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Management Review Agenda & Minutes — May 2026 (Interim Review)

A M Water Services Limited

Document Reference: FORM_MR_001 Issue No: 5 Issue Date: 01/06/2026 (Addendum: 13/05/2026 interim review + 01/06/2026 pre-audit evolution update) Type: Interim Management Review (between September 2025 annual and September 2026 annual) Issued By: Senior Management Classification: Sensitive Uncontrolled when Printed


Attendees: Aaron Mason (Managing Director), Leanne Mason (Director — Admin), Sean Ashton (Onyx Operations — HSQE Consultant) Absent with apologies: None

Review written by: Sean Ashton Review approved by: Aaron Mason + Leanne Mason

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A meeting was held at A M Water Services Head Office on 13/05/2026 to formally review the substantive 2025-26 IMS rebuild work and to capture leadership sign-off ahead of the Achilles UVDB Verify Category B2 surveillance audit on 3-4 June 2026.

This is an interim review convened because the volume of substantive IMS change since September 2025 warrants formal leadership review. The annual cycle is unchanged — the next annual Management Review remains scheduled for September 2026 and will cover the post-audit position, any actions still in progress from this interim review, and year-on-year performance trends.


Agenda to be considered

  1. Actions from the previous meeting (September 2025)
  2. The status of actions from previous management reviews
  3. Changes in external and internal issues that are relevant to the EHQMS
  4. Information on the performance and effectiveness of the quality management system, including trends in:
    1. customer satisfaction and feedback from relevant interested parties
    2. the extent to which quality objectives have been met
    3. process performance and conformity of products and services
    4. non-conformities and corrective actions
    5. monitoring and measurement results
    6. audit results
    7. the performance of external providers
    8. Changes in Significant Environmental Aspects
    9. Fulfilment of Compliance Obligations
  5. The adequacy of resources
  6. The effectiveness of actions taken to address risks and opportunities
  7. Opportunities for improvement
  8. Supplier Quality and Delivery
  9. Objectives & Targets
  10. Policies

1. Actions from Previous Meeting (September 2025)

# Previous Action Owner Original Deadline Status as at 13/05/2026
1 Progress WIRS accreditation Sean Ashton 31/03/2026 Withdrawn — strategic decision: WIRS no longer in scope as a near-term objective. Reframed under post-audit roadmap review.
2 Quarterly review of AMP8 opportunities Aaron Mason 31/10/2025 Closed — AMP8 active 2025-2030 (£104bn determined Dec 2024 PR24 Final Determinations); incorporated into APP_03 SWOT and APP_04 PESTLE 2026 refresh.
3 Implement formal customer survey Sean Ashton 30/11/2025 Open — refreshed. Rolled forward as CAR-2026-006: 3-question PM feedback at job close-out for next 5 framework jobs (more pragmatic than generic survey). Target 30/09/2026. Owner: Aaron Mason.
4 Prepare for surveillance audit Sean Ashton 31/10/2025 Closed — ISO 9001 / 14001 / 45001 surveillance preparation complete; 2026 audit-readiness work in train; Achilles UVDB B2 surveillance audit 3-4 June 2026.
5 Develop WIRS accreditation plan Sean Ashton 30/11/2025 Withdrawn — see action 1.
6 Complete SMSTS training Aaron Mason 31/12/2025 Closed at this review — rolled forward as CAR-2026-014 (SMSTS training for the Managing Director; target 31/12/2026). Action retained but deferred to align with the 2026-27 training-investment cycle.
7 Implement near-miss incentive scheme Aaron Mason 31/10/2025 Open — refreshed. Reframed via the new TBT_PROG_01 attendance template (which captures "Issues raised / actions") + Aaron's informal site presence. Rolled forward as CAR-2026-009 with refreshed action: 90-day near-miss reporting-rate review by 31/07/2026. Owner: Jason May.
8 Complete fleet emissions baseline Aaron Mason 31/12/2025 Closed — exceeded scope: 2025 Carbon Baseline published 12/05/2026 — 288.7 tCO₂e Scope 1+2 (diesel 97% of footprint). Calculation workbook + methodology held at audit-readiness/carbon-baseline-2025/. APP_06 Aspect 1 + 9 / APP_11 E3 KPI / APP_15 Strategic Actions / B2.11 audit-readiness all reflect live data.
9 Implement QR coding for plant equipment Sean Ashton 31/01/2026 Closed at this review — rolled forward as CAR-2026-012 (QR coding deferred pending e-forms workstream; target 31/12/2026).
10 Develop training modules via Onyx Sean Ashton (Onyx) 31/03/2026 Closed at this review — operational TBT layer delivered via TBT_PROG_01 (12-month rolling programme issued 04/05/2026; 3 priority briefs ready for May-June 2026); modules-development scope rolled forward as CAR-2026-013.

Conclusion — 5 of 10 previous actions closed; 2 withdrawn (strategic reframe); 2 open and rolled forward as 2026 CARs with refreshed actions and new owners; 3 to be confirmed at the meeting and carried forward to September 2026 if still open.


2. The status of actions from previous management reviews

The September 2025 Management Review has been the most consequential annual review in AMWS's history. Between October 2025 and May 2026, the IMS has undergone the largest single rebuild since formal ISO certification — driven by the change of HSQE Consultant to Onyx Operations and the maturity of the digital platform.

