INDEPENDENT ASSURANCE STATEMENT Scope and objectives URENCO commissioned DNV GL Business Assurance Services UK Limited (“DNV GL”) to undertake independent assurance of its Sustainability Report 2014 (the “Report”). Our assurance engagement was planned and carried out in accordance with the DNV GL Protocol for Verification of Sustainability Reporting, VeriSustainTM1. We evaluated the report for adherence to the VeriSustainTM Principles (the “Principles”) of stakeholder inclusiveness, materiality, responsiveness, completeness, neutrality and reliability. We evaluated the performance data using the reliability principle together with URENCO’s data protocols for how the data are measured, recorded and reported. It was agreed with URENCO that the performance data in scope were: Number of lost time incidents Waste (hazardous and non-hazardous) Water (usage and discharges) Air emissions Direct energy usage Indirect energy usage CO2 emissions from direct and indirect energy consumption The basis for agreeing the performance data in scope was to cover the most material indicators in the performance summary table. We understand that the reported economic data and information are based on data from the Annual Report and Accounts for 2014, which are subject to a separate audit process by Deloitte LLP. The review of financial data taken from the Annual Report and Accounts is not within the scope of our work. We planned and performed our work to obtain the evidence we considered necessary to provide a basis for our assurance opinion. We are providing a ‘moderate level’ of assurance. A ‘high level’ of assurance would have required additional work at Group and site level to gain further evidence to support the basis of our assurance opinion. Responsibilities of the Directors of URENCO and of the assurance providers The Directors of URENCO have sole responsibility for the preparation of the Report. In performing our assurance work, our responsibility is to the management of URENCO; however our statement represents our independent opinion and is intended to inform all of URENCO’s stakeholders including management. DNV GL was not involved in the preparation of any statements or data included in the Report except for this Assurance Statement. We have no other contract with URENCO and this is the 3rd year that we have provided assurance. DNV GL’s assurance engagements are based on the assumption that the data and information provided by the client to us as part of our review have been provided in good faith. DNV GL expressly disclaims any liability or co-responsibility for any decision a person or an entity may make based on this Assurance Statement. 1 The VeriSustain protocol is available on dnvgl.com Urenco - Assurance Statement.docx Basis of our opinion A multi-disciplinary team of sustainability and assurance specialists performed work at group level. We did not conduct audit activities at site level, although we undertook some remote checks detailed below. We undertook the following activities: Review of the current sustainability issues that could affect URENCO and are of interest to stakeholders; Review of URENCO’s approach to stakeholder engagement and recent outputs from stakeholder engagement activities at enrichment sites and at Group level; Review of information provided to us by URENCO on its reporting and management processes relating to the Principles; Interviews with selected personnel responsible for management of sustainability issues and review of selected evidence to support issues discussed; Review of supporting evidence for key claims and data in the report. Our checking processes were prioritised according to materiality and we based our prioritisation on the materiality of issues at a consolidated group level; Telephone interviews with site data owners to review the process and systems at site level for preparing sustainability data; Review of the processes for gathering and consolidating the specified performance data and, for a sample, checking the data consolidation from site to group level; and An independent assessment of URENCO’s reporting in accordance with the ‘core’ option of the Global Reporting Initiative (GRI) G4 Guidelines. Opinion On the basis of the work undertaken, nothing came to our attention to suggest that the Report does not properly describe URENCO’s adherence to the Principles. In terms of reliability of the performance data, nothing came to our attention to suggest that these data have not been properly collated from information reported at operational level, nor that the assumptions used were inappropriate. We believe that the report is in line with the ‘Core’ elements of the GRI G4 Guidelines. Observations Without affecting our assurance opinion we also provide the following observations. Stakeholder Inclusiveness The participation of stakeholders in developing and achieving an accountable and strategic response to sustainability. This year URENCO has used existing stakeholder engagement processes at enrichment facilities and Group level to inform and validate the development of its sustainability strategy. For the first time the results of this stakeholder mapping exercise have also been used to determine the content of the sustainability report. We understand that URENCO is planning to undertake more extensive stakeholder engagement in the future. We recommend a specific focus on engagement with more critical stakeholder voices and reporting on the outcome of this engagement in future sustainability reports. Urenco - Assurance Statement.docx Materiality The process for