilst also financially benefitting from RAV growth. The implied risk is that assessment of Network Options may be biased toward asset solutions, leading to higher costs for consumers and a suppression of the market for flexibility and smart solutions.",4,3,12,"Head of DSO","1. Functional separation of DSO and DNO roles and accountabilities\n\n2. DSO holds the budget for and sanctions all load related expenditure.\n\n3. The DSO oversees optioneering subject to the published Distribution Network Options Assessment (DNOA) process, in which:\n\n(a) The DSO sources options (asset from the DNO and flex from the market)\n(b) The DSO performs evaluation of options via the industry standard Common Evaluation Methodology (CEM) and publishes CEM outputs","CEM Tool assessment publication\n\nAnnual Distribution Network Options Assessment (DNOA) publication\n\nPublished planning outputs (NDP, LTDS, Week 24 notifications)\n\nDSO:DNO governance framework and supporting process documents",3,2,6]
[null,"R6","Planning & Network Development","Not offering flexible connections","DNO-DSO-Connecting customers","There is a risk that the DNO may favour traditional connections solutions over flexible connection options - e.g. due to simplicity, cultural inertia, or bias toward asset solutions - leading to connection delays and higher costs to connecting customers and consumers",3,4,12,"Head of DSO","1. Functional separation of DSO and DNO roles and accountabilities\n\n2. Clear process and policy that DNO connections function must explore flexible connections options within offers, and other access products\n\n3. Monthly governance meeting between DSO and DNO connections for the DSO to assure the appropriate consideration of flexible options, and to bring supportive challenge to ensure the overall connections portfolio is best leveraging synergies and flexible options in delivering the required system capacity","DSO:DNO governance framework and supporting process documents\n\nDSO:DNO Decision Group action log (internal)",3,2,6]
[null,"R7","Market Development","Anticipatory flexibility spend to \"prime the market\"","DNO-DSO","There is a potential conflict of interest in the DSO role in deciding volumes of flexibility services to procure. Over-procurement would be required (anticipatory flexibility spend) to drive market participation and to develop a liquid supply of flexibility in readiness for more locational and short term future use cases - e.g. accelerating individual connection applications or supporting planned and unplanned outages - but the DNO is incentivised under Totex in ED2 to procure flexibility only when and where it drives value as an alternative to short-term reinforcement needs. This may incentivise under-procurement and stifle the market for flexibility.\n",3,3,9,"Head of DSO","1. Long-term DSO benefits forecasting to reveal the future value of near-term anticipatory flexibility spend to \"prime the market\"\n\n2. Flexibility strategy internally agreed and shared with stakeholders to pursue strategy of engagement and procurement to drive market participation ahead of need (subject to clear criteria)","Annual Distribution Network Options Assessment (DNOA) publication\n\nFlexibility strategy\n\nDistribution Flexibility Services Procurement Statement",3,1,3]
[null,"R8","Market Development","Development of flexibility and access products","DSO-Market facilitator","There is a risk of conflicts of interest between the DSO and the Market Facilitator should the latter seek to drive standardisation of products for national aims in a way that does not cater for local regional factors.",2,3,6,"Head of DSO","1. Proactive engagement with the market facilitator and via ENA working groups to represent SP ENW views on market development","Flexibility strategy",1,2,2]
[null,"R9","Market Development","Standardisation vs. market participation","DSO-FSP","There is a potential for conflict of interest between the DSO and FSPs if the DSO seeks to drive standardisation of products and contracts for simplicity (for the DSO and providers) but therefore fails to cater for specific unique needs thereby inhibiting market participation.",3,3,9,"Head of DSO","1. The Market Faciltitor is aligning local and national flexibility market arrangements to reduce friction and unlock the full value of flexibility. Several new baseline methodologies will go live in April 2026 with only minimal departures permitted as a licence condition.\n\n2. The DSO COmmercial Team is engaging with stakeholders to help them prepare for the new industry-wide defaults so they do not deter participation.","Flexibility strategy",3,2,6]