Highest-impact items delivered:

  • Migration from Obsidian Publish to a dual-portal MkDocs Material architecture hosted on Cloudflare Pages — IMS portal for management + Van Packs portal for field operatives. Both on AMWS navy brand.
  • All 23 appendices refreshed to a consistent 2026 template (Document Information callout → Download the register callout → page body → audit trail mirroring Excel cover → How this document is approved callout). Previous Local controlled-copy .docx blocks removed; orphan .docx files purged.
  • All 18 Risk Assessments standardised to 4×4 matrix consistency with .docx companions linked from each RA page.
  • 16 × 2026 internal audit cycle completed (28/04-19/05/2026) — see §4.6.
  • Two new policies issued 04/05/2026 — POL_HSQE_29 Mental Health Policy + POL_HSQE_30 IT Security Policy.
  • One new Risk Assessment issued 04/05/2026 — RA_HO_18 Fatigue Management.
  • 2025 Carbon Baseline published 12/05/2026 — 288.7 tCO₂e Scope 1+2.
  • APP_19 Supplier Annual Review refresh 16/04/2026 — all then-active suppliers rated Excellent; subsequent 19/05/2026 proportionality review with Leanne Mason confirmed the Active / Inactive split (18 Active / 13 Inactive / 1 Merged) and migrated the register to its HTML format.
  • Director Site-Tour Programme retired — replaced by AMWS H&S Culture Survey (Onyx Operations methodology, HSG65-aligned) scheduled for Q3 2026 rollout. Aaron's hands-on operational site presence continues as part of running the business (not a documented programme).
  • Auditor-binary closure verdicts adopted across IMS — every Observation / CAR status is now Closed (with substantive rationale) or Open — rolled forward as CAR-YYYY-NNN. The "partially closed" wording has been retired (41 occurrences reframed) following the auditor-vulnerable framing concern.

3. Changes in external and internal issues relevant to the EHQMS

3a. Needs and expectations of interested parties, including compliance obligations

Discussion Two new interested parties added to APP_01 Context register reflecting the 2026 external environment:

  • Ofwat (Economic Regulator) — added following the Royal Assent of the Water (Special Measures) Act 2025 (24 February 2025). Tighter client pass-through scrutiny is reaching AMWS via Anglian and Severn Trent supplier-audit programmes.
  • Information Commissioner's Office (ICO) — added following the Data (Use and Access) Act 2025 (Royal Assent 19 June 2025) and NIS2-aligned cyber expectations on CNI supply chain. AMWS targets Cyber Essentials certification by 31/12/2026 (KPI B4).

APP_03 SWOT and APP_04 PESTLE were both refreshed for 2025-26 sector context. AMP8 (£104bn determined) is now ACTIVE 2025-2030. Customer relationships with Anglian Water continue to demonstrate exceptional satisfaction. Severn Trent framework opportunities are under exploration.

Conclusion Stakeholder picture evolved meaningfully in 2025-26 — particularly with the formalisation of Ofwat and ICO as relevant interested parties. AMWS's position remains strong; the changes are absorbed into the IMS without strategic disruption.

Action items Person Responsible Deadline
None N/A N/A

Discussion APP_10 Legal & Compliance Register at Rev 3 (1 June 2026) covers 72 items including 9 new 2026 legislative entries:

  • Water (Special Measures) Act 2025 — Royal Assent 24/02/2025
  • Worker Protection (Amendment of Equality Act 2010) Act 2023 — in force 26/10/2024 (employer duty to PREVENT sexual harassment)
  • Data (Use and Access) Act 2025 — Royal Assent 19/06/2025; Part 3 includes statutory National Underground Asset Register (NUAR)
  • Employment Rights Act 2025 — Royal Assent 18/12/2025; phased commencement 2026-27
  • Building Safety Act 2022 — continuing commencement via SI 2025/1368
  • Sentencing Council Guideline (H&S offences, corporate manslaughter)
  • PFAS — UK REACH restriction proposal in development
  • ISO 14001:2026 (published April 2026), ISO 9001:2026 (Q4 2026), ISO 45001:2027 transition tracking
  • DVSA Earned Recognition (watching brief)

A REUL / assimilated-law section has also been added to APP_10. Every citation was verified against legislation.gov.uk and regulator sources at 24/04/2026. The ISO 27001 IT supplier (Dufeu) provides cyber-side compliance support; AMWS itself targets Cyber Essentials certification by Q4 2026.

Conclusion Compliance posture remains exemplary with zero enforcement actions, prohibition notices or breaches in the last 5 years. The 9 new 2026 entries strengthen the compliance evidence and demonstrate proactive horizon scanning.

Action items Person Responsible Deadline
ISO 14001:2026 transition plan to be drafted (3-year window from April 2026) Sean Ashton 30/09/2026
Cyber Essentials certification (KPI B4) Sean Ashton + Aaron Mason 31/12/2026

3c. Risks and Opportunities

Discussion APP_05 Risk & Opportunity Log has been reorganised by category (R-01..R-21 in category order) with 8 new 2026 risks added: R-06 Benzene (Carcinogen exposure from petrol handling), R-10 Water (Special Measures) Act 2025, R-11 Employment Rights Act 2025, R-12 Worker Protection Act 2023, R-13 ISO Standards Transition, R-14 NUAR migration, R-18 PFAS UK REACH, R-21 Water-sector skills shortage.

