SPAA Risk Register Operating Plan October V 1

SPAA Risk Register & Operating Plan October. V 1. 2 2019

Risks and Opportunities Log Ref Title Source Risks/Opportunities (General) Potential Outcome Risks/Opportuniti es (SPAA Specific) Potential Outcome 2 In SPAA Operating Plan? Date added Last Updated No July 2018 September 2019 Clean version of the draft code shared with working group members for review, No further update. Yes August 2018 September 2019 Collating feedback for phase two. Yes Update 1. SPAA 1. 1 Supplier Data Flow Catalogue 1. 2 Metering Code of Practice Amalgamation 1. 5. 1 New SPAA Website (Post Implementation) FS 559738 EMS 559739 IS 619353 More fluid market Increasing part of with new the market relationships outside the No update - currently a beyond the existing Code; watching brief. traditional potentially new ‘supplier hub’ non-level playing concept field Horizon Scanning Opportunity to Metering amalgamate Parties MAMCo. P and AMICo. P A comprehensive and consolidated Code of Practice for both MAMs and AMIs SPAA Enhanced functionality Executive Delivery timescales of the SPAA website. Committee | 2 | Electra. Link confidential | ©Electra. Link 2018 September 2019

Risks and Opportunities Log Ref 1. 8 1. 9 Title Gas Theft Detection Incentive Scheme (GTDIS) Source Theft Risks/Opportunities (General) Potential Outcome Risks/Opportu nities (SPAA Potential Outcome 2 Specific) A TIG Member has flagged that there is a risk that the once a year payment The TIG is considering schedule of the whether the incentive current incentive scheme payments should be scheme may be made more frequently. causing cashflow issues for smaller Suppliers. SCP 443 Provision of SPAA Opportunity to customer contact data Executive develop SCP 443 via to Transporters - Committee SPAA Working Group Improvement of customer experience through a new SPAA process for the transfer of customer contact information from Suppliers to Transporters Opportunity to Transition of process to UNC Joint SPAA & UNC MDD SPAA develop the migration governance as required by 1. 10 Migration Working Executive of Market Participant Ofgem for CSS Group Committee MDD to UNC implementation governance FS 559738 EMS 559739 IS 619353 | Electra. Link confidential | ©Electra. Link 2018 Update In SPAA Operating Date added Plan? A comprehensive review of theft incentive schemes is being undertaken as part of the Theft Strategy Work. SCP 443 approved at the August 2019 Change Board. Last Updated No November 2018 October 2019 Yes November 2018 August 2019 Yes January 2019 October 2019 See chart update here Ofgem have approved all modifications associated with this initiative, to be implemented 28 February 2020. Xoserve are required to undertake a ‘parallel’ publishing period from November 2019 for testing purposes.

Risks and Opportunities Log Ref 1. 11 Title Schedule 22 Reporting 1. 12 Joint Theft Reporting Review 1. 13 Theft Ofgem FS 559738 EMS 559739 IS 619353 Source Risks/Opportunities (General) SPAA Executive Reporting Timescales Committee Potential Outcome Risks/Opportunitie s (SPAA Specific) Opportunity: the reporting should Reporting is not add value where delivered in line Parties are able to with the review it and take contractual action where the timescales report indicates they may be noncompliant. Potential Outcome 2 Update EC approved performance Each Supplier improvement option to should receive a commence July 2019. The copy of the report was anonymised and report, showing published. Each Supplier was their assigned a unique ID to look organisation’s up their performance which data, to enable was issued in July. them to monitor compliance. Ongoing reporting. Opportunity: To review and resolve Remediation of discrepancies Opportunity: To review theft discrepancy in The JTRR has now concluded between data reporting processes following with 33 improvement confirmed Improvements to reported by numerous comments from reported across recommendations made. The SPAA Theft theft reporting Suppliers via SPAA Suppliers, Shippers and different parts JTRR closure report will be Groups across both SPAA (TRAS and Sched Transporters that the of industry and presented to the EC in due 33) and that and UNC requirements are unclear and simplification or course. reported by may not add value reporting Shippers into requirements Settlement, under the UNC Ofgem has been Ofgem will be attending a There is a risk that the Ofgem asked to provide TSG meeting to discuss the SPAA Theft Review will impact on the more information TRAS and ETTOS Contracts. Executive SPAA theft schedules and on its review to Any impacts on SPAA will be Committee associated contracts with the Theft Steering identified as part of the Experian and Crimestoppers Group strategy review. | 4 | Electra. Link confidential | ©Electra. Link 2018 In SPAA Operating Plan? Date added Last Updated No January 2019 September 2019 Yes April 2019 October 2019 No April 2019 October 2019

