Business continuity
Business continuity policy
The NWL Board recognises the importance of business continuity and requires the company to have a series of business-owned, business-driven processes that establish a comprehensive fit-for-purpose strategic and operational framework that:
• Proactively improves the company’s resilience against the disruption of its ability to achieve its key objectives;
• Provides a rehearsed method of restoring the company’s ability to supply its key services and products to an agreed level within an agreed time after a disruption;
• Delivers a proven capability to manage disruptions to various business processes and protects the company’s reputation, assets and financial position.
Business continuity action plan
Under the direction of the NWL Board Audit Committee and the Security, Emergency Planning, Occupational Safety and Health (SEPOSH) management team group, NWL has developed a series of Business Continuity, Disaster Recovery and Emergency Planning documents that provide guidance and information to assist in the delivery of the above policy. In particular it is NWL’s intention to have plans to:
• Meet the requirements of the Security and Emergency Measures Direction 1998, with respect to alternative water supplies in times of emergency.
• Meet the requirements of the Civil Contingencies Act – “Emergency Preparedness” and “Emergency Response and Recovery” as statutory regulations and non-statutory guidance.
• At all times, give highest priority to the health, safety and security of its employees and customers.
• Ensure that public health is not compromised.
• Safeguard water and sewage services.
• Protect the aqueous environment.
• Mitigate the effects of foreseeable incidents and crises.
• Respond rapidly and appropriately to other incidents and crises.
• Safeguard and protect its assets and water resources.
• Safeguard and protect its reputation.
• Regularly exercise and update its business continuity, disaster recovery and emergency plans.
In addition, NWL ensures resources and skills are available to the business so that:
• Appropriate and fully equipped facilities are provided for emergency management teams.
• Regular exercises are carried out.
• Lessons learned from exercises are recorded, plans are updated and appropriate action taken to prevent recurrence.
• Adequate and appropriate emergency stocks and provisions are held and strategically located.
• Employees are available and appropriately trained in emergency management at operational, incident and crisis levels.
• Rules, procedures, standards and systems, including all relevant legislation, relating to business continuity, disaster recovery and emergency management are strictly observed, regularly reviewed, communicated to employees and monitored for effectiveness.
• Employees are actively encouraged to develop high levels of awareness of good business continuity, disaster recovery and emergency management practices and to participate and cooperate in maintaining these in their everyday work.
Business continuity KPIs
The Company’s Business Continuity, Disaster Recovery and Emergency Plans are continually being reviewed, expanded and updated to ensure that they remain current and fit-for-purpose in a constantly changing environment. To ensure satisfactory performance is being maintained:
1) The NWL Audit Committee and SEPOSH Group will receive and review a report on the Company’s Business Continuity, Disaster Recovery and Emergency Plans on an annual basis. It is a requirement for the business that the Audit Committee and SEPOSH Group are satisfied and endorse that annual report.
2) As part of their annual IT Audit, NWL’s external financial auditors carry out an independent review of the Company’s Disaster Recovery and Business Continuity provisions. The findings from that independent review are reported to the NWL Audit Committee and Management Team. It is a requirement that any reported inadequacies in provisions that are identified by the external financial auditor are addressed to the satisfaction of the NWL Audit Committee and Management Team.
3) The Security and Emergency Measures Direction (SEMD) is a statutory document produced under the provisions of Section 208 of the Water Industry Act 1991. It places upon the Company the requirement to: “..keep under review and revise such plans as it considers necessary to ensure the provisions of essential water supply…and wastewater services at all times.”
As part of the SEMD requirements it is necessary for the Company’s emergency plans to be independently audited and certified annually and for a copy of the external auditor’s report to be provided to DEFRA. In addition, it is a requirement for the company to arrange for an independent audit to be carried out every three years to review the security provisions at its external designated key sites and for a copy of that auditor’s report to be provided to the Security Services. As part of the Company’s internal processes it is a requirement that any inadequacies in provisions identified by either of these external audits are reported and addressed to the satisfaction of the NWL Audit Committee and Management Team.
Business continuity case study
NWL carries out regular internal exercises and tests to examine the applicability and robustness of its Business Continuity, Disaster Recovery and Emergency Plans, skills and resources. In addition, NWL participates in national, regional and local emergency exercises with the security, local government, utility and emergency services. Some examples of these include:
Exercise 'Magpie', Newcastle Civic Centre, April 2004
This CBRN (Chemical, Biological, Radiological and Nuclear) contamination exercise was the largest of its kind anywhere in the UK outside of London.
Scenario: A 'dirty' bomb exploding in Newcastle City Centre.
NWL’s participation in the major regional exercise comprised representation on the 'Silver' or 'Tactical' team along with Newcastle City Council, the Health Agency, Government Office North East (GONE), the National Civil Contingencies Secretariat, Regional Emergency Planning Units and local Emergency Services.
Exercise 'Norland', South Tyneside Council, South Shields, November 2006
Scenario: Widespread flooding in South Tyneside affecting sewers and wastewater treatment sites.
NWL participated in the 'Silver' or 'Tactical' team along with Local Councils, Local Emergency Planning Units and the Emergency Services.
Exercise 'Aragon', Sizewell 'B' power station, March 2007
Scenario: A fire in a plant room produced an escape of a radioactive cloud which moved over sites in our Essex & Suffolk Water supply area.
NWL participated in the gold team at the Local Emergency Centre at Sizewell with Government Office for the East of England (GoEast), the EA, DTI, Defra, Suffolk County Council, Police, Fire and Ambulance.
Exercise 'Jinx', Go East Offices, Cambridge, October 2006
Scenario: Flu pandemic.
NWL participated in the silver team with Essex County Council, Suffolk County Council, GoEast, Anglian Water Services, Network Rail, Essex Police, Fire Service, Ambulance and Local Health Authorities.