Information risks, strengths and weaknesses statement

Transcription

1 Information risks, strengths and weaknesses statement November 2018 wessexwater.co.uk

2 Who we are We provide water and sewerage services to more than 2.8 million customers in the south west of England. Our overall mission is to provide outstanding sustainable water and environmental services. Water m Safeguarding drinking water quality Protecting our water sources to safeguard water quality We maintain and operate hundreds of water sources, treatment works, service reservoirs and pumping stations We treat & supply 265 million litres of water a day 405m Providing reliable services Including completing our water supply grid so we can move water around our whole region We maintain and renew 7,400 miles of water mains 54m Reducing leakage We re investing further to cut leakage Sewerage m Minimising sewage flooding Reducing incidents of sewage flooding by improving the sewerage network and managing rainfall run-off We look after 21,800 miles of sewers 50m Reducing the carbon footprint Producing more renewable energy during waste treatment at our sewage works We take away & treat 485 million litres of sewage a day 732m Protecting rivers, lakes and estuaries Improving water quality to meet new European directives 155m Improving bathing water quality Increasing levels of treatment and waste water storage to keep beaches clean Our customers priorities are always our starting point. Customers service expectations continue to grow and the information we provide is a key part of ensuring we do the right thing for our customers and stakeholders. Where we work Our region Our catchments Stroud 8 Cotswold Wessex Water West Somerset North Somerset Weston-super-Mare Sedgemoor Bridgwater South Gloucestershire Bristol BANES Mendip Bath Chippenham Trowbridge Wiltshire Devizes Warminster 9 B r i s t o l C h a n n e l Key Taunton Taunton Water supply and sewerage services area Sewerage services only Water supply services only South Somerset Yeovil West Dorset Dorchester Weymouth and Portland North Dorset Purbeck Weymouth Poole Salisbury East Dorset New Forest Christchurch Bournemouth 3 Key 1 Bristol Avon 2 Brue 3 Parrett and Tone 10 4 Axe and North Somerset streams 5 Dorset Stour 6 Poole Harbour 7 Hampshire Avon 8 South Gloucestershire streams 9 West Somerset streams 10 Dorset coastal streams 5 6 E n g l i s h C h a n n e l

3 Contents About this document 2 Section 1 - Our assurance framework 3 Section 2 - Process for identifying risks, strengths and weaknesses 4 Section 3 - Issues we identified last year and progress we have made 7 Section 4 - New target areas to address 9 Section 5 Assurance statement 14 1

4 About this document Welcome to Wessex Water s information risks, strengths and weaknesses statement This statement is designed to help us ensure that we continue to provide transparent, easy to understand, complete and accurate information to all our customers and stakeholders. It provides a summary of the stakeholder engagement and data assurance we have carried out, our methods and processes, and sets out our progress made on improving data quality. Whilst we have a separate risk register for all the issues that might affect us as a company, providing transparent, easy to understand, complete and accurate information to all our customers and stakeholders is one of our core values and is essential to building trust and confidence in the services we provide. Equally important is that we meet our performance commitments and deliver real improvements, keeping up with customers changing needs. Company monitoring framework In 2016, Ofwat published its company monitoring framework, which assesses how well water companies achieve this aim. All companies are required to fulfil some common requirements: explicit board sign-off of assurance provided sign-off of compliance with all relevant statutory, licence and regulatory obligation, and the steps being taken to manage and/or mitigate risks transparency on audit procedures regarding data assurance summary of outcome of data assurance undertaken. Ofwat s framework places companies into three categories: self-assurance, targeted and prescribed. Our aim is to be self-assured. However, along with most other water companies, we are currently in the targeted assurance category. This means we must also: carry out an exercise with stakeholders to target issues to address produce a risks, strengths and weaknesses statement consult on our draft assurance plan to resolve the issues identified publish a final version of the assurance plan. This document provides detail on: our assurance framework process for identifying risks, strengths and weaknesses issues we identified last year and progress we have made our strengths, risks and weaknesses our assurance statement. Tell us what you think Your feedback is important to us so please do let us know your thoughts. You can us at assurance@wessexwater.co.uk 2