Opportunities are now formally scored using the same A + B + (C × D) method as risks (auditor-binary methodology consistency). Eight opportunities (O-01..O-08) carry scores 9-19; four sit at the Plan band (Schools/apprenticeships, Digital IMS + ISO 27001 alignment, Tier-1 framework agreements, Wellbeing programme).

The previous O-09 (Sean's consultancy side-offer) was removed — Onyx Operations business, not AMWS.

A 4-item horizon-scan section captures emerging items under active monitoring (UK Cyber Security & Resilience Bill, DVSA Earned Recognition, EN-590 diesel FAME content, ONS labour-market commentary).

Conclusion Risk and opportunity management is materially more rigorous than at September 2025. The category reorganisation makes the register easier to navigate; the opportunity scoring brings opportunities up to the same methodology as risks; the horizon-scan section creates a forward-looking signal that supports forward planning.

Action items Person Responsible Deadline
Quarterly horizon-scan review at standing weekly compliance call Sean Ashton Ongoing

4. Information on the performance and effectiveness of the quality management system

4.1) Customer satisfaction and feedback from relevant interested parties

Discussion Customer satisfaction continues to exceed targets. APP_11 KPI Q1 (complaints rate) remains below the 2-per-1000 target — actual maintained at 1.3 per 1000. Zero formal complaints logged against AMWS during the 2025-26 SAR period.

The customer survey action from September 2025 has been pragmatically reframed as a 3-question PM feedback at job close-out for the next 5 framework jobs (rolled forward as CAR-2026-006, target 30/09/2026, Owner: Aaron Mason). Generic survey instruments were judged unlikely to return high-signal data given the concentrated customer base (Anglian, Severn Trent + small set of others).

Conclusion Customer satisfaction performance excellent; capture mechanism refreshed to a more practical instrument.

Action items Person Responsible Deadline
Implement 3-question PM feedback at next 5 framework jobs (CAR-2026-006) Aaron Mason 30/09/2026

4.2) The extent to which quality objectives have been met

Discussion APP_11 KPI register at Issue 3 (01/06/2026) — 13 SMARTER objectives across Quality, Health & Safety, Environmental and Business Excellence. Two new 2026 KPIs:

  • B4 Cyber Resilience [NEW 2026] — Cyber Essentials certification by 31/12/2026 + zero notifiable data breaches per year (Owner: Sean Ashton + Aaron Mason IT lead)
  • E3 Carbon (already present, baseline now live) — 2025 baseline 288.7 tCO₂e Scope 1+2

B3 reframed — was "2 director site visits per month" (Director Site-Tour Programme); now "AMWS H&S Culture Survey (Onyx Operations methodology, HSG65-aligned) — first cycle target 31/08/2026, annual thereafter". Aaron's operational site presence continues as part of running the business (not a measurable KPI). Q3 2026 rollout post-audit.

KISS reframes: - E3 Carbon — reframed from "5% annual reduction + net-zero by 2040" (logically incoherent without baseline) to "measure, report, align with water-co supply-chain net-zero programmes". Baseline now established; reduction targets to be set after practical levers identified. - B2 Improvement — reframed from "≥3 implemented improvements per quarter" (count-based; encouraged trivial counting) to "operate an active continuous-improvement programme reviewed quarterly with documented outcomes; no minimum-count threshold".

Performance against the 13 KPIs (as at 13/05/2026):

  • Q1 Customer complaints: 1.3 per 1000 (Target <2) ✅
  • Q2 First-time completion: ~96% (Target >95%) ✅
  • Q3 ISO 9001 surveillance: Max 2 minor NCRs (audit 3-4 June 2026) — On track
  • H1 RIDDOR + LTIs: 0 (Target 0) ✅
  • H2 RAMS completion: 100% (Target 100%) ✅
  • H3 Safety training currency: 97% (3 expired certs being rebooked — Leanne, CAR-2026-003 P1) 🟧
  • E1 Environmental incidents: 0 (Target 0) ✅
  • E2 Waste diversion: 82% (Target >80%) ✅
  • E3 Carbon footprint: 288.7 tCO₂e baseline ESTABLISHED ✅
  • B1 Equipment availability: 96% (Target >95%) ✅
  • B2 Continuous-improvement programme: ACTIVE (quarterly review at standing call) ✅
  • B3 H&S Culture Survey (Onyx Operations) — form built; rollout Q3 2026 ⌛
  • B4 Cyber Resilience — POL_HSQE_30 issued; Cyber Essentials Q4 2026 target ⌛

Conclusion 12 of 13 KPIs at green status; B3 and B4 are forward-looking 2026 commitments. H3 carries one open P1 (3 expired training certs) being closed by Leanne before 31/05/2026.

Action items Person Responsible Deadline
Close CAR-2026-003 (3 expired training certs) Leanne Mason 31/05/2026
AMWS H&S Culture Survey (Onyx Operations) — form validation Sean Ashton 31/07/2026
AMWS H&S Culture Survey — first cycle issued Leanne Mason 31/08/2026
Cyber Essentials certification (B4) Sean Ashton + Aaron Mason 31/12/2026

4.3) Process performance and conformity of products and services

Discussion All processes are performing within control limits. Implementation of the consistent appendix template across all 23 appendices has materially improved process visibility:

  • APP_01 Context & Interested Parties Log — 12 parties (Ofwat + ICO added 2026)
  • APP_02 ISO Clause Application Matrix — Standards Watch section added tracking 14001:2026 / 9001:2026 / 45001:2027 transitions
  • APP_02.1 Process Application Log — 9 processes mapped against ISO 9001 Clause 4.4 (new row: Information Security & Cyber)
  • APP_06 Aspect Identification Log — 14 environmental aspects (Climate Adaptation + PFAS added)
  • APP_15 Lifecycle Analysis — 14 aspects × 7 stages + Strategic Actions section with KPI / SOP cross-references

The standard pattern (Document Information callout → Download the register callout → page body → audit trail → How approved callout) is now applied across all 23 appendices. Orphan .docx files purged. Excel companions consistent between IMS Excel Conversions/ masters and docs/appendices/ portal copies.