Risks and Opportunities Log Ref Title Source Risks/Opportunities (General) Potential Outcome Risks/Opportunities (SPAA Specific) Potential Outcome 2 Update 1. 14 Consistently Risk: SPAA Parties may be ‘last frustrated change Risk: SPAA projects and changes that involve in the queue’ to receive new development, central systems are often dependent on SPAA Parties are unable systems that may be essential where central Xoserve and DSC Parties and there are often to fully assess how SPAA for the progression of positive system change is Central Systems SPAA lengthy timelines. Xoserve will prioritise any industry change. SPAA Parties requirements may also required. Change Executive ‘core’ service requirements above anything else Monitor are less able to assess the costs translate into central Inordinate delays Congestion Committee – and SPAA related projects are not considered systems design, ahead of and impacts of systems changes to positive as core service which means they are low voting on SPAA changes. as central systems are not industry changes priority, particularly during times of change developed until after SPAA that are outwith congestion. obligations have been approved. SPAA’s control. 1. 15 Improved processes and Risk: Many processes that are fundamental to improved experience of the operation of SPAA have not received review users of processes SPAA since the inception of SPAA in 2004 (e. g. Outdated SPAA (particularly newer, Executive accessions, withdrawals, etc) and simple Processes smaller participants). Committee improvements are possible to either remove Learning applied to REC unnecessary potential barriers or codify de for benefit of Parties in facto processes that work well. future. FS 559738 EMS 559739 IS 619353 | 5 | Electra. Link confidential | ©Electra. Link 2018 In SPAA Date Operating added Plan? Accession improveme nt SCP underway. Further processes to be reviewed. Last Updated No July 2019 August 2019 No July September 2019

Risks and Opportunities Log Ref Title Source Risks/Opportunities (General) Potential Outcome Risks/Opport unities (SPAA Specific) Potential Outcome 2 Update In SPAA Operating Plan? Date added Last Updated No July 2018 September 2019 Yes July 2018 September 2019 2. Retail Energy Code (REC) 2. 1 2. 2 Ensure SPAA ready to transition on time and have contingency in place in case of delays. Work closely with MRA and OFGEM Forward Uncertainty, Delay in planning/ greater Risk - Does not go implementation implementati REC Horizon Scanning administrative live on time creating uncertainty in on burden and cost markets compromise NDA – SPAA to parties d transition arrangements to be agreed in September 19 Complications Delayed Monitor developments arising during implementation of Continue to work with Risk – coordination Ofgem Faster Switching across codes and development key parts of the Ofgem and CACo. P to Horizon Scanning across the Programme Ofgem to ensure SPAA and programme and deliver best possible programme stays on track implementati imperfect outcomes. on phases outcomes FS 559738 EMS 559739 IS 619353 | 6 | Electra. Link confidential | ©Electra. Link 2018

Risks and Opportunities Log Ref Title Source Risks Review SPAA Schedules 2. 3 REC Ofgem Theft & Metering Subgroups of the EC SPAA Change Process FS 559738 EMS 559739 IS 619353 Risks/Opportun Potential Outcome ities (SPAA Specific) Risks/Opportunities (General) Potential Outcome 2 Update Prepayment Schedules were reviewed and Simpler Opportunity to consolidated, metering governance review schedules are being structure overall schedules and consolidated, SPAA data Ensure Schedules and lower flow catalogue are fit for purpose to remove administrative redundancy developed, as well as a and ready for burden number of other SPAA transition Schedules. Uncertainty of Theft and Metering Maintain a watching schedules. brief. In SPAA Operating Plan? Date added Last Updated Potential there will be subgroups that will run parallel to the REC therefore requiring Parties to adhere to both. Significant code review outcome – existing and future changes that will be impacted by the SCR. | 7 | Electra. Link confidential | ©Electra. Link 2018 No November 2018 September 2019 No October 2019 Maintain a watching brief. No October 2019 This is being mitigated by the monitoring through the existing SPAA Change Process and reviewed by the group each month. No October 2019