determining the issues that are most relevant to an organisation and its stakeholders. We noted URENCO’s endeavours for clearer and focused reporting, including its transition to the G4 guidelines. The materiality exercise has helped prioritise the sustainability programme and report and we look forward to seeing how this is refined next year. We noted that information on nuclear waste and radiation have been referenced as areas of interest by some stakeholders in relation to the industry as a whole. We recommend their inclusion in future reporting. We have observed that URENCO’s internal sustainability programme includes additional topics that are being managed and for which data are collected across the business. Even though some of these data are considered material by the business currently only limited performance information is reported externally in some of the six focus areas of the sustainability agenda. We recommend using the updates to stakeholder engagement and materiality processes to consider reviewing the data and information URENCO discloses in its sustainability report. Responsiveness The extent to which an organisation responds to stakeholder issues. The establishment of the Sustainability Committee in 2014 has increased the ability for stakeholder issues to be given appropriate attention by Group management. In line with the advancement in URENCO’s data collection procedures and controls, we recommend that URENCO should continue to develop measurable, quantitative sustainability targets for both the medium and long term. In particular, we suggest introducing quantifiable targets for emissions and energy use in order to encourage continuous improvement in this area. Completeness How much of all the information that has been identified as material to the organisation and its stakeholders is reported. URENCO’s reporting of performance including the disclosure of data is comprehensive. As management processes for Health and Safety are strengthened across the business we recommend that URENCO considers disclosing more information and KPIs in this area. Neutrality The extent to which a report provides a balanced account of an organisation’s performance, delivered in a neutral tone. The report outlines a number of challenges URENCO currently faces, including increased safety incidents, and discloses performance indicators in an unbiased manner. In addition to reporting on the challenges that URENCO currently faces, we recommend that URENCO also reports on those it has faced during the year which have been successfully addressed. This provides stakeholders increased confidence that URENCO is responsive to the challenges it faces. Reliability The accuracy and comparability of information presented in the report, as well as the quality of underlying data management systems. URENCO has developed a number of documents and guidelines for sustainability reporting across the Group. Improvements in the process for submission and approval of data from sites to the Group have Urenco - Assurance Statement.docx also been implemented. This includes the establishment of the sustainability data working group, which has strengthened roles and responsibilities for data collection and submission. We also observed improved organisation of data and source evidence on the central systems. This has strengthened the availability and auditability of information to the Group. Acknowledging that data collection arrangements have improved, the amount of manual transfer and calculation of data remains high. There also remains a high dependency on appropriate and sufficient controls from Group to ensure data quality. We observed a number of differences in the manner in which data for indicators are collected, measured and calculated across sites. We recommend strengthening site-specific guidance that explains the local calculation methods, specifies the types of supporting evidence, and prescribes the organisation thereof. The site-specific guidance will provide greater clarity to the group on how information is collated at a site level and will enable the establishment of a more effective audit trail. We also recommend that URENCO should aim to increase automation of data collection. In this context, we furthermore recommend that URENCO should increase the accountability for data quality and auditability at sites. This could include continuing to increase site-specific internal controls and formalising data sign off processes at local sites. A number of sites rely on estimations for their data calculation. For several of these, URENCO is currently considering the ways in which it can more accurately record actual numbers. We recommend that sites should aim to use actual values wherever possible. If actual numbers are not available, we recommend that URENCO discloses the basis for any estimation made. For and on behalf of DNV GL Business Assurance Services UK Limited London, UK 20th March 2015 Anne Euler Principal Consultant and Lead Assuror UK Sustainability, DNV GL – Business Assurance Jon Woodhead Regional Assessment Services Manager and Reviewer UK Sustainability, DNV GL – Business Assurance ------------------------------------------------------------------------------------------------DNV GL Business Assurance Services UK limited is part of DNV GL – Business Assurance, a global provider of certification, verification, assessment and training services, helping customers to build sustainable business performance. www.dnvgl.com Urenco - Assurance Statement.docx
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