Guardian News and Media Limited (“Guardian”) commissioned DNV GL Business Assurance Services UK Limited (“DNV GL”) to undertake independent data verification of selected environmental indicators in the Living our Values Report 2014/2015 (“LoV 2014/15 Report”) for the reporting year ended 29 March 2015.
The scope of our data verification includes the following six carbon management and operational efficiency KPIs in the Climate Responsibility Section:
Carbon management:
- Total carbon emissions
- Carbon efficient digital media
- Carbon efficient print media
Operational efficiency :
- Data Centre efficiency
- Unproductive energy
- Building energy
The review of other data and content within the LoV 2014/15 Report and financial data from the Annual Report and Accounts was not within the scope of our work.
Opinion
On the basis of the work undertaken, in terms of reliability of the carbon and operation efficiency data in scope, 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 utilised were inappropriate. We are not aware of any errors that would materially affect the data presented.
Our methodology and approach
We planned and performed our work to obtain the evidence we considered necessary to provide a basis for our data verification opinion. We used the methodology described below to evaluate the accuracy, comparability and timeliness of the carbon management and operational efficiency data in scope, as well as the reliability of underlying data management systems for how data should be measured, recorded and reported.
We evaluated the carbon management and operational efficiency indicators using the reliability principle from the GRI’s Principles for Defining Report Quality.
We planned and performed our work to obtain the evidence we considered necessary to provide a basis for our data verification opinion. We are providing a “limited level” of data verification.
A multi-disciplinary team of sustainability and verification specialists performed work at headquarters and site level. We undertook the following activities:
- Visit to the Guardian’s headquarters in London to assess full year data for the carbon and operational efficiency data in scope. This involved reviewing and sample checking the measurement, collection and reporting processes;
- Interviews with data owners who are responsible for oversight and implementation of data gathering, aggregation and quality control for the performance indicators included within the scope of data verification;
- Review of the controls and supporting evidence for the collation of data and consolidation process through interview with the Environment and Sustainability Manager to understand how the carbon and operational data in scope are represented in the LoV Report 2014/15 and that this has been represented accurately;
- Tested the KPI figures reported were consolidated from source spreadsheets and source data into the main spreadsheet correctly. Reviewed and clarified that all relevant sites/business operations were included in the data aggregation, collation and consolidation for relevant performance indicators in scope;
- For relevant performance indicators in scope, checked that conversion factors were in line with the 2014 Defra carbon conversion factors;
- Site visit to the Guardian Print Centre to review process and systems for preparing site level sustainability data and checking data consolidation at site level. The site visit involved a site tour, interviews with the provider of the data for environmental reporting, and testing a sample of reported data back to source evidence; and
- Interviews with selected senior managers responsible for management of sustainability issues.
Responsibilities of Guardian News and Media and of the data verification providers
The Guardian has sole responsibility for the preparation of the LoV 2014/15 Report. In performing our data verification work, our responsibility is to the management of the Guardian; however our statement represents our independent opinion and is intended to inform all of its stakeholders. DNV GL was not involved in the preparation of any statements or data included in the LoV 2014/15 Report except for this Data Verification Statement.
We have advised the Guardian in the past on its approach to responsible paper sourcing. This role moved primarily to one of assuring the sourcing data five years ago – which we view as fully compatible with our overall data verification role.
DNV GL’s verification engagements are based on the assumption that the data and information provided by the Guardian 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 Data Verification Statement.
Observations and recommendations
Without affecting our data verification opinion, and recognising the overall progress made by the Guardian in the areas covered by the data in the scope of the exercise, we make the following observations and recommendations:
We observed that the Guardian uses non-automated (manual) data transfers between raw data files and consolidated reports. Due to the large number of different raw data files, there may be a potential risk of error or misinterpretation, especially if the data owners responsible for these activities were to change. We recommend that the Guardian reviews its data processes to identify opportunities to minimise manual transfers of data. Please also see the recommendation below;
We found that there was no formal, documented guidance for the data capture, calculation and aggregation. We recommend that the Guardian considers developing a methodology reporting manual which includes clear definitions of the calculation methodology used, the scope and boundary for each KPI, the data review, checking and audit processes and the data owners responsible for these activities;
With regards to Energy Processing Efficiency, we observed that there were no formal targets for energy use at the print sites, nor for energy reduction and efficiency at business operations. We recommend that, where appropriate, the Guardian develops SMART targets; and
The traffic light colour coding system displayed in the LoV Report 2014/15 was only linked to a percentage threshold for change from the previous year. We recommend linking these to actual target performance to increase transparency on current performance levels.
In previous years, interviews with management highlighted that there was room to improve internal communication on sustainability. This was reflected again in this year’s management interviews. We recognise that embedding sustainability across the whole organisation is a continuous journey, and recommend Guardian to continue to adopt and develop its long term approach and strategy for integrating and embedding sustainability across the organisation
For and on behalf of DNV GL Business Assurance Services UK Limited
London, UK
7 September 2015
Tracy Oates
Principal Consultant and Lead Assuror
UK Sustainability, DNV GL – Business Assurance
Kate Bruintjes
Principal Consultant and Reviewer
UK Sustainability, DNV GL – Business Assurance
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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