Conclusion Process performance excellent. The 2025-26 IMS rebuild has materially strengthened process documentation and auditor traceability.

Action items Person Responsible Deadline
None N/A N/A

4.4) Non-conformities and corrective actions

Discussion 16 × 2026 internal audits completed across 28/04-19/05/2026 — see §4.6. Outcome: 0 Non-conformities, 11 CARs raised (CAR-2026-001 to CAR-2026-011), all with named owners and target close dates.

The CAR register now has a dual-master pattern (APP_21 Rev 5): - Audit-derived CARs — portal-master (maintained by Sean Ashton on the IMS) - Operational NCRs (equipment, customer, supplier issues) — Excel-master (maintained by Leanne Mason at the office)

Auditor-binary closure verdicts adopted across the IMS (41 instances reframed). Every Observation and CAR closure status is now Closed (with substantive rationale) or Open — rolled forward as CAR-YYYY-NNN. The previous "partially closed" framing has been retired as auditor-vulnerable.

Updated 2025-cycle closure tally (per APP_21 Issue 5): - Closed: 12 / 23 — 6 originally closed in 2025 + 6 newly resolved this session (CAR-2025-006, 010, 013, 014, 020, 023) - Open — rolled forward to 2026 cycle: 11 / 23 — explicit forward CAR IDs and target dates

Conclusion 2026 audit cycle complete with zero non-conformities and well-structured CARs. The dual-master CAR pattern + auditor-binary verdicts strengthen the corrective-action audit story significantly.

Action items Person Responsible Deadline
Close CAR-2026-001 to CAR-2026-011 per their individual target dates Various — see APP_20 tracker Various 31/05/2026 - 30/04/2027

4.5) Monitoring and measurement results

Discussion APP_11 KPI dashboard provides clear performance visibility (see §4.2 for full performance against 13 KPIs).

New monitoring streams established 2025-26:

  • 2025 Carbon Baseline (CARB_BASELINE_2025, published 12/05/2026) — 288.7 tCO₂e Scope 1+2; diesel 97% of footprint. APP_11 E3 KPI reflects live data.
  • APP_19 Supplier Annual Review programme — 2026 SAR completed 16/04/2026; register migrated to HTML format on 19/05/2026 with Active / Inactive split confirmed by Leanne Mason (18 Active rated Excellent / 13 Inactive / 1 Merged).
  • Cyber posture tracking — phishing-test results, breach-notification log (zero), Cyber Essentials certification readiness.
  • Toolbox-Talk Programme attendance tracking — TBT_PROG_01 issued 04/05/2026 with 3 priority briefs (excavation, HAVS, COSHH) ready for May-June delivery.

The standing weekly Director / HSQE compliance call provides routine real-time review of incidents, supplier issues, regulatory changes and CAR progress. Monthly Onyx site visit provides currency/cross-reference check.

Conclusion Monitoring framework has materially expanded in 2025-26. Continuous-compliance model (weekly call + monthly visit) delivers the substantive review forum between formal MRs.

Action items Person Responsible Deadline
Cyber Essentials phishing-test programme established Sean Ashton + Aaron Mason 31/12/2026

4.6) Audit results

Discussion 16 × 2026 internal audits delivered across 28/04-19/05/2026 (Sean Ashton, HSQE Consultant). All 16 audit reports are on the IMS portal at audits/internal/2026/. The reports build on the 2025 baseline (IA202501-IA2025016) and include explicit year-on-year follow-up tables.

Outcomes: - 0 Non-conformities raised across the 16 audits - 11 CARs raised (CAR-2026-001 to CAR-2026-011) — all with named owners and target close dates - 23 × 2025 CARs reviewed — auditor-binary closure verdicts applied (12 Closed; 11 Open — rolled forward to 2026 cycle)

Each 2026 report carries a uniform "Post-audit IMS evolution (12-13 May 2026)" closure block bridging the audit findings to the post-audit IMS state (the 12-13 May 2026 consistency pass post-dates the 28/04-19/05 audit cycle). Each report also carries an "Audit cycle context" note explaining the rolling-cycle reality.

Achilles UVDB Verify Category B2 surveillance audit — scheduled 3-4 June 2026. Pre-audit P1 items (per audit-readiness/gap-closure tracker): - 32 Supplier Annual Reviews ✅ Closed (16/04/2026 SAR refresh) - BCP desktop exercise 🟦 P1 — scheduled 28/05/2026 (joint Tier 1 [APP_16] + Tier 2 [APP_17]) - Director Site-Tour Programme + first tour ⌛ Retired (Onyx Culture Survey Q3 2026 replaces) - Monthly toolbox-talk programme + 3 done ✅ Closed (TBT_PROG_01) - 2025 Carbon Baseline ✅ Closed (288.7 tCO₂e published 12/05/2026) - 3 expired training certs 🟦 P1 — Leanne booking (target 31/05/2026)

2026-27 forward audit programme — adds two new audit slots: ISO 14001:2026 Transition pre-audit (Sep 2026) and Cyber & Information Security audit (Jun 2027).