Risks and Opportunities Log Ref 2. 4 2. 5 Title Erroneous Transfers BEIS/OFGEM Code Review FS 559738 EMS 559739 IS 619353 Source Ofgem BEIS Risks/Opportun Potential Outcome ities (SPAA Outcome 2 Specific) Reduction in the Opportunity to establish volume of ETs; Reduction in ET an industry led improve operational volumes is not performance assurance working practices achieved and Ofgem mandates more onerous framework to across the industry; mitigating demonstrate active establish and test actions not action measures to reduce ET performance demonstrated volumes. assurance framework to Ofgem prior to REC Risks/Opportunities (General) Update ET Performance Assurance Board established – inaugural meeting 28 Aug 2019. In SPAA Operating Plan? Date added Last Updated No July 2018 September 2019 No March 2019 September 2019 Maintain a watching brief on developments and brief SPAA EC as needed. The review delivers outcomes that could disrupt the consolidation process involving SPAA and MRA activities being incorporated into the REC. This would bring uncertainty and complexity into the process and, potentially, additional costs to SPAA. BEIS and Ofgem have issued invitation requests for workshops which are to take place in September. Update to be provided in September meeting. | 8 | Electra. Link confidential | ©Electra. Link 2018

Risks and Opportunities Log Ref Title Source Risks/Opportunities (General) Risks/Opportun Potential Outcome ities (SPAA Specific) Potential Outcome 2 Update In SPAA Operating Plan? Date added Last Updated Yes September 2019 October 2019 Approval of workpages 1 -6 at September 2019 SPAA EC. 2. 6 SPAA and SPAA Ltd Closure Project FS 559738 EMS 559739 IS 619353 Ofgem Closure of SPAA and Orderly shutdown of SPAA transition to REC | 9 | Electra. Link confidential | ©Electra. Link 2018 Maintain a watching brief as is reliant on the progression of the Switching Programme.

Risks and Opportunities Log Ref Title Source Risks/Opportunities (General) Potential Outcome Risks/Opport unities (SPAA Specific) Potential Outcome 2 Update In SPAA Operating Plan? Date added Last Updated Matter being discussed at CACo. P and regular updates provided by SPAA representative. Ongoing engagement with Ofgem and visibility to EC members of initiative No August 2018 June 2019 3. Joint Initiatives Support for Ofgem initiative and SPAA kept abreast of any changes or consequential Opportunity to requirements support Ofgem Innovation Link / Ofgem's 3. 3 Support for Ofgem Sandbox innovation initiative and SPAA initiatives. kept abreast of any changes or consequential requirements 3. 5 MRA Secure Communications Working Group (SCP 472) FS 559738 EMS 559739 IS 619353 Risk that SPAA may be subject to any outcomes. Risk that SPAA not Risk that SCP able to influence 472 will not discussions and that a solution not fit for be sufficiently Cross code Communication methods not SPAA Parties is developed to working. fit for purpose agreed enable voting by SPAA Change Board | 10 | Electra. Link confidential | ©Electra. Link 2018 No current action required – mitigation by approval to establish SCP 472 WG which gives SPAA Parties ability to influence method. Update to be provided in the September meeting. Yes November 2018 September 2019

Risks and Opportunities Log Ref Title Source Risks/Opportunities (General) Potential Outcome Risks/Opportuni ties (SPAA Specific) Potential Outcome 2 Update In SPAA Operating Plan? Date added Last Updated 4. Market Developments 4. 2. 1 2022 Election Horizon Even greater focus on Greater government Scanning cost to consumers intervention Potential for an early Horizon As above but sooner election Scanning than 2022 4. 3 New regulatory regime Third Parties 4. 4 Market Churn Third Parties FS 559738 EMS 559739 IS 619353 Explore potential scenarios Constrains parties and highlight concerns to Further changes and SPAA Authorities to regulatory resulting in less No regime competition and No update - Maintain a innovation watching brief. As above but sooner than 2022 As above No Gain a good understanding of what is being proposed Change in New relationships and the implication for spectrum of Challenge the existing Create a new regulatory between Parties, Parties. Contribute to the No Parties and what regulatory framework consumer and debate. is expected of regulator them No update - Maintain a watching brief. Ensure contingency measures remain fit-for. Greater burden Higher Reduced purpose on remaining administrative competitiveness of Higher cost to consumer Second phase of Ofgem No market costs on market license review to look at participants remaining Parties making changes to the So. LR process. | 11 | Electra. Link confidential | ©Electra. Link 2018 July 2018 September 2019 June 2019 September 2019 July 2018 September 2019