5 Section 1 Our assurance framework We have a structured approach to assessing and managing business risk governed by a business risk assurance map. Our business risk assurance map can be viewed on our website, here. We maintain a Regulatory Assurance Manual (RAM) that helps ensure we provide the appropriate level of assurance to all the information we provide. The manual provides a quality assured system for the compilation of information or data based on the principles of ISO9001. It sets out data flows, the process for internal certification of data, a framework for assessing the level of assurance required and training requirements. Our RAM is published on our website, here. The responsibilities detailed in the RAM include both assurance and information provider roles. The assurance roles include the Wessex Water Services Limited (WWSL) Board, the WWSL Audit and Risk Committee, external technical and financial auditors and our internal audit team. The information provider roles are internal reviewers; owners; compilers; and originators. Each of these roles has responsibilities for certain elements of our data and information provision according to the framework assessment. Our overall approach to ensuring data is fit for purpose can be summarised as follows. Board governance Board ownership is key to providing a strong assurance process. The board owns and assures all regulatory submissions, supported by the Audit and Risk Committee and our senior management team. Independent audit Our technical auditors independently check and assure all our regulatory submissions. Our financial auditors perform a separate and well-established audit of the financial and regulatory accounts. We also gain additional specialist advice where needed. Responsibilities Senior management teams monitor performance and risk and report to the board. All elements of regulatory submissions have clear ownership with a senior manager who is responsible for ensuring the submission is completed to an appropriately high standard. Individuals compiling data are responsible for their calculations and processes. The completion of detailed method statements and process diagrams for all repeatable work ensures submissions are easily auditable and that the ability to complete a single area does not all rest on a single individual. Regulatory submissions have allocated data providers, compilers, checkers and owners. All these individuals sign statements with each submission outlining their obligations and stating data and calculations have been completed to the best of their ability. 3

6 Section 2 Process for identifying risks, strengths and weaknesses Risk management is fully embedded in our business. Each year, we carry out an internal risk review to identify risks to the reliability and accuracy of the data we provide to customers and other stakeholders. We use the findings of the review, coupled with direct and indirect engagement with our customers and other stakeholders and direct feedback from our independent auditors, to identify areas where we can improve. Further detail is given below. Internal risk review We maintain an information risk register to monitor the risks associated with the provision of reliable and accurate information to our customers and other stakeholders. This covers the information and data we provide in seven areas, as identified in our Regulatory Assurance Manual. These are: direct to customers regulatory reporting financial reporting annual performance report market operator (MOSL) retailers other stakeholder information. Each year, we consider if any new risks should be included, if any are no longer relevant and whether the impact or likelihood have changed. We assess likelihood using the definitions shown below. Description Likelihood Very high 5 It is almost certain that the event will occur if the situation continues as it is >90% High 4 It is very likely that the event will occur if the situation continues as it is 60 90% Medium 3 It is foreseeable that circumstances may exist which result in the event occurring 40 60% Low 2 It is unlikely that circumstances will combine to result in the event occurring 10 40% Very low 1 It is most unlikely that the event will occur / it would require exceptional conditions < 10% 4

7 We assess impact in relation to the following categories: 1 Financial, investor and commercial 2 Customer/service 3 Environmental/sustainability 4 Public health, safety and security 5 Legal and regulatory We combine the impact and likelihood scores to give an overall risk score. The pre-mitigation position takes account of existing controls and we categorise the overall risk as low, medium or high using the following definitions. Risk rating Risk score Low Between 1 and 8 Medium Between 9 and 14 High Greater than or equal to 15 We target areas where the overall risk is assessed as medium or high. We identify actions to mitigate the likelihood or impact. We record any mitigating actions on an action log with an assigned owner and target completion date. Independent external assurance Our technical auditors provided external technical assurance on the following submissions in the reporting period: Annual Performance Report bioresources RCV water resources RCV PR14 reconciliation our September PR19 submission, including: allocation of costs between price controls direct procurement for customers PR19 performance commitments (PCs) and outcome delivery incentives (ODIs). 5