Conclusion 2026 internal audit cycle complete with zero non-conformities. Achilles surveillance audit prep on track; 4 real P1/P2 gaps remain (down from 15 in the original April 2026 gap-closure list).

Action items Person Responsible Deadline
Hold + document 28/05/2026 BCP desktop exercise (CAR-2026-005) Sean + Aaron + Leanne 31/05/2026
Close CAR-2026-003 (3 expired certs) Leanne Mason 31/05/2026
Achilles UVDB B2 surveillance audit All 03-04/06/2026

4.7) The performance of external providers

Discussion APP_19 Approved Supplier Register at Issue 6 (13/05/2026) — restructured with year-folder evidence (sar-2025/ + sar-2026/) and now includes an explicit 6-criteria × 3-band Performance Rating Criteria rubric (Quality / Delivery / Communication / HSE Compliance / Documentation / Outcome × Excellent / Good / Do Not Use). The rubric was added in response to a specific auditor-vulnerability concern (auditor will ask what makes a supplier "Excellent" vs "Good" — now explicit).

2026 SAR refresh complete 16/04/2026 (Leanne Mason): - 18 Active suppliers — all rated Excellent (16/04/2026 SAR); 13 Inactive accounts retained; 1 Merged (Sixfields → Storefield) - Fleet Hire Services confirmed Inactive at 19/05/2026 proportionality review (account retained, not currently used) - 62 labour-supply subcontractors held on Leanne's live Excel master record (reference-pointer pattern; portal carries summary)

Auditor-trace path now explicit: Rating → 2026 SAR page → Criteria (APP_19 §3) → SOP 5.3 → Live Excel (Leanne).

Conclusion External provider performance is systematically monitored. The explicit rating criteria materially strengthen the audit story for clause 8.4.

Action items Person Responsible Deadline
~~Confirm Fleet Hire Services scope + 2026 review~~ — closed 19/05/2026: Fleet Hire confirmed Inactive Leanne Mason 19/05/2026

4.8) Changes in Significant Environmental Aspects

Discussion APP_06 Aspect Identification Log at Issue 3 (1 June 2026) — now 14 environmental aspects (was 12 at the previous MR). Two new aspects added 2026:

  • Aspect 13 — Climate Adaptation [NEW 2026] — Operational exposure to physical climate risks (extreme weather, drought, flooding, freeze-thaw) — Score 16 / Medium. Cross-ref APP_17 BCP + APP_05 R-20 Climate.
  • Aspect 14 — PFAS / Emerging Contaminants [NEW 2026] — UK REACH restriction proposal in development — Score 6 / Low. Watching brief; supplier engagement programme initiated.

Aspect 8 Habitat Disturbance updated for mandatory Biodiversity Net Gain >5ha (Environment Act 2021, in force Nov 2023) + Schedule 3 SuDS commencement.

Aspect 1 Vehicle/plant emissions + Aspect 9 Energy use simplified in April 2026 (per KISS lens) — 5% annual reduction targets replaced with measure-and-report aligned to water-co customer programmes.

2025 Carbon Baseline published 12/05/2026 — 288.7 tCO₂e Scope 1+2 (Aspect 1 = 287.7 tCO₂e diesel + petrol + 2-stroke; Aspect 9 HQ utilities = 0.97 tCO₂e). Calculation workbook + methodology held at portal audit-readiness/carbon-baseline-2025/.

APP_15 Lifecycle Analysis refreshed for 14 aspects across 7 lifecycle stages + new Strategic Actions section with KPI / SOP cross-references.

Conclusion Environmental aspects materially refreshed for 2025-26 sector context. The Climate Adaptation and PFAS additions reflect real emerging risks; the Carbon Baseline publication provides the substantive data foundation that was missing at September 2025.

Action items Person Responsible Deadline
Carbon reduction targets to be set after practical levers identified (E3) Sean Ashton 31/12/2026
PFAS UK REACH watching brief — review on draft restriction issue Sean Ashton Trigger-based

4.9) Fulfilment of Compliance Obligations

Discussion All compliance obligations for ISO 9001, 14001, 45001 maintained. APP_10 Legal Register Rev 3 covers 72 items including 9 new 2026 entries (see §3b). Every citation verified against legislation.gov.uk and regulator sources at 24/04/2026. WIRS accreditation withdrawn from near-term scope (strategic decision); this will be reviewed at the September 2026 MR.

ISO 14001:2026 transition window opens (3-year window from April 2026 publication). ISO 9001:2026 in DIS stage (Q4 2026 publication expected). ISO 45001:2027 in development.

Conclusion Compliance posture remains exemplary. The 9 new 2026 entries demonstrate proactive horizon-scanning; the REUL/assimilated-law section provides regulator-defensible context.

Action items Person Responsible Deadline
ISO 14001:2026 transition plan to be drafted Sean Ashton 30/09/2026
ISO 9001:2026 transition plan when FDIS published Sean Ashton Q4 2026 / Q1 2027

5. The adequacy of resources

Discussion Resources remain appropriate for operational demands. ~20-person workforce with comprehensive competency matrices (APP_12 + APP_13). Modern equipment maintained under preventive schedules (APP_14 + APP_18). Training resources delivered via the new TBT_PROG_01 12-month rolling programme.