[null,"R10","Market Development","Equitability of market access","DSO-FSPs","There is a risk that the DSO flexibility product offering unfairly advantages some FSPs over others - e.g. through technical barriers to entry or contracting/baselining practices creating barriers.",3,3,9,"Head of DSO","1. Pursuing a strategy of maximum technical market enablement through a third party market platform partner and standard APIs for market interaction and dispatch\n\n2. Ongoing programme of targeted FSP engagement via DSO Commercial team to identify and address commercial barriers to participation","Flexibility strategy",3,1,3]
[null,"R11","Network Operation","Use of flexibility in operational planning","DNO-FSPs","There is a risk that the DNO may favour traditional asset solutions or options such as CLASS over flexible options in operational planning and planned outages, thus supressing the market for flexibility services and increasing costs.",3,2,6,"Head of DSO","1. Functional separation of DSO and DNO roles and accountabilities. To ensure transparency and maintain SP Electricity North West’ role as a neutral market facilitator within its evolving roles as a DSO, the commercial operation of CLASS has been structurally separated from other business functions. This separation mitigates any actual or perceived conflicts of interest with the flexibility services market.\n\n2. Transparent Operational Decision Making Framework (ODMF) document published with clear dispatch principles which are encoded in systems to present options to control engineers in accordance with principles","Operational Decision Making Framework (ODMF) document\n\nDSO:DNO governance framework and supporting process documents",3,1,3]
[null,"R12","Network Operation","Use of flexibility in real-time operations","DNO-FSPs","There is a risk that the DNO network operations teams may favour traditional asset solutions over flexible options in managing real-time operations, thus supressing the market for flexibility services and increasing costs.",3,2,6,"Head of DSO","1. Functional separation of DSO and DNO roles and accountabilities\n\n2. Network control systems provide automated real‑time optimisation of curtailment and flexibility service options. These optimised options are presented directly to control engineers for review and approval, supporting efficient and consistent operational decision‑making.\n\n3. Transparent Operational Decision Making Framework (ODMF) document published with clear dispatch principles which are encoded in systems","Operational Decision Making Framework (ODMF) document\n\nDSO:DNO governance framework and supporting process documents",3,1,3]
[null,"R13","Network Operation","NESO conflicts of service","DSO-NESO","There is a risk of conflicts in DER service dispatch between DSO and NESO needs, in which the NESO may instruct a service which conflicts with a DSO constraint management need, or the DSO may instruct a service which conflicts with a NESO balancing need. Such conflicts can lead to adverse system and DER provider outcomes, and reduced whole system efficiency of dispatch.",3,5,{"$f":"G15*H15","v":15},"Head of DSO","1. We are pursuing activation of an ICCP link to the NESO control room for efficient data exchange on service conflicts - target date for testing March 2026. All configurations on our side are complete and we continue to chase NESO for the required actions to progress.\n\n2. Publication of Risk of Conflicts report between the DNO and the NESO via our Open Data Portal updated on a weekly basis.\n\n3. Transparent Operational Decision Making Framework (ODMF) document published with clear dispatch principles respecting Primacy rules.","Risk of Conflict Reports in .csv file format bublished weekly on our Open Data Portal\n\nOperational Decision Making Framework (ODMF) document",3,3,{"$f":"M15*N15","v":9}]

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[]