Risks and Opportunities Log Ref 4. 6 Risks/Opportuni In SPAA Title Source Potential Outcome ties (SPAA Potential Outcome 2 Update Operating Specific) Plan? As SPAA provides the Any reform of Blurring of the lines infrastructure competition policy Previously it was between consumer for retail thought competitive will change CMA and competition markets any enforcement markets were in policy. If a policy dysfunction will priorities. consumers best seems unfair then it potentially be interests. The new can be taken up by an Reform to UK Analysis will focus regime will focus on the CMA. administrative Competition Policy- CMA on consumers and consumer outcome. SPAA EC to maintain priority as No changes to primary letter to not on technical SPAA will have to a watching brief. issues will be CMA duty BIES aspect of CMA will be able to update its picked up by competition make arguments compliance policies. the CMA. economics. Competition cases will SPAA will have to CMA is also CMA also point out be run on a faster time adjust any active in the that there is public scale than they have competition digital space doubt the benefits of before. monitoring systems that could have market it may have. an impact on SPAA. FS 559738 EMS 559739 IS 619353 Risks/Opportunities (General) | 12 | Electra. Link confidential | ©Electra. Link 2018 Date added Last Updated March 2019 September 2019

Risks and Opportunities Log Ref Title 4. 7 Labour Party Letter 4. 8 Open Data Framework FS 559738 EMS 559739 IS 619353 Source Risks/Opportunities (General) Potential Outcome Risks/Opportunities (SPAA Specific) Fundamental change Nationalised energy Unknown how Horizon to energy market. industry. Exact nationalisation will Scanning` Exact risks unknown. outcome unknown impact SPAA Potential Outcome 2 Update Unknown how nationalisation Monitor will impact SPAA General risks and Opportunity to begin A potential sea opportunities ground work for open change in the way the presented by the data, through data industry holds, shift to the open data comparison and maintains and framework (e. g. cleansing (e. g. accesses data, with SPAA beginning Mi. Data) and clear removing bad data), less to put Refer to SPAA code implications in data reconciliation (e. g. duplication/overlap, foundations in SPAA terms of Expert Group for identifying and more defined place for more Executive requirements for populating missing discussion on responsibility and clarity in data Committee robust governance what actions may data), flow and better access to data ownership and that defines governance be required. improvements to for those who need it responsibilities for development (e. g. – with the end goal of current data sets. ‘mastering’ data, automating data sharing improving customer places security and exception experience in terms of standards on parties processes), definitive billing, switching, and monitors and data sources, validation, asset data, etc. assures data quality. etc. | 13 | Electra. Link confidential | ©Electra. Link 2018 In SPAA Operating Plan? Date added Last Updated No June 2019 September 2019 No July 2019 September 2019

Summary Ref. Title 2019 J 1. 2 Metering Amalgamation Group (MAG) 1. 11 Schedule 22 Performance Improvement 1. 12 Joint Theft Reporting Review 2. 2 Ofgem Faster Switching Programme 2. 4 3. 5 2020 F M A M J J A S O Erroneous Transfer Performance Assurance Board (ETPAB) Secure Communications Working Group (SCWG) / SCP 472 1. 5. 1 SPAA Website Phase 2 2. 6 SPAA and SPAA Ltd Closure Project FS 559738 EMS 559739 IS 619353 | 14 | Electra. Link confidential | ©Electra. Link 2018 N D J F M A M J J A S O

1. 2 Metering Amalgamation Group (MAG) Summary: MAG is a SPAA Executive Committee (EC) approved Working Group (WG) to consider SPAA Change Proposal (CP), CP 17/407 with seeks to clarify the accountabilities and responsibilities for both, Approved Meter Installers (AMIs) and Meter Asset Managers (MAMs), through an amalgamation of the Code of Practice documents into one – Metering Code of Practice. Impact Outlook Progress Updates: October 2019 - At the August 2019 MAG meeting, the group were provided with a draft copy of the new Metering Code of Practice. - SPAA are still awaiting a response from the MAG on the first draft version of the new amalgamated code. 2018 Milestones A M J J A 2019 S O Working Groups to develop proposed changes Consultation on Working Group proposals and finalisation of change proposal External legal review SPAA Schedule review Change proposal presented to change board FS 559738 EMS 559739 IS 619353 | 15 | Electra. Link confidential | ©Electra. Link 2018 N D J F M A M J J