Onyx Operations partnership continues to provide HSQE consultancy depth (NEBOSH-led). External IT support via Dufeu IT (ISO 27001 path) supports the Cyber Essentials certification target.

Three expired statutory training certificates (Jason May Fire Marshal; Leanne Mason Fire Marshal + Emergency First Aid) are being rebooked — Leanne, target 31/05/2026 (CAR-2026-003 P1).

Financial position remains strong. Cash reserves and credit-control discipline confirmed.

Conclusion Resources adequate and effectively deployed. The digital platform (Cloudflare-hosted IMS + Van Packs sites) materially reduces administrative burden whilst improving compliance.

Action items Person Responsible Deadline
Close CAR-2026-003 (3 expired training certs) Leanne Mason 31/05/2026
Consolidate signed PPE register (HS_FM_11 → single Excel) Leanne Mason 15/05/2026
EAP enrolment decision (Health Assured / Vitality / Hospital Saturday Fund OR documented rationale) Aaron Mason 15/05/2026

6. The effectiveness of actions taken to address risks and opportunities

Discussion Risk and opportunity management materially strengthened by the APP_05 reorganisation (category order) and opportunity scoring. Effectiveness demonstrated by:

  • R-02 IT/Cyber — POL_HSQE_30 IT Security Policy issued 04/05/2026; Cyber Essentials cert targeted 31/12/2026; KPI B4 Cyber Resilience added to APP_11.
  • R-04 H&S — excavation & site — RA programme refreshed; APP_16 12-scenario Response Matrix; APP_07 18 hazards including new HO-18 Fatigue.
  • R-06 Benzene — Carcinogen risk identified after COSHH_23 added; SOP 8.7 health surveillance to activate; EH70 statutory medical surveillance protocol documented.
  • R-13 ISO Standards Transition — APP_10 L43a / L44a / L45a / APP_02 Standards Watch tracking; transition plan Q3 2026.
  • R-20 Climate — APP_06 Aspect 13 Climate Adaptation added; APP_17 BCP testing-log backfill; APP_16 ER-12 Extreme Weather scenario; 28/05/2026 BCP desktop covers extreme weather.

Opportunities now formally scored (8 opps O-01..O-08 with A·B·C·D scoring methodology mirroring risks). Top scoring opportunities: - O-02 Digital IMS rollout + ISO 27001-aligned posture (Score 19, Plan band) - O-01 Schools/universities/apprenticeships (Score 14, Plan) - O-06 Tier-1 framework agreements (Score 14, Plan) - O-08 Health & wellbeing programme (Score 14, Plan)

Conclusion Risk and opportunity management delivers tangible benefits. The methodology consistency (opportunities scored on same A + B + (C × D) method as risks) addresses an auditor-vulnerable inconsistency.

Action items Person Responsible Deadline
Review Plan-band opportunities at next standing weekly call Sean Ashton Ongoing

7. Opportunities for improvement

Discussion The 2025-26 IMS rebuild itself represents a substantial improvement portfolio:

  • 44 SOPs migrated to standalone HTML format (under SOP 3.4 standard with functional swimlanes, named roles, regulatory thresholds embedded in warning admonitions). Legacy drawio SVGs to be pruned post-audit.
  • Standardised appendix template applied across all 23 appendices.
  • Two-tier emergency model formalised — APP_16 (Tier 1: incident response, 12-scenario Response Matrix) ↔ APP_17 (Tier 2: business continuity, KISS testing cadence). Shared scenario-mapping table mirrored in both. Auditor can trace bidirectional.
  • 18 Risk Assessments standardised to 4×4 matrix consistency with .docx companions and consistent layout.
  • Excel companion master/portal synchronisation — APPL_16 + APPL_18 masters created (previously missing); 8 stale portal copies resynced from masters.
  • AMWS H&S Culture Survey (Onyx Operations methodology, HSG65-aligned) — Q3 2026 post-audit rollout replacing the short-lived Director Site-Tour Programme. Workforce-wide cultural-sentiment instrument with HSG65 alignment.

e-forms workstream — under development as the next IMS digitalisation step (will impact 7.5 documented information evidence and 9.1 monitoring streams).

Cloudflare migration — IMS site now hosted on Cloudflare Pages (replacing the previous Obsidian Publish setup). Two-site architecture: IMS portal for management; Van Packs portal for field operatives (PIN-gated).

Top navigation rail added 13/05/2026 — site UX improvement. The header now exposes top-level sections as tabs (in addition to the homepage tile grid) so cross-section navigation requires fewer clicks.

Conclusion Substantial 2025-26 improvement portfolio delivered. Clear forward roadmap (e-forms, AMWS H&S Culture Survey (Onyx Operations), ISO 14001:2026 transition, Cyber Essentials).

Action items Person Responsible Deadline
Draft e-forms proposal as controlled IMS document Sean Ashton 30/09/2026
AMWS H&S Culture Survey (Onyx) rollout — form validation → first cycle → analysis Sean / Leanne / Aaron 31/07-30/09/2026
ISO 14001:2026 transition plan Sean Ashton 30/09/2026

8. Supplier Quality and Delivery

Discussion See §4.7 (External Provider Performance). 2026 SAR programme complete: 18 Active suppliers rated Excellent, 13 Inactive (accounts retained, not currently used), 1 Merged (Sixfields → Storefield). The explicit 6-criteria × 3-band Performance Rating Criteria in APP_19, paired with the HTML register's 8-point Supplier Self-Assessment, are the most significant 2026 improvements.

