Response to Ofgem Code Governance Review (Phase 3)
Published On: 16th December 2015
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We welcome the opportunity to respond to the consultation on the Code Governance Review (Phase 3) – Initial Proposals (CGR3).
We understand that Ofgem’s CGR3 work is focused on incremental change and we have responded accordingly. Nonetheless, our stakeholders are struggling with a very complex change landscape with competing priorities, not least being those related to Nexus, settlement, Theft Risk Assessment Services (TRAS), Faster Switching and now centralised registration. All against a backdrop of smart metering roll out and environmental policy change.
With respect to CGR3, Gemserv is supportive of the proposed reforms, and if carried through appropriately, the incremental measures should make material improvement to code governance practices. However, some of the proposals require further clarification and detail in order to understand the specific nature of the reforms being proposed – we comment accordingly within our response where this applies.
CGR3 is inextricably linked to wider reform measures, and consequently in responding to the consultation, we highlight three key aspects:
The need for a more strategic approach to code governance;
Reforming the Code Administration Code of Practice (CACoP) as the foundation for improvements; and
It is the quality of chairmanship that is of greater importance.
We hope the solutions we have set out in our response to your questions helps inform your thinking. Gemserv looks forward to engaging with you further at the ongoing code governance workshops.
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