[null,"ID","Topic","Entities","Raised by","Description of risk and/or conflict of interest","Impact","Likelihood","Risk rating","Mitigation strategy","Impact","Likelihood","Controlled risk rating","Next steps"]
[null,"C1","Iberdrola acquisition","DSO-Wider ScottishPower Group","Stakeholder","DSO stakeholder panel requested consideration of potential conflict of interests resulting from Iberdrola’s acquisition of ENWL to form SP ENW, and the interactions between the SP ENW DSO and a vertically integrated organisation that undertakes generation and retail activities as well as network ownership and operation",4,2,{"$f":"G3*H3","v":8},"1. Each ScottishPower Group company—including SP ENW—has its own decentralised executive management and governing bodies, reducing the risk of undue influence\n2. CMA approved the acquisition, indicating no competition or conflict issues that could not be managed\n3. SP ENW Licence Condition 42 requires it to operate separately of other group companies, maintaining strict managerial and operational separation. Failure would expose SP ENW to Ofgem penalties and reputational damage\n4. SP ENW has published a formal Business Separation Policy applying to all staff ",4,1,{"$f":"K3*L3","v":4}]
[null,"C2","Network monitoring","DSO-DNO","DSO team","DSO team highlighted potential conflict with DNO progress concerning the roll-out of PreSense and the associated network monitoring benefits. The DSO highlighted the benefits to customers as a consequence of network monitoring and pressed the DNO to identify alternative solutions.",3,3,9,"1. Alternative physical monitoring solutions being utilised through the use of Smart Street Rural and Perch. Virtual monitoring solutions being developed through the use of smart meter data and DSO Foresight project",3,2,6]
[null,"C3","CLASS vs ANM","DSO-DNO","DSO team","A potential conflict of interest has been identified between CLASS (DNO NESO service providing voltage reduction for demand response) and ANM (Active Network Management, DSO). \nThe issue arises when both services operate simultaneously on the same part of the network. CLASS activation reduces demand, which ANM may then interpret as reduced network loading, resulting in reduced curtailment or flexible services dispatch. \nThis could lower CLASS revenues and potentially reduce service provision to the NESO.",3,2,6,"1. CLASS and ANM teams are functionally separate to ensure neutrality  \n2. CLASS team is aware of the risk and monitoring potential impacts. \n3. Current risk is minimal due to low numbers but will be reviewed on a 6-monthly basis",3,1,3]
[null,"C4","CLASS vs Primacy","DSO-DNO","DSO team","A potential and perceived conflict of interest has been identified between CLASS (DNO NESO service) and the emerging Primacy process in which DSO teams will signal where NESO services may conflict with DSO network needs. \nThis signalling could indirectly restrict CLASS operations in certain areas or conversely create perceptions that CLASS might unfairly benefit if competitors are flagged as conflicting.",3,2,6,"1. All DSO conflict-risk reports will be made public\n2. DSOs only signal risk - NESO retains the final decision on which services to dispatch\n3. Current risk is minimal due to low numbers but will be reviewed on a 6-monthly basis\n",3,1,3]
[null,"C5","Flexible services vs flexible connections - operational neutrality","DSO-DNO","DSO team","As ANM and flexibility markets expand there is a risk that familiarity or perceived simplicity could bias operational decisions toward curtailment or reinforcement rather than potentially more economically efficient set-point optimisation or dispatch of flexibility services",3,2,6,"1. Operational Decision Making Framework (ODMF) published for transparency\n2. Operational DSO team delivering targeted training on set-point optimisation\n2. DSO monitoring connection offers and update of set-point-enabled schemes",3,1,3]