8 Our financial auditors reviewed relevant tables from our PR19 Business Plan, our statutory accounts and the accounts published as part of the Annual Performance Report. In addition, a range of other third parties provided assurance across all areas of our PR19 Business Plan. Figure 1 below illustrates the range of organisations involved in each of the main sections of our plan. Figure 1 PR19 Business Plan Assurance Map Engagement with customers and stakeholders Our customer engagement exercise takes a variety of forms. From taking feedback on calls, conducting surveys, live chat via our website, Have your say panels and the Wessex Water Partnership, we are actively listening to what our customers have to say about our performance. In addition to engaging the Wessex Water Partnership on the process for fulfilling our obligations under the company monitoring framework, we provide copies of our Information risks, strengths and weaknesses statement and our draft and final assurance plan. We also hold a separate meeting on progress with delivery of our performance commitments. We also invite customers to respond to our consultations and have their say on both this document and our assurance plan to ensure their views are being considered. We have engaged with the following regulators, industry bodies and stakeholders, both directly and indirectly throughout the year: Consumer Council for Water (CCWater) Drinking Water Inspectorate (DWI) Environment Agency (EA) market operator (MOSL) and retailers Ofwat developers Wessex Water Partnership (our independent customer challenge group). 6

9 Section 3 Issues we identified last year and progress we have made Our 2018 assurance plan identified eight target areas to improve the information we provide to customers and other stakeholders. We identified actions associated with each target area, incorporating the six actions from 2017 highlighted as ongoing. The target areas were: 1 Responding to customer needs 2 Website improvements 3 Asset data quality 4 Improving how we serve customers in vulnerable circumstances 5 Price review: submission 6 Price review: allocating our capital value 7 Regulatory accounting 8 Reporting process documentation The target areas and actions were to address risks/weaknesses associated with customer feedback; ensuring compliance; new processes or data requirements; and/or consistency and quality of data. We have completed all the actions identified. Further detail is given below. Action Risk/weakness addressed Progress Responding to customer needs Review the design of billing information and incorporate graphics into customer bills Further improve the design of billing information to help customers reduce their water use Customer feedback Customer feedback Complete. New bills being used. Complete. New bills being used. Implement our Save Water Save Money initiative, better informing customers how to save water Enhanced Homecheck service, improving the information we provide when visiting customers Website improvements Customer feedback Customer feedback Complete. Information included in billing packs and online. Complete. All teams fully trained, and information being shared with customers. Improve how we design access to information Customer feedback Improvements include the 'our performance' and business plan microsites on our website Asset data quality Work with market participants and neighbouring companies to improve market data and ensure that it is high quality Ensuring compliance Bioresources data published; asset data quality reviewed; water resources and bioresources RCV updated here 7

10 Action Risk/weakness addressed Progress Improving how we serve customers in vulnerable circumstances Full review of the Priority Services Register, sharing findings and investigating collaboration with neighbouring companies and other industries Building an in-house mapping system to gain a comprehensive view of vulnerability in our region, drawing on many sources of data enabling, complex analysis and data visualisation New processes or data requirements New processes or data requirements Complete. Plan in place to have a National Data Share agreement with the energy sector for customers on our Priority Services Register by 2020 Complete. We have developed an in-house mapping tool Price review: submission Ensure we complete the price review applying the most stringent assurance processes, giving Ofwat, customers and other stakeholders confidence that the data on which we base our calculations is fit for purpose. To include all submissions and pre-submissions as set out in the previous table. New processes or data requirements Complete. Our business plan included an assurance map showing those involved in the assurance process Price review: allocating our capital value Engage with Ofwat to ensure we understand their requirements when proposing new asset values for water resources New processes or data requirements Complete. Data published as part of our PR19 Business Plan submission Regulatory accounting Develop proposals for the assessment of transfers between our sewage and bioresources activities Reporting process documentation Keep our regulatory assurance manual up to date and published Continue to improve method statements, checking and sign-off Completing further assurance of source data Data consistency New processes or data requirements Consistency and quality of data Consistency and quality of data Consistency and quality of data Complete. Audited by technical auditors Complete for To be reviewed in March 2019 Complete for Ongoing improvements planned Internal audit of Developer Services data carried out In the following section we describe the outcome of our review to identify the current areas to target. 8