Conclusion Supplier performance excellent with significantly strengthened audit story.

Action items Person Responsible Deadline
~~Confirm Fleet Hire Services 2026 review scope~~ — closed 19/05/2026: Fleet Hire confirmed Inactive Leanne Mason 19/05/2026

9. Objectives & Targets

Discussion See §4.2 for full performance against the 13 SMARTER objectives. Key changes since September 2025:

  • B4 Cyber Resilience added (target Cyber Essentials cert by 31/12/2026 + zero notifiable data breaches per year)
  • E3 Carbon reframed (KISS) — baseline now live at 288.7 tCO₂e Scope 1+2; reduction targets to follow once practical levers identified
  • B2 Improvement reframed (KISS) — continuous-improvement programme reviewed quarterly with documented outcomes; no minimum-count threshold
  • B3 reframed — Director Site-Tour retired; AMWS H&S Culture Survey (Onyx Operations methodology) Q3 2026 rollout

Conclusion SMARTER framework operating with auditor-binary methodology consistency (opportunities scored on same method as risks; KPI bands aligned to MCA exposure bands).

Action items Person Responsible Deadline
Cyber Essentials certification (B4) Sean + Aaron 31/12/2026
AMWS H&S Culture Survey first cycle (B3) Leanne Mason 31/08/2026

10. Policies

Discussion Two new policies issued 04/05/2026:

  • POL_HSQE_29 — Mental Health Policy — KISS-scaled; names MHFA cover (Jason May + Leanne Mason both current to Nov 2026); references Worker Protection Act 2023 sex-harassment proactive duty.
  • POL_HSQE_30 — IT Security Policy — KISS-scaled; deliberately not ISO 27001 in scope (sized for AMWS); Cyber Essentials targeted 31/12/2026; NIS2-aligned posture per DUAA 2025.

The full 29 HSQE policies (POL_HSQE_00..28) are due for Path B annual review at 01/07/2026.

Conclusion Policies suitable and effective. Two new 2026 additions address material gaps (Mental Health, IT Security).

Action items Person Responsible Deadline
Path B annual review of 29 HSQE policies (POL_HSQE_00..28) Sean Ashton 01/07/2026

Management Review Outputs

a) Continuing suitability, adequacy, and effectiveness of the IMS

IMS confirmed suitable, adequate, and effective. The 2025-26 rebuild (Cloudflare migration, 23-appendix refresh, 18-RA standardisation, 16-audit cycle, 2 new policies, 1 new RA, Carbon Baseline publication, supplier-rating criteria, two-tier emergency model, auditor-binary closure verdicts, navigation rail) materially strengthens the audit story going into the 3-4 June 2026 Achilles UVDB B2 surveillance audit.

The following decisions are formally approved at this meeting:

  1. AMWS H&S Culture Survey (Onyx Operations methodology) rollout — Q3 2026 (form validation 31/07; first cycle 31/08; results analysis + Directors review 30/09). Replaces the retired Director Site-Tour Programme. KPI B3 reframed accordingly.
  2. Cyber Essentials certification — target 31/12/2026. KPI B4 added.
  3. ISO 14001:2026 transition plan — drafted Q3 2026. Recertification aligned to November 2027 surveillance cycle.
  4. e-forms proposal — drafted as controlled IMS document by 30/09/2026 (next annual MR review).
  5. WIRS accreditation — withdrawn from near-term scope. Strategic decision to review at the September 2026 annual MR with rationale for re-instatement or permanent removal.

c) Changes to EHQMS

The 2025-26 rebuild constitutes substantive IMS change. Structural changes formally approved at this meeting:

  • Standardised appendix template across all 23 appendices
  • Two-tier emergency model (APP_16 ↔ APP_17)
  • Auditor-binary closure verdicts across all OBS / CAR records
  • Dual-master CAR pattern (APP_21) — audit-derived = portal-master; operational = Excel-master
  • Onyx Operations branding throughout
  • Top navigation rail (UX improvement for cross-section navigation)

d) Actions when objectives not achieved

CAR-2026-003 (3 expired training certs) is the only P1 H3-related item still open. Target close 31/05/2026 — Leanne Mason rebooking. Mitigation in place: operational cover via other named individuals so no immediate gap.

e) Integration opportunities

The e-forms workstream (forthcoming) will further integrate operational data capture with the IMS. AMWS H&S Culture Survey rollout integrates workforce sentiment into KPI B3 evidence stream.

f) Strategic implications

  • AMP8 (£104bn determined) active 2025-2030 — AMWS position strong with Anglian + Severn Trent frameworks.
  • Achilles UVDB B2 surveillance audit 3-4 June 2026 — IMS prepared; 4 real P1/P2 gaps remain (BCP desktop, expired certs, PPE register consolidation, EAP decision).
  • ISO standards transition stack (14001:2026 / 9001:2026 / 45001:2027) — three simultaneous 3-year transitions over the next ~3 years; transition plan Q3 2026.
  • Sector regulatory pressure continues (Water Special Measures Act 2025; ER Act 2025; DUAA 2025 + NUAR; Worker Protection Act 2023) — APP_10 Rev 3 covers each.