1. 5. 1 SPAA Website Phase 2 Summary: Enhance the new SPAA website. Impact Outlook Progress Updates: October 2019: The SPAA Team continue to liaise internally as well as with customers to Collate all findings, feedback suggested improvements. These will be reviewed and scored to form the functional specification for phase 2. Once the functional specification is agreed, a statement of work and timeline will be produced to determine the implementation plan of the improvements. Milestones 2019 S 2020 O N D Collating feedback FS 559738 EMS 559739 IS 619353 | 16 | Electra. Link confidential | ©Electra. Link 2018 J F M A M J J A

1. 11 Schedule 22 Performance Improvement Summary: In June 2019, the SPAA EC agreed to implement a performance improvement option in order to allow Suppliers to view their transactional performance for a number of specific RGMA data flows (ONJOB, ONUPD, K 08) that are sent from their Shipper to the CDSP. This centralised reporting replaced the legacy ‘Metering Schedule Reporting’ in November 2018. Impact Outlook Progress Updates: Standing Update – updated by exception The CDSP provides the centralised report to SPAA by the 10 th Working Day of the month. SPAA has until the 20 th Working Day of the month to anonymise the report and host on the SPAA website, as well as sending to all Suppliers. Quarterly updates will be provided to the SPAA EC. October 2019 Update Third report was delivered on time Quarterly update to be provided during October EC meeting Target delivery dates 2019 J A S O 2020 N D Report delivered to Suppliers on/before 20 th WD? Quarterly Update to SPAA EC? FS 559738 EMS 559739 IS 619353 | 17 | Electra. Link confidential | ©Electra. Link 2018 J F M A M J A S O N

1. 12 Joint Theft Reporting Review Summary : The Joint Theft Reporting Review Working Group (including UNC Request 0677 R) has been established as a sub-committee of the Supply Point Administration Agreement (SPAA) Executive Committee (EC) pursuant to Clause 6. 2. 18 of the SPAA Main Body v 13. 0. This group is established as a joint SPAA and Uniform Network Code (UNC) Working Group to enable the joint review of theft reporting arrangements for Suppliers, Shippers and Transporters. The aim of this working group is to address concerns over discrepancies in the number of thefts reported by Suppliers, Shippers and Transporters and potential impacts on theft allocations, within Unidentified Gas (UIG) calculations, that are used in Settlement. The scope of this Working Group will be to review theft reporting arrangements contained within SPAA and the UNC, and, with reference to relevant licence conditions, make a recommendation for any change that may be required to improve theft reporting arrangements Impact Outlook Progress Updates: Meeting 08 (27 September 2019): • At the final meeting of the JTRR, the group conducted a detailed review of its final improvement recommendations and agreed amendments to better clarify the intent of the recommendations • The group also agreed several additional recommendations to ensure unison between the cross code recommendations for SPAA and UNC and to recommend that SPAA, UNC and DSC Parties cooperate in the development and implementation of the recommendations • At a high level, the JTRR has recommended that confirmed theft data that is input by Suppliers into TRAS be used to automatically update Settlement systems (current CMS operated by Xoserve) thereby; ensuring theft investigation outcomes reach Settlement; reducing the number of reporting channels for Suppliers and Shippers; and, eliminating the potential for discrepancies between theft outcomes reported by Suppliers and Shippers • To enact the improvement recommendations, the JTRR has also provided recommendations on the changes that may be required to both TRAS and CMS, to enable the automated flow of confirmed theft data • A further recommendation relates to changes in the way suspected theft is reported by Shippers to Suppliers and how this is tracked, with obligations being codified and a procedure established to ensure Shippers provide suspected theft reports to Suppliers and that Supplier provide a unique identifier (the ‘Supplier Investigation ID’) on receipt of the report • The JTRR has also recommended that SPAA and UNC parties respectively consider whether performance assurance is required, in respect of both TRAS and CMS performance for Suppliers and Shippers • The group finalised its improvement recommendations and discussed how/and by whom they would be taken forward • The group determined that, in addition to development at SPAA theft groups, UNC working groups and DSC committees, a ‘phase 2’ JTRR working group may be required to ensure SPAA, UNC and DSC Parties are able to jointly develop the processes required to enact the recommendations and any SPAA Change Proposals (SCPs), UNC Modifications and DSC Change Proposals, as may be required 2019 2020 • Milestones In total, the JTRR have made 33 improvement recommendations and now recommend that the relevant groups move forward with development and implementation, subject to industry governance and change control procedures J J F M A M J A S O N D J F M A Overview/consideration of existing theft reporting processes FS 559738 EMS 559739 IS 619353 Development and refinement of issues log | 18 | Electra. Link confidential | ©Electra. Link 2018