[null,"C6","Social DSO fund principles","DSO-Consumers","DSO team","There is an inherent tension between supporting customers at risk of being left behind in the energy transition and maintaining fairness and proportionality for all customers who fund network investment",3,3,9,"1. Transparent scoring framework for bid assessment\n2. Post-scoring portfolio fairness review carried out after each funding round assessing geographic spread, beneficiary diversity and balance between short- and long-term impact of awards\n3. Assessment panel includes internal and external representation and decisions are shared with the DSO Stakeholder Panel for transparency and challenge",3,2,6]
[null,"C7","Social DSO funding assessment","DSO-DSO Stakeholder Panel","DSO team/DSO Stakeholder Panel","As part of the development of the social DSO fund governance arrangements a conflict was noted between the proposed role of the DSO panel in assessing funding bids and some of the panel members who would potentially be submitting funding bids on behalf of their organisations.",2,4,8,"1. DSO Stakeholder Panel members who are involved with (or likely to be) social DSO funding applications not permitted to sit on the assessment panel\n2. Conflicts declared at the start of every DSO Stakeholder Panel meeting and recorded formally\n3. Applicants on the DSO Stakeholder Panel do not receive internal insights about scoring criteria or any other information not available to other applicants\n4. Processes and COI approach are clearly explained in public-facing documents available on the website",2,1,2]

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[]
[null,"Conflict tracking"]
[]
[null,"Reference","Risk","Date logged ","Compliance manager assessment",null,null,"DSO DNO decision group review",null,"DSO stakeholder panel review",null,"DSO strategic forum review",null,"ExCo review",null,"Date of next review"]
[null,null,null,null,"Proposed risk score (pre)","Proposed risk score (post)","Comments/action","Date","Comments/action","Date","Comments/action","Date","Comments/action","Date","Comments"]
[null,"C1","Iberdrola acquisition","2025-09-01","Impact - 4\nLikelihood - 2\nRating - 8 (Med)","Impact - 4\nLikelihood - 1\nRating - 4 (Med)","N/A","2026-02-24","Approved","2026-03-04","Approved","N/A","N/A","N/A","N/A","Sept -26"]
[null,"C2","Network monitoring","2025-11-01","Impact - 3\nLikelihood - 3\nRating - 9 (Med)","Impact - 3\nLikelihood - 2\nRating - 6 (Low)","Progress to be kept under review","2026-02-24","Approved","2026-03-04","Approved","N/A","N/A","2026-01-01","Has been discussed at ExCo","Sept -26"]
[null,"C3","CLASS vs ANM","2025-12-01","Impact - 3\nLikelihood - 1\nRating - 3 (Low)","Impact - 1\nLikelihood - 1\nRating - 3 (Low)","Ongoing monitoring of affected sites","2026-02-24","Approved","2026-03-04","Approved","N/A","N/A","N/A","N/A","Sept -26"]
[null,"C4","CLASS vs Primacy","2025-12-01","Impact - 3\nLikelihood - 3\nRating - 9 (Medium)","Impact - 2\nLikelihood - 1\nRating - 3 (Low)","Ongoing monitoring of affected sites","2026-02-24","Approved","2026-03-04","Approved","N/A","N/A","N/A","N/A","Sept -26"]
[null,"C5","Flexible services vs flexible connections - operational neutrality","2026-02-01","Impact - 3\nLikelihood - 2\nRating - 6 (Low)","Impact - 3\nLikelihood - 1\nRating - 3 (Low)","Ongoing monitoring of set-point control and flex connection offers","2026-02-24","Approved","2026-03-04","Approved","N/A","N/A","N/A","N/A","Sept -26"]
[null,"C6","Social DSO fund principles","2026-02-01","Impact - 3\nLikelihood - 3\nRating - 9 (Med)","Impact - 3\nLikelihood - 2\nRating - 6 (Low)","Portfolio fairness monitoring"]
[null,"C7","Social DSO funding assessment","2026-02-01","Impact - 2\nLikelihood - 4\nRating - 8 (Med)","Impact - 2\nLikelihood - 1\nRating - 2 (Low)","N/A"]

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[]
[null,"Risk Impact and Likelihood Descriptors - DSO"]
[null,null,null,null,"Risk = Impact x Likelihood"]
[]
[null,"IMPACT"," ",1,2,3,4,5]
[null,null,null,"Minor","Moderate ","Significant ","Serious ","Very Serious / Business Threatening "]
[null,null,"Financial ","<£100k ","£100k - £1m ","£1m - £5m ","£5m - 10m ",">£10m "]
[null,null,"(impact in a 12 month period) "]
[null,null,"Legal ","No legal impact. ","Criticism from Regulatory Bodies. ","Financial penalties imposed. ","Serious financial penalties imposed. Breach of statutory duty, competition law or corporate manslaughter legislation. ","Loss of Licence. Persistent Breach of statutory duty or risk of imprisonment of staff or directors. "]
