Ofgem approve Elexon’s Business Separation Plan for Market-wide Half Hourly Settlement
On 19 November 2021, Ofgem approved Elexon’s Business Separation Plan for the Market-wide Half Hourly Settlement (MHHS) Programme.
Maintaining business separation
Elexon has collaborated with Ofgem to ensure the Separation Plan mitigates the potential conflict of interest risk and is aligned with the BSC and MHHS Governance Framework. The Business Separation Plan supports the required physical, organisational and cultural programme separation.
Elexon has implemented internal compliance controls to monitor compliance with the Business Separation Plan and the ongoing management of the potential conflict of interest risk.
The Independent Programme Assurance (IPA) provider will monitor and provide assurance that Elexon is complying with its obligations and will be responsible for identifying and reporting on issues relating to business separation and Elexon’s conflict of interest.
In Ofgem’s decision document, they state that the decision “provides a reasonable basis for ensuring that the service providers, personnel, IT systems and facilities that Elexon uses to perform its role as MHHS Implementation Manager are sufficiently separated from those it uses as an MHHS Participant.”
Key Elements of Elexon’s Business Separation Plan
- The Elexon Board has delegated its MHHS IM oversight responsibilities to a named Elexon Executive who has no involvement in Project Helix (Elexon’s Central Systems MHHS Programme)
- The Elexon Executive Committee is excluded from receiving MHHS IM information not shared with other Programme participants and from participating in MHHS IM decisions
- No MHHS IM information can be shared with Elexon other than the Elexon Board and the named Elexon Executive and certain named persons providing Professional Services support (such as Legal, Finance and Design Authority subject matter experts)
- Any MHHS information shared with the named Elexon Executive and the Elexon Board, and any decisions taken, will be shared with the IPA
- The majority of the MHHS IM roles are outsourced to the Lead Delivery Partner (LDP)
- The MHHS Programme has a separate office space, email, website and data directory
- A communications programme and online training tool will raise the awareness of the potential conflict of risk to all Elexon and MHHS IM resources and educate on how to manage the conflict of interest risk