2. 2 Ofgem Switching Programme Summary: SPAA are currently providing resource to support the Ofgem Regulatory Design Team and Switching Design Forum where impacts to SPAA are monitored and identified. Monthly updates are being provided to the SPAA Executive Committee. Impact Outlook Progress Updates: • June 2019 – September 2019 Ofgem consultation ‘Switching Programme and Retail Code Consolidation: Proposed changes to licences and industry codes’ was issued on 17 June. The SPAA EC responded on 29 June. The consultation closes on 9 September. Regulatory Design User Group (RDUG) was held on 30 September where June consultation responses were discussed as well as clarifications to REC V 2 operational schedules such as MPAS. • February - May 2019 SPAA Ltd continue to support the Faster Switching Programme via a number of workstreams including design, regulatory, security and commercial. Ofgem are looking at options to further develop REC V 3 as some Schedules will not have been fully written and legally reviewed by the end of March 2019. Milestones Indicative timelines 2020 2019 J F M A M J J A S O N Development REC V 3 policy areas Ofgem publish June Consultation response Ofgem publish Q 4 governance consultation SCR Launch Statement to Industry Ofgem Consultation on licence drafting RECCo Manager appointed FS 559738 EMS 559739 IS 619353 | 19 | Electra. Link confidential | ©Electra. Link 2018 D J F M A M J J A S O

2. 6 SPAA and SPAA Ltd Closure Project Summary: Due to the Faster Switching Programme and Retail Energy Code upcoming implementation in April 2021, a project to close down SPAA and SPAA Ltd s required. Impact Outlook Progress Updates: • September 2019 Close down work packages 1 -4 presented to the SPAA EC. • August 2019 Initial discussion paper presented to the SPAA EC, looking at SPAA governance, contracts held and closure of a company. Milestones 2019 A 2020 S Discussion paper for closing down options Project work packages discussed by SPAA EC Project initiated Work Package 1 Work Package 2 Work Package 3 Work Package 4 Work Package 5 Work Package 6 FS 559738 EMS 559739 IS 619353 | 20 | Electra. Link confidential | ©Electra. Link 2018 O N D J F M A

2. 4 Erroneous Transfer Performance Assurance Board (ETPAB) Summary: Upon the closure of the Erroneous Transfers Working Group (ETWG) in May 2018, it was agreed that the MRA and SPAA Code Administrators would work together to develop a joint approach to the establishment of an ETPAB and assurance framework to support the reduction of Erroneous Transfer (ET) volumes for both gas and electricity. Impact Outlook Progress Updates: • Change Proposal 432 implementation 27/06 for MEC and 28/06 for SPAA. • The inaugural ET PAB was held in August 2019 and subsequent Boards are scheduled monthly up to the end of 2019 with agreed work schedules • Ofgem will be attending as an Observer from ET PAB 2 • Implementation lessons learned will be conducted after completion of the third ET PAB (by December 2019); effectiveness of the ET PAB will be reviewed by SPAA EC after 6 -months Milestones 2020 2019 J F M A M J J A S O SPAA EC / MEC Approval ET PAB Implementation ET PAB 1 ET PAB 2 ET PAB 3 ET PAB 4 + Agree ET PAB Schedule for 2020 ET PAB Implementation Lessons Learned ET PAB Operational Review FS 559738 EMS 559739 IS 619353 | 21 | Electra. Link confidential | ©Electra. Link 2018 N D J F M A M J

