The purpose of this intervention was to gain confidence in the management arrangements for the prevention and control of counterfeit and fraudulent items by NNB Generation Company (HPC) Ltd (NNB GenCo). The objectives were to determine NNB GenCo’s policy, strategy and approach to fraudulent and suspect items (CFSI) management; and how their approach was systemised and implemented.
The intervention was undertaken remotely by skype, using on-line interviews with staff responsible for aspects of the management arrangements.
The intervention related to Licence Condition 17, which requires a licensee to make and implement a management system that gives due priority to safety. ONR expects that the system should include arrangements to mitigate the risks of CFSI entering NNB GenCo’s supply chain.
NNB GenCo has both a written policy (as part of a wider supply chain management policy) and a written strategy concerning management of CFSI. In summary, the policy requires appropriate defence mechanisms to be in place, with emphasis on identification of CFSI, procedures, training and material traceability. The strategy gives more detail, committing NNB GenCo to “seven levels of defence” against CFSI risks, including sharing of information about CFSI, appropriate contract terms with its suppliers, audits of suppliers and an alert mechanism. In ONR’s judgment, the commitments in both documents, if implemented, provide satisfactory arrangements to mitigate the risks from CFSI entering NNB GenCo’s supply chain.
We found that the policy and strategy were not adequately implemented within NNB GenCo, which requires improvement. Some aspects of the seven levels of defence were in place, but others were weak or not present in line with the strategy.
At Director level, NNB GenCo has committed to actions that will implement their CFSI strategy and systemise their arrangements. An ONR Issue will be raised to track their remedial action and ONR has assigned an amber rating to this intervention.