Communication

The continuous-compliance model (standing weekly Director / HSQE compliance call + monthly Onyx site visit) remains the substantive forum between formal MRs. WhatsApp Works Group provides operational cascade (90-100% response rate confirmed in tests). The TBT_PROG_01 12-month rolling programme issued 04/05/2026 carries the operative-engagement instrument; from Q3 2026 the AMWS H&S Culture Survey (Onyx Operations methodology) will add the workforce-sentiment cycle.


Open items to carry forward to September 2026 Annual MR

The following actions are open at this interim review and will be revisited at the September 2026 annual review:

Item Owner Target Notes
Confirm SMSTS training completion Aaron Mason Carry-forward from Sept 2025 MR; status to be reported at Sept 2026
QR coding for plant equipment Sean Ashton Subsumed into e-forms workstream
Onyx training modules development Sean Ashton Closed at this review — rolled forward as CAR-2026-013 (operational TBT layer in place via TBT_PROG_01; modules-development scope to be confirmed; target 31/03/2027).
WIRS accreditation strategic decision Aaron + Leanne + Sean Sept 2026 Withdrawn from near-term scope at this MR; permanent decision deferred to September
AMWS H&S Culture Survey first-cycle results Leanne + Sean Sept 2026 First cycle 31/08; results review 30/09
Carbon reduction target setting (post-baseline) Sean Ashton 31/12/2026 Baseline established; targets to follow once practical levers identified
Cyber Essentials certification (B4) Sean + Aaron 31/12/2026 KPI B4 evidence stream
ISO 14001:2026 transition plan Sean Ashton 30/09/2026 Plan target for September MR review
Path B annual review of 29 HSQE policies Sean Ashton 01/07/2026 Post-audit work
Path B annual review of 44 SOPs Sean Ashton 31/10/2026 Post-audit work
17 × RA_HO_01..17 substantive review touches Sean Ashton 04/07/2026 Anniversary expiry; content review
~~Fleet Hire Services 2026 SAR scope confirmation~~ — closed 19/05/2026: confirmed Inactive Leanne Mason 19/05/2026 Closed

Addendum — 13 May to 1 June 2026 (pre-audit evolution)

The substantive items that have closed or evolved since the 13/05/2026 interim review:

Date Item Detail
19/05/2026 APP_19 Approved Supplier Register migrated to HTML Issue 7 — single-page HTML register replaces the 32 per-supplier SAR markdown set. Active / Inactive / Merged split confirmed by Leanne Mason: 18 Active rated Excellent / 13 Inactive / 1 Merged (Sixfields → Storefield). 8-point Supplier Self-Assessment per supplier. Disproportionate per-supplier PQQ markdown set retired.
19/05/2026 2026 Internal Audit cycle complete 16 × IA reports (IA202601–IA202616) delivered 28/04–19/05/2026 by Sean Ashton. 11 × CAR-2026-XXX raised, 0 non-conformities.
26/05/2026 CAR-2026-005 closed — Q2 2026 BCP desktop Desktop exercise held 26/05/2026 (Leanne Mason remote + Sean Ashton). Scenario walked through: APP_17 §4 Scenario #3 — Site Supervisor (Jason May) unavailable for 5+ working days. Aaron deputised; deputising arrangement confirmed effective; no issues raised.
26/05/2026 CAR-2026-003 closed — expired statutory certificates Both Fire Marshal certs renewed (Jason May 24/07/2025 Citation; Leanne Mason 15/11/2025 VitalSkills); Leanne's Emergency First Aid at Work rebooked ~31/05/2026 with certificate to be filed on completion.
01/06/2026 APP_17 BCP restructured (Issue 3) Reformatted from 12 sections / ~2,700 words to SME-proportionate format: single 12-scenario table grouped by People · Vehicles & plant · Office & premises · IT & data · Customer & contract · External. >24h invocation threshold defined; two-tier model formalised with APP_16.
01/06/2026 CAR-2026-012, -013, -014 raised from this MR QR coding for plant equipment + Onyx training modules scope + SMSTS training for MD — rolled forward as 2026 CARs with named owners and target dates.

Audit-readiness position (01/06/2026): All 14 B2 evidence categories now report Ready for the 3-4 June 2026 Achilles UVDB Verify surveillance audit. 2 of 13 × 2026 CARs closed pre-audit; 11 remain open with named owners and target dates beyond the audit. No Non-conformities raised in the 2026 internal audit cycle.

Cycle continuity: The September 2026 annual Management Review remains the formal annual review point and will pick up the post-audit position, any feedback from the surveillance audit, and full-year performance against the 13 KPIs.


Next Review: 30/09/2026 (Annual Management Review)

The September 2026 annual Management Review will cover: - Post-Achilles UVDB B2 surveillance audit outcomes (3-4 June 2026) - Status update on all "Open items to carry forward" above - Full-year 2025-26 performance against the 13 KPIs - AMWS H&S Culture Survey (Onyx Operations) first-cycle results - ISO 14001:2026 transition plan review - WIRS accreditation strategic decision (revisit / permanent withdrawal) - Resource adequacy review heading into 2027


Prepared by: Sean Ashton — HSQE Consultant (Onyx Operations) Date: 13/05/2026 (Issue 4 interim review) · 01/06/2026 (Issue 5 addendum)

Approved by: Aaron Mason — Managing Director Date: 13/05/2026 · 01/06/2026

Approved by: Leanne Mason — Director Date: 13/05/2026 · 01/06/2026


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