SPAA Change Proposals Awaiting Implementation FS 559738 EMS 559739 IS 619353 | 22 | Electra. Link confidential | ©Electra. Link 2018

1. 9 SCP 443 Working Group Summary: The SCP 443 Working Group has been established as a sub-committee of the Supply Point Administration Agreement (SPAA) Executive Committee (EC) pursuant to Clause 6. 2. 18 of the SPAA Main Body v 13. 0. The scope of this Working Group is to develop SPAA Change Proposal (SCP) 443 (Provision of customer contact data to Transporters) and, following industry consultation, produce a Working Group Report and any associated legal text as may be deemed necessary. Impact Outlook Progress Updates: UPDATE: October 2019 – SCP 443 was approved by Ofgem in October 2019, with an implementation date of June 2020, subject to approval of Xoserve Change Proposal XRN 4850. Transporters have advised that, following discussion and development of the systems requirements at Data Services Contract (DSC) meetings, there is potential that the change cannot meet either the June 2020 or November 2020 Xoserve releases, due to other industry projects that have taken priority. As such, there is a possibility that the systems required to implement SCP 443 will not be available until February 2021, despite the SPAA requirements having been agreed in August 2019. Central system change congestion has been added to the EC Risk Register as item 1. 14 (above). 2018 Milestones O N 2020 2019 D J F M A M J J A S O N Data transfer method reviewed and agreed Use cases agreed Business rules finalised and draft legal text produced Working Group consultation issued/reviewed Working Group report issued to EC Change developed/implemented in SPAA and central systems FS 559738 EMS 559739 IS 619353 | 23 | Electra. Link confidential | ©Electra. Link 2018 D J F M A M J J A S O N D

1. 10 Joint SPAA & UNC MDD Migration Working Group Summary : The Joint SPAA & UNC MDD Migration Working Group has been established as a sub-committee of the Supply Point Administration Agreement (SPAA) Executive Committee (EC) pursuant to Clause 6. 2. 18 of the SPAA Main Body v 13. 0. The aim of this Working Group is to give effect to Ofgem’s policy intent with regard to the migration of Market Participant Market Domain Data (MDD) from SPAA governance to Uniform Network Code (UNC) governance arrangements, thereby making the Central Data Service Provider (CDSP) responsible for the creation and management of gas Market Participant data. The scope of this Working Group will be to agree the changes required to both the SPAA and UNC to enable the migration to occur and to agree the implementation timescales. Impact Outlook Progress Updates: September 2019 – SCP 467 has been approved by Ofgem and will be implemented on 28 February 2019. The SPAA Secretariat is working with Xoserve regarding the reconciliation of information held between the SPAA MDD and UK Link and ‘parallel’ publication of the MDD is due to commence in November 2019 Milestones J F M A M J 2020 J A Final Joint MDD Migration Meeting (01 Feb 2019) Reconciliation of existing data (see following slide also) SPAA Change Proposal (submitted to March SPAA Change Board, 30 WD Impact Assessment, vote/approval at May SPAA Change Board) UNC Modification (pre-mod at Feb DWG, presented to March UNC Panel, consultation from April UNC Panel, voting/approval at May UNC Panel) DSC Change Proposal (submitted to Feb Ch. MC, developed, approved at June Ch. MC) Authority Consent obtained (SPAA and UNC) Implementation of change proposals (standard FS 559738 EMS 559739 IS 619353 SPAA and UK Link releases) | 24 | Electra. Link confidential | ©Electra. Link 2018 S O N D J F M A

1. 10 Joint SPAA & UNC MDD Migration Working Group continued…. 2019 Milestones J F M A M J 2020 J A Backstop implementation date (prior to CSS implementation testing) Publication of Market Participant MDD under new arrangements commences (parallel publication) Publication of Market Participant MDD under existing arrangements cease FS 559738 EMS 559739 IS 619353 | 25 | Electra. Link confidential | ©Electra. Link 2018 S O N D J F M A