11 Section 4 New target areas to address Summary Our internal assessment continues to show that the risk of us providing inaccurate information remains low We have completed the actions identified in previous years including publishing performance information on a new microsite on our website We continue to improve how we design access to information for customers and other stakeholders We have received positive feedback from our main regulators and industry bodies throughout the year Our technical auditors highlighted that they found no significant issues with our reported performance in the 2018 Annual Performance Report We received a low number of queries from Ofwat on our Annual Performance Report and PR19 Business Plan Key areas for us to target for improvements are our method statements, our Annual Performance Report and reporting of a small number of our performance commitments In detail Internal risk review Our information risk register identifies 71 different types of information provided to customers and other stakeholders, including our 32 performance commitments. The number of risks in each category, both before any new actions to address the weaknesses identified and following the impact of any mitigating actions, is shown below. Figure 2 Risk assessment summary pre-mitigation Figure 3 Risk assessment summary post-mitigation High 3 Medium 4 Medium 7 Low 61 Low 67 We identify target areas as those where the overall risk before mitigation is assessed as high or medium, a total of 10 areas. The mitigations proposed reduce the number of items categorised as high risk to zero and the number of items categorised as medium risk from 7 to 4. 9

12 Independent external assurance Following the external technical assurance of the 2018 Annual Performance Report, our external technical assurers highlighted that they had found no significant issues with our reported performance. They recommended that we continued to focus on: Method statements: continue to develop method statements, especially to detail reporting calculations, improve repeatability, and to improve version control. Leakage, shadow reporting: implement the remaining technical actions to finalise the measure. Supply interruptions, shadow reporting: keep full records of the decisions made for each event. We also recommend strengthening the checking process applied to the data, from collection through to reporting. In their Assurance Report for the PR19 business plan, the auditors also recommended that method statements were updated, prioritised based on the frequency of reporting, the regulatory risk, and the complexity of reporting. In their audit report relating to the financial statements for , our financial auditors highlighted that the statements: gave a true and fair view of the company s affairs as at 31 March 2018 and of its profit for the year then ended; and had been properly prepared in accordance with International Financial Reporting Standards (IFRSs) as adopted by the European Union. Engagement with customers and stakeholders Wessex Water Partnership (WWP): Our customer scrutiny group, the Wessex Water Partnership was established in January 2016 with an independent chair and diverse membership representing various customer and stakeholder groups. One of its key roles is to review and challenge Wessex Water s Business Plan, specifically that it has been developed using sound customer engagement and that it reflects customers needs and priorities, and their willingness to pay for them. Some specific comments in the WWP report on our PR19 Business Plan include: Engagement has been two-way and transparent and there has been good use of innovative customer research techniques, mainly associated with digital media, web-based tools involving gaming and virtual reality and the engagement of future customers including the use of a Young People s Panel. Participants were provided with accurate and sufficient information on the company s current performance relative to its peers. As a result of its work, the Partnership considers overall that the company s Business Plan is grounded in good customer engagement. There is strong evidence that customers have been involved in the shaping of the company s strategic objectives. The company has developed a good understanding of its customers priorities, needs and valuations. Its Business Plan includes service outcomes that customers have said they value and prioritise and at a price they find affordable. It also includes a commitment to meet all its statutory and regulatory obligations. Consumer Council for Water (CCWater): CCWater has confirmed they remain very satisfied with our engagement with them and have no concerns with the quality and timeliness of information we have provided during the year. One area they did note that they would have appreciated advanced notice was a consultation on our developers charging arrangements. Whilst this was published on our website, we have committed to ensure that they receive a specific notifying them of such a change in the future. CCWater recently published their year-end report on complaints and enquiries. This confirmed that we have, again, the lowest number of complaints and enquiries of any water and sewerage company in the country. 10