[null,null,"Regulatory Performance ","No impact on regulatory performance. ","Request for performance improvement with no comparative shift in position. ","Request for performance improvement requiring movement in comparative position. \nSmall financial penalties imposed. ","Failure to deliver promised improvements. Financial penalties imposed. ","Significant regulatory penalties are incurred. "]
[null,null,"Safety/Health ","Near miss incident. ","First aid / medical treatment is required. ","Time losing injury/health impact results. ","A fatality/fatal occupational disease occurs. ","Multiple fatalities/fatal occupational diseases occur. "]
[null,null,"Environment ","Near miss incident. ","Small localised incident contained on site with minimal remediation resourcing required eg oil leak, diesel spillage. ","Large scale on site incident requiring moderate remediation resourcing - EA request information / Improvement Notice issued. ","Major incident leading to offsite pollution eg  contamination of water course - EA Prohibition Notice or withdrawal of consents. ","Catastrophic release causing pollution of Local \nNature Reserve (LNR)/ Site of Special Scientific Interest (SSSI)/ RAMSAR site (Int. recognised conservation area). Fundamental break-down in working relationship with EA or Local Authority regulator resulting in prosecution. "]
[null,null,"People ","Insignificant effect on staff morale and will not lead to staff absence/retention issues. ","Small impact on staff morale amongst a few individuals, with little impact in terms of staff absence/retention and business continuity. ","Decreased staff morale in a small number of teams around the business which may result in absence and productivity issues which need to be managed at line manager level. Corporate absenteeism increases by up to 1% over normal rate. Requires consultation with Union. ","Impacts a significant number of company employees and results in uncertainty and lower levels of morale across more than one business directorate with increasing staff absence (<5% above normal rates). This may result in decreased productivity for the business as a whole. Inability to recruit appropriately skilled employees. Potential for extensive consultation/grievance with Union. \nLimited industrial action. ","Decreased staff morale for a large number of staff across all business directorates. Potential for key staff leaving and increasing staff absence (>5% above normal rates) and staff turnover which will leave the business with serious risk exposure in terms of business continuity and productivity. Industrial action including strike action. "]
[null,null,"Reputation ","Insignificant. ","Local press article e.g. SP ENW action criticised from key stakeholders such as our shareholders, the Regulator, partner forums, local pressure groups, or other alleged \"expert\". ","Criticism in Industry Press or local/regional press. SP ENW proposals/outcomes receive negative reaction in the electricity forums, and/or from Regulator(s) and other key stakeholders such as our shareholders. ","Reported in national press/TV. SP ENW brand raised into prominence (eg incident, business performance,) and publicised negatively by Regulator, electricity pressure groups or other key stakeholders.  Significant effect on or prominence for owning consortia and shareholders. ","Headline in national press – TV and newspapers.  Failure to adequately address known problem or to anticipate or prepare for unpredictable occurrence.  SP ENW and owning consortia heavily criticised in media. Heavy criticism from key stakeholders such as our shareholders. "]
[null,null,"Customer Service ","Individual justifiable complaint.  \nIf security of supply issue, small number of customers affected. Concluded within 18 hours. ","Individual complaint of serious nature. Likely to be taken up by local consumer advocate or champion. Reported in local press.  If security of supply issue, small numbers of customers affected after 18 hrs. ","Failure to satisfy: \n>1,000 customers during a single incident; or >200 customers over a period of three months for a common cause; or \nLikely to generate >100 specific complaints. \nHeadline in local or regional press. \n","Failure to satisfy: \n>10,000 customers during a single incident; or >2,000 customers over a period of three months for a common cause; or \nLikely to generate >1,000 specific complaints Likely to be visible and commented on by key stakeholders. \nReported in national press. ","Failure to satisfy: \n>50,000 customers during a single incident; or >10,000 customers over a period of three months for a common cause; or \nLikely to generate >5,000 specific complaints Likely to be visible and commented on by key stakeholders.  \nHeadline in national press. "]