3. 5 Secure Communications Working Group (SCWG) / SCP 472 Summary: In May 2018 the MRA Executive Committee (MEC) agreed to establish a group following concerns from MRA Parties that they are experiencing increased issues with the exchange of data over email because of different policies introduced to ensure compliance with the General Data Protection Regulation (GDPR). The SPAA EC subsequently identified this as a cross code issue and requested that Electra. Link attend the meetings to represent SPAA parties and ensure that, where appropriate, the issues are addressed for SPAA and common solutions taken forward in parallel. This has now evolved into SCP 472 and MRA CP 0262. Impact Outlook Progress Updates: SCP 472 (Web-based portal for sending customer information securely) • Closure report was delivered to the July SPAA EC meeting. • SCP 472 accepted for implementation in June 2020. • No further action required at this time. 2019 Milestones (updated for SCP 472) M J 2020 J A S IA IA Vote O N Terms of reference drafted & approved at the SPAA EC First Working Group meeting held and update delivered to SPAA EC Legal Review by Gowling Second Working Group Meeting to ‘sign off’ SCP Change Board Impact Assessment Period and Vote Implementation FS 559738 EMS 559739 IS 619353 | 26 | Electra. Link confidential | ©Electra. Link 2018 D J F M A M J J A

Projects with Ongoing Developments FS 559738 EMS 559739 IS 619353 | 27 | Electra. Link confidential | ©Electra. Link 2018

1. 4 RGMA Issues Resolution Group Summary: The aim of this Working Group is the identification and resolution of current RGMA compliance issues, in order to enhance bilateral relationships involving RGMA transactions. The scope of work undertaken by the RGMA IRG is limited to issues arising in processes, data and documents that are governed by RGMA, and will not cover business specific RGMA process implementation issues, or any commercial arrangements. Impact Outlook Progress Updates: • April 2019: - RFI issued 11 April 2019 with responses due by 15 May 2019. • May 2019: - Closure report and recommendations for May SPAA EC - Further work proposed to develop SCPs in June 19 • September/October 2019: - Work ongoing as part of phase 2 work package. - Change Proposals are to be drafted, sponsors identified and raised. - Updates will be provided as progress is made. Milestones 2019 J F M A 3 x Monthly Meetings Release RFI Develop and raise SCPs based on RFI Responses Report outcome to SPAA EC Raise SCPs FS 559738 EMS 559739 IS 619353 | 28 | Electra. Link confidential | ©Electra. Link 2018 M J J A S O N D

Control Log Closed Projects Summary of Closure Follow-up actions General Data Protection Regulations (GDPR) A closure report was provided to the closed session of the June EC summarising the work completed to ensure SPAA is compliant with GDPR. Maintenance and review through the EC Risk and Opportunities Register. MDD Review Group (Phase 1) Following a fourth impact assessment, CP 17/419 was approved at the July Change Board. Potential Phase 2 of review (scope TBC). Priority Service Register (PSR) CP 16/370 A will be implemented on 29 June 2018 Monitor subsequent issue with large domestic premises through EC Risk and Opportunities Register – UPDATE: issue now resolved in June 2019 UK Link release. Review of Metering Schedule Reporting CP 17/411 will be implemented on 02 November 2018. Wider Governance Reforms (CMA) The Code Governance team at Ofgem has been disbanded and licencing is highly unlikely in the foreseeable future. Erroneous Transfers (ETs) Following closure of ET Working Group Prepayment Schedule Consolidation Consolidated schedule released 02 November 2018 as part of standard SPAA Release. RGMA Faster Switching Review Closed at the February EC meeting. BREXIT (Ref 4. 1) SCP 461 - Brexit Consequential Amendments to SPAA implemented 28 March 2019. Joint SEG/IREG (Ref 3. 1 & 3. 2) Agreed at the April SPAA EC to be removed from Risk Register. FS 559738 EMS 559739 IS 619353 | 29 | Electra. Link confidential | ©Electra. Link 2018 Consideration being given once more to no-deal. Consideration required of impacts on MAMCo. P and AMICo. P in relation to status of EU directives.

Control Log Closed Projects Summary of Closure Follow-up actions 1. 5 New SPAA Website live with effect from Tuesday 20 August. Project replaced with 1. 5. 1 – New SPAA Website (Post Implementation) MRA Secure Communications Working Group (SCP 472) Change Proposal developed, and agreed for implementation at the September 2019 Change Board. All risks to SPAA parties have now been mitigated. Awaiting implementation – no further actions. FS 559738 EMS 559739 IS 619353 | 30 | Electra. Link confidential | ©Electra. Link 2018