CSR assurance
Scope and objectives
Two Tomorrows (Europe) Limited has undertaken independent assurance of the FirstGroup plc (FirstGroup) 2010 Corporate Responsibility Report (the Report)
The assurance process was conducted in accordance with AA1000AS (2008). We were engaged to provide Type 2 assurance, which covers
- evaluation of adherence to the AA1000APS (2008) principles of inclusivity, materiality and responsiveness (the Principles) and
- the reliability of specified sustainability performance information.
All of the performance data in the Report and associated web pages is included in the scope of this work with the exception of any financial information subject to audit under the FirstGroup Annual Financial Report.
We used the Global Reporting Initiative (GRI) Quality of Information Principles as Criteria for evaluating performance information as well as existing FirstGroup data quality standards where appropriate.
Responsibilities of the directors of FirstGroup and of the assurance providers
The Directors of FirstGroup have sole responsibility for the preparation of the Report. We were not involved in the preparation of any part of the Report. This is the seventh year in which we have provided assurance for FirstGroup's Corporate Responsibility disclosures. We have also provided recommendations on the FirstGroup Materiality Process independently of this assurance.
Our statement represents our independent opinion and is intended to inform all of FirstGroup's stakeholders including management. We adopt a balanced approach towards all FirstGroup stakeholders.
Our team comprised Todd Cort and Vicky McAllister (Project Leaders) and Mark Line (Project Director) as well as Anne Euler and Doug Bannerman. Further information, including individual competencies relating to the team can be found at: www.twotomorrows.com
Basis of our opinion
Our work was designed to gather evidence with the objective of providing moderate assurance as defined in the AA1000AS (2008). We undertook the following activities:
- Review of information provided to us by FirstGroup on its reporting and management processes relating to the AA1000 Principles.
- Review of the current Corporate Responsibility issues that could affect FirstGroup and are of interest to stakeholders
- Review of stakeholder engagement practices and FirstGroup's response to issues raised
- Review of the draft Report to identify material claims for further checking and clarification during the site visit and management interviews.
- Three site visits to review management systems for sustainability areas discussed in the Report including two in the United States (Greyhound Chicago and First Student San Francisco) and one in the United Kingdom (Scotland East for UK Bus).
- Senior and Executive management interviews in the United States and United Kingdom to assess management and adherence of the company to the three assurance Principles.
- Review of supporting evidence for key claims in the report
- Review of the processes for gathering and consolidating data and, for a sample, checking the data consolidation
Findings
We reviewed and provided feedback on drafts of the Report and where necessary changes were made. On the basis of the work undertaken, nothing came to our attention to suggest that the Report and supporting information on the FirstGroup website do not properly describe FirstGroup's adherence to the Principles or its performance.
Observations
Without affecting our assurance opinion we also provide the following observations.
Inclusivity concerns the participation of stakeholders in developing and achieving an accountable and strategic response to sustainability.
- The introduction of the CSR External Advisory Group has been a positive development. It has discussed several material issues which form part of FirstGroup's CSR programme. We look forward to seeing FirstGroup build on this example to improve its understanding of stakeholder concerns for senior managers, both in the UK and North America.
- We note the efforts to improve local employee engagement and the introduction of a new learning and development programme for managers. This was done in order to heighten their awareness of key employee issues and how to respond to them (as well as other areas). We look forward to seeing an account of the impact of these activities in future reports.
Material issues are those which are necessary for stakeholders to make informed judgments concerning FirstGroup and its impacts.
- There is an opportunity to further improve supplier management and engagement. Until now, efforts to improve supplier responsible practices have focused on supplier self assessment. Looking forward, FirstGroup should focus on improving communication and verification methods, prioritising materials sourced in developing markets.
- Filling engineering and technical positions continues to be a challenge within the industry. It is not clear that current efforts (apprenticeship, training and certification) will be sufficient to address the demand. We anticipate that this will be a focus area for the new Group-level HR function
- FirstGroup has this year undertaken a more robust materiality assessment process, with input from senior management and the CSR external advisory group. This should help FirstGroup identify any new, emerging key issues for its CR and reporting work.
Responsiveness concerns the extent to which an organisation responds to stakeholder issues
- The last year marked several positive changes in First Group America (FGA), highlighted by increased awareness and ownership of CSR at the senior level, for example through the American Management Board and CSR Working Groups.
- The focus for environmental management in FGA over the last year has been on robust and detailed data collection. The next step will be to use this data to formulate and agree targets that go 'beyond' regulatory compliance. More aggressive targets will complement existing proactive management efforts in place such as current efforts to close contaminated sites.
- Following the 2008 employee engagement survey, we note that the UK Bus division has undertaken considerable work in communicating survey results, developing action plans and understanding the reasons behind the less than satisfactory employee engagement scores, through a number of focus groups and 'touch point' surveys. We look forward to seeing the impact these actions have on improving engagement and supporting better management mechanisms.
Performance information
- Many performance metrics have improved in 2009 as a result of focused efforts. In particular, we note the improved data for a fuel baseline in FGA. Despite these efforts, data protocols for some key performance indicators still need to be formalised to ensure consistency in data reported from the operations.
- Waste and recycling data in the Report is based on measured and estimated values. Therefore small changes in performance should not be considered significant.
Two Tomorrows (Europe) Limited
London
June 2010