[]
[]
[null,"LIKELIHOOD"," ",1,2,3,4,5]
[null,null,null,"Very Low "," Low ","Medium ","Fairly likely ","More Than Likely "]
[null,null," ","<5% chance of happening or frequency of risk is once in more than ten years. ","<25% chance of happening or  frequency of risk is once in ten years. ","<50% chance of happening or frequency of risk is once in five years. ","<75% chance of happening or frequency of risk is once in one year. ",">75% chance of happening or frequency of risk is once in three months. "]

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[null,"Impact-Likelihood Risk Matrix"]
[null,null,null,1,2,3,4]
[null,null,5,"L","M","H","H","H"]
[null,"Impact Metric Score",4,"L","M","M","H","H"]
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[null,null,null,"Likelihood Metric Score"]
[]
[null,null,null,"Total risk ratings:","Low Risk"]
[null,null,null,null,"Medium Risk"]
[null,null,null,null,"High Risk"]

{"sheet":"Full Risk Framework (SP ENW)","index":8,"n_rows":20,"n_cols":8,"rows_kept":20,"cut":false,"hidden":true,"merged":[[6,6,7,6],[6,7,7,7],[17,1,19,1],[17,2,18,2],[2,4,2,5],[4,1,14,1],[4,2,5,2],[6,3,7,3],[6,4,7,4],[6,5,7,5]]}
[]
[null,"Risk Impact and Likelihood Descriptors "]
[null,null,null,null,"Risk = Impact x Likelihood"]
[]
[null,"IMPACT"," ",1,2,3,4,5]
[null,null,null,"Minor","Moderate ","Significant ","Serious ","Very Serious / Business Threatening "]
[null,null,"Financial ","<£100k ","£100k - £1m ","£1m - £5m ","£5m - 10m ",">£10m "]
[null,null,"(impact in a 12 month period) "]
[null,null,"Legal ","No legal impact. ","Criticism from Regulatory Bodies. ","Financial penalties imposed. ","Serious financial penalties imposed. Breach of statutory duty, competition law or corporate manslaughter legislation. ","Loss of Licence. Persistent Breach of statutory duty or risk of imprisonment of staff or directors. "]
[null,null,"Regulatory Performance ","No impact on regulatory performance. ","Request for performance improvement with no comparative shift in position. ","Request for performance improvement requiring movement in comparative position. \nSmall financial penalties imposed. ","Failure to deliver promised improvements. Financial penalties imposed. ","Significant regulatory penalties are incurred. "]
[null,null,"Safety/Health ","Near miss incident. ","First aid / medical treatment is required. ","Time losing injury/health impact results. ","A fatality/fatal occupational disease occurs. ","Multiple fatalities/fatal occupational diseases occur. "]
[null,null,"Environment ","Near miss incident. ","Small localised incident contained on site with minimal remediation resourcing required eg oil leak, diesel spillage. ","Large scale on site incident requiring moderate remediation resourcing - EA request information / Improvement Notice issued. ","Major incident leading to offsite pollution eg  contamination of water course - EA Prohibition Notice or withdrawal of consents. ","Catastrophic release causing pollution of Local \nNature Reserve (LNR)/ Site of Special Scientific Interest (SSSI)/ RAMSAR site (Int. recognised conservation area). Fundamental break-down in working relationship with EA or Local Authority regulator resulting in prosecution. "]