13 Drinking Water Inspectorate (DWI): We have maintained a positive relationship with the Drinking Water Inspectorate over the past year. We provide monthly as well as annual data submissions and continue to work with them to ensure the information that we submit is in line with regulatory requirements. We have regularly met with our liaison inspector where discussions included progress with our programme of legal instrument notices, reservoir audit outcomes and our plans for drinking water quality in PR19. We proactively engaged with the Drinking Water Inspectorate over perceived shortcomings in our compliance sample scheduling. We accepted the concerns raised and subsequently improved our scheduling to ensure the requirements of the regulations are fully met. The Inspectorate were satisfied with our approach and response. We have continued to demonstrate industry leading performance on the Compliance Risk Index (CRI) and remain in the top few companies on the new Event Risk Index (ERI) measures. Environment Agency (EA): The EA has not raised any significant issues about general data reporting and we continue to have an excellent relationship with them. We have had regular constructive dialogue with the EA on the provision of water and waste water quality data. We continue to perform very well against the EA s EPA assessment, gaining a ranking of industry leading again in Market operator (MOSL) and retailers: The success of the retail market relies in part on the quality of data, so participants can make accurate and timely decisions. Since market opening our data has consistently been among the top of the industry in transactions completed first time. MOSL s market performance operating plan sets out 'Enabling Efficient Settlement' as its highest priority outcome, with the initiation of data improvement plan activity a core element of the planned approach. MOSL had no concerns about our response to requests for information. We continue to manage minor data corrections through BAU processes and proactively working with retailers to ensure our data is accurate and fit for purpose. Ofwat: In their assessment of Wessex Water under the 2017 company monitoring framework, Ofwat highlighted that our assurance plan set out the context and the results of our information, risks, strengths and weaknesses, that there was good evidence of engagement with stakeholders and that the plan was self-standing and an accessible overview. Ofwat also highlighted that the targeted areas identified were quite wide and actions at a high level and that it would be helpful to have more detail around the assurance activities planned. There has been a detailed query process after submission of both the 2018 Annual Performance Report (APR) and our PR19 Business Plan. We are pleased to have received a very small number of queries, which helps to give us confidence that our information assurance processes are robust. Following one query from Ofwat, we are required to submit updated values for our performance commitment B6: BAP landholding assessed and managed for biodiversity. The changes are very small and do not affect the achievement of our performance commitment or our reward/penalty situation in any year. We will publish the updated numbers for the previous three years as part of our interim results in November We have also engaged our technical auditor who has confirmed that no additional external auditing is required and that our proposal for an improved internal process will ensure accurate reporting in the future. We also had confirmation from Ofwat that, in relation to our developer charges, our engagement has strongly confirmed their view that the charging arrangements are a major improvement for developers compared with previous arrangements not least in delivering predictability and transparency. They have also confirmed that they are content with our explanation of the calculation of the balance of charges, which is correct and consistent with their understanding. Developers: We have run several sessions with developers, both in relation to our new charging arrangements and to encourage dialogue about our services overall. These sessions have been very positive, and developers have consistently told us that they are satisfied with our information provision. Ofwat required all companies to consult on an amendment to charges arrangements in April based on its new legal analysis. At the same time, we also consulted on some minor changes to developers charges where we had new information to ensure that these charges best met our obligations. 11

14 Target areas We perform very well in the vast majority of areas and have a low overall risk associated with our information provision. However, we have set out below the small number of areas we plan to target and the actions we believe are necessary to address these issues. We have sought to address Ofwat s feedback as part of the 2017 company monitoring framework assessment by focusing on more specific areas and including more detail around the assurance activities planned. Where possible, we have grouped the actions into the information areas included in our Regulatory Assurance Manual. Reporting process documentation In our previous assurance plan we identified three actions in relation to the reporting process. Keep our Regulatory Assurance Manual up to date and published Continue to improve method statements, checking and sign off Completing further assurance of source data The ongoing need for focus in these areas has been highlighted both by feedback from our technical auditor and our internal review. We review our Regulatory Assurance Manual on an annual basis with the next review scheduled for March We will progress the recommendations made by our technical auditor to continue to develop our method statements. Regulatory reporting Water quality risk assessments: Our internal review identified the water quality risk assessments that we provide to the Drinking Water Inspectorate as medium risk. To mitigate the risk, we plan to implement improvements to internal governance through a monthly risk meeting and to focus on reviewing drinking water safety plans and actions. We are also working with the DWI and LRQA for formal accreditation of our drinking water safety plans. PR19 Business plan submissions: In our information risk register, the PR19 business plan submission was identified as high risk. As detailed in the previous section, our assurance plan for 2018 included an action to ensure we complete the price review applying the most stringent assurance processes, giving Ofwat, customers and other stakeholders confidence that the data we use to base our calculations on is fit for purpose. To include all submissions and pre-submissions as set out in the previous table. The main business plan submission is now complete, and we have received only a small number of queries from Ofwat. We consider we are well prepared for future submissions and this risk can be reduced to medium. Annual performance report B4 compliance with abstraction licences: In our internal review we identified this measure as medium risk as the method relies on some minor interpretation and judgement. To mitigate the risk of inaccurate reporting, we plan to review our approach in collaboration with the Environment Agency and their processes for assessing compliance. B6 BAP landholding assessed and managed for biodiversity: Our internal review highlighted this performance commitment as medium risk. This measure was new in the reporting period. Although the reporting rules are clear and the process is detailed in a method statement, our internal review identified an error in reporting in prior years, which was also highlighted by an Ofwat query. To reduce the risk of inaccurate reporting in the future, we plan to change the ownership for reporting to align with the updated business structure, to provide training for new employees involved in the process and to introduce additional checks prior to future reporting. We will ensure that as business structures are amended in future that ownership for reporting of performance commitments is amended at the same time. 12