[null,null,"People ","Insignificant effect on staff morale and will not lead to staff absence/retention issues. ","Small impact on staff morale amongst a few individuals, with little impact in terms of staff absence/retention and business continuity. ","Decreased staff morale in a small number of teams around the business which may result in absence and productivity issues which need to be managed at line manager level. Corporate absenteeism increases by up to 1% over normal rate. Requires consultation with Union. ","Impacts a significant number of company employees and results in uncertainty and lower levels of morale across more than one business directorate with increasing staff absence (<5% above normal rates). This may result in decreased productivity for the business as a whole. Inability to recruit appropriately skilled employees. Potential for extensive consultation/grievance with Union. \nLimited industrial action. ","Decreased staff morale for a large number of staff across all business directorates. Potential for key staff leaving and increasing staff absence (>5% above normal rates) and staff turnover which will leave the business with serious risk exposure in terms of business continuity and productivity. Industrial action including strike action. "]
[null,null,"Reputation ","Insignificant. ","Local press article e.g. ENWL action criticised from key stakeholders such as our shareholders, the Regulator, partner forums, local pressure groups, or other alleged \"expert\". ","Criticism in Industry Press or local/regional press. ENWL proposals/outcomes receive negative reaction in the electricity forums, and/or from Regulator(s) and other key stakeholders such as our shareholders. ","Reported in national press/TV. ENWL brand raised into prominence (eg incident, business performance,) and publicised negatively by Regulator, electricity pressure groups or other key stakeholders.  Significant effect on or prominence for owning consortia and shareholders. ","Headline in national press – TV and newspapers.  Failure to adequately address known problem or to anticipate or prepare for unpredictable occurrence.  ENWL and owning consortia heavily criticised in media. Heavy criticism from key stakeholders such as our shareholders. "]
[null,null,"Customer Service ","Individual justifiable complaint.  \nIf security of supply issue, small number of customers affected. Concluded within 18 hours. ","Individual complaint of serious nature. Likely to be taken up by local consumer advocate or champion. Reported in local press.  If security of supply issue, small numbers of customers affected after 18 hrs. ","Failure to satisfy: \n>1,000 customers during a single incident; or >200 customers over a period of three months for a common cause; or \nLikely to generate >100 specific complaints. \nHeadline in local or regional press. \n","Failure to satisfy: \n>10,000 customers during a single incident; or >2,000 customers over a period of three months for a common cause; or \nLikely to generate >1,000 specific complaints Likely to be visible and commented on by key stakeholders. \nReported in national press. ","Failure to satisfy: \n>50,000 customers during a single incident; or >10,000 customers over a period of three months for a common cause; or \nLikely to generate >5,000 specific complaints Likely to be visible and commented on by key stakeholders.  \nHeadline in national press. "]
[]
[]
[null,"LIKELIHOOD"," ",1,2,3,4,5]
[null,null,null,"Very Low "," Low ","Medium ","Fairly likely ","More Than Likely "]
[null,null," ","<5% chance of happening or frequency of risk is once in more than ten years. ","<25% chance of happening or  frequency of risk is once in ten years. ","<50% chance of happening or frequency of risk is once in five years. ","<75% chance of happening or frequency of risk is once in one year. ",">75% chance of happening or frequency of risk is once in three months. "]

{"sheet":"Drop Downs","index":9,"n_rows":34,"n_cols":4,"rows_kept":34,"cut":false,"hidden":true,"merged":[]}
["Type","Impact category ","Impact category ","Likelihood"]
["Risk ","Safety ","1 - minor","1 - very low"]
["Issue","Customer","2 - moderate","2 - low"]
["Conflict of Interest","Affordability","3 - significant","3 - medium"]
[null,"Sustainability","4 - serious","4 - fairly likely"]
[null,"People","5 - business threatening","5 - more than likely"]
[]
[]
[null,"Risk rating"]
[null,"1 - Low"]
[null,"2 - Low"]
[null,"3 - Low"]
[null,"4 - Low"]
[null,"5 - Low"]
[null,"6 - Low"]
[null,"7 - medium"]
[null,"8 - medium"]
[null,"9 - medium"]
[null,"10 - medium"]
[null,"11 - medium"]
[null,"12 - medium"]
[null,13]
[null,14]
[null,"15 - high"]
[null,"16 - high"]
[null,"17 - high"]
[null,"18 - high"]
[null,"19 - high"]
[null,"20 - high"]
[null,"21 - high"]
[null,"22 - high"]
[null,"23 - high"]
[null,"24 - high"]
[null,"25 - high"]