15 D3 water supply interruptions minutes lost: Following their review of the 2018 Annual Performance Report, our technical auditors highlighted that the new industry-wide supply interruptions reporting measure, currently shadow reported alongside companies own measures, has developed well. They found a lack of detail in the records for some events and recommend keeping full records of the decisions made for each event. In addition, they highlighted the need to strengthen the checking process applied to the data, from collection through to reporting. We will adopt both recommendations. F1 volume of water leaked: In our internal review we identified reporting of leakage as high risk linked to the new reporting method. As the new reporting method (as per the consistency project) will be well established by 2020, we consider this will reduce the risk to medium as the likelihood of inaccurate reporting will decrease. In addition, we will adopt the recommendation made by our technical auditors to implement the remaining technical actions to finalise the measure. Annual Performance Report (Section 1 Regulatory financial reporting): Our internal review assessed the risk associated with reporting inaccurate data in section 1 of the APR as medium. The existing controls include well established and governed regulatory accounting reporting processes, experienced reporting employees, director sign-off and annual external audits. However, changes to reporting structure and personnel completing certain tasks in combination with some previous errors increase the likelihood of reporting inaccurate information. To further strengthen the reporting process, we plan to allow additional time to prepare the data and to introduce additional checks, particularly focusing on previous errors. Annual Performance Report (Section 2 price control and segmental reporting): Our internal review assessed the risk associated with reporting inaccurate data in section 2 of the APR as high. The weaknesses identified in our review included that some cost data comes from other systems aside from the general ledger, that some management estimating is required, and that reporting documentation should be improved. To strengthen the reporting process, we propose to review and update the reporting documentation and introduce additional checks, particularly focusing on previous errors. We consider these mitigating actions will reduce the overall risk to medium. Annual Performance Report (Section 4 additional regulatory information): We consider the risk of inaccurate reporting in section 4 of the APR as medium. The main weaknesses identified in our review were that reporting rules continue to be fluid, some management estimates will be required, and a small number of previous errors have been found. To strengthen the reporting process, we propose to introduce additional checks, particularly focusing on previous errors. Wholesale cost assessment data submission: Our internal review assessed the risk associated with reporting inaccurate data in the wholesale cost assessment submission as medium. The weaknesses identified in our review included a small number of previous errors; some complex and incomplete data sources and the need for some management estimates. To strengthen the reporting process, we plan to carry out a full external audit of the submission with extra focus on previous errors. We will also further improve the reporting documentation. Other stakeholder information Developers charging arrangements: In their feedback, CCWater highlighted that they would have appreciated advanced notice that there was a consultation on our developers charging arrangements. While this was published on our website, we have committed to ensure that they receive a specific notifying them of such a change in the future. Developer services (routine enquiries): Our internal review identified the risk associated with providing inaccurate data to developers as part of routine enquiries as medium. To reduce the risk, we plan to introduce on line application forms that will reduce data entry errors. In addition, improved asset data information will help to avoid providing incorrect information to customers. 13

16 Next steps We will engage with stakeholders further before publishing more details on how we assure the data we provide, and our plans to further improve in our Draft Assurance Plan in early If you want to contact us at any time, we are available at Section 5 Assurance statement This Information risks, strengths and weaknesses statement has been reviewed and assured by the Wessex Water Audit and Risk Committee, which includes all the independent non-executive directors of the company board. The company pays close attention to its data quality and verification procedures and has a detailed Regulatory Assurance Manual setting out the process for assuring all data. The committee confirms that the company has complied with all its relevant statutory, licence and regulatory obligations and is taking appropriate steps to manage and/or mitigate the risks it faces. The committee confirms it is satisfied it has the appropriate assurance processes in place and, based on these process, endorses this assurance statement and states, to the best of its knowledge and belief, the information produced is accurate, reliable and complete in all material respects. 14