# Verify

Stage Four of the Programme is verification. Here, Participants are required to maintain their membership of WSAP, and be audited by an Authorised Auditor to verify that they have implemented the actions set out in their Water Stewardship Plan. They are also required to evaluate the actions taken and their effectiveness, as well as publicly disclose their efforts.

A Third-party Audit must be conducted by an Authorised Auditor to verify compliance with the required indicators and criteria, and be approved by Water Stewardship Asia Pacific. To maintain the Verify level of verification, a Maintenance Audit must be completed by an Authorised Auditor to the satisfaction of Water Stewardship Asia Pacific once every three years from the date of the first Verify level audit. Such audits will pay special attention to any issues raised through the Annual Communication of Progress in the years between audits.

Participants must complete an Annual Communication of Progress every 12 months in any year that a Maintenance Audit is not completed.

# Step 4 - Evaluate

Participants are required to evaluate the actions taken and their effectiveness.

# 4.1 Evaluate the site's performance

# 4.1.1 Document evaluation of performance against planned targets

The organisation should list the targets for action and improvement from its water stewardship plan, and report on to what extent they are being, or have been met. It should also report on how it has contributed to achieving each of the five International Water Stewardship Standard Outcomes. The rate at which targets are achieved should be compared with timelines given in the water stewardship plan.

# 4.1.2 Document evaluation of value creation from water stewardship plan

This indicator refers to value creation for the implementing organisation. The organisation should aim to provide a financial water cost-benefit component and report on its financial investment in water stewardship and the services and benefits achieved. For example, improved water efficiency will result in some costs savings, such as on water supply fees or reduced energy costs (for pumping boreholes).

There may be a net cost to the benefit of reducing risk (and avoiding unexpected higher costs), to achieving longer term water security.

# 4.1.3 Provide information on the quantified catchment shared value benefits

Where identified, the organisation should report on the value benefit to the catchment and/or catchment stakeholders, preferably with quantified contributions. This may be a financial benefit, but it may also be a value benefit such as improved natural capital and ecosystem services or improved long term water security across the catchment and reduced risks.

Evaluating quantitatively the water-related value generated by the site to the benefit of the catchment may pose challenges in some cases and often it may be only possible to give a qualitative assessment.

Examples include:

Free provision of water or treated waste water for general water supply or irrigation
Improving water quality of a water body through improved wastewater treatment or installation of wetland treatment system;
Helping to improve an IWRA feature and providing social and natural capital benefits to nature and communities (e.g. for recreation and wellbeing).

# 4.2.1 Document evaluation of root-cause and site response, identify preventative and corrective actions

The organization should report at least annually on any significant or emergency water-related events, its response, actions and outcome. It should aim to understand the cause of events, and where appropriate, implement new actions or modify its water stewardship plan. This includes events that impact on the organization and events arising from the organization or its site that impact on others in the catchment. Such a review may be performed as part of a larger review (of all emergency incidents), so long as the water-related aspects are identified and documented as above.

Incidents can include environmentally based emergencies (which may or may not be extreme events, and may or may not be anthropogenic):

Floods – mild to severe – that may affect the flow regime and infrastructure capabilities, including storm water management
Natural disasters that have disrupted the water infrastructure (e.g. tornado, hurricane, earthquake)
Droughts that have seriously affected water availability and concentrations of contaminants in effluent
Environmental shifts in water quality (e.g. algal blooms)
Freshwater invasive species Incidents may also include accidental or other external situations:
Contaminant spills or leakages that require abatement
Structural failures of equipment
Political conflicts (e.g. war)
Human error
Vandalism/terrorism

Extreme events, including those from neighbouring catchments, that have occurred in the past 10-20 years should also be considered relevant as they may indicate potential future climate-related water risk for the site. Extreme weather events and extreme climate events are most easily noted through media stories but may also be found through academic research, which sometimes compiles such information. Public sector agencies may, in certain jurisdictions, offer resources in terms of both tracking such events and evaluating their impacts and risks. Lastly, non-governmental organizations also have tools and often generate reports that speak to the trends in a given location. All these groups should be explored to see whether extreme event information is available for evaluation.

The site should prepare a written annual review of the year’s emergency incident(s) with particular attention to the site’s response to the incident(s). Any proposed measures to mitigate against future incidents should be included in Criterion 5.4. The site must either provide the previous and updated copies of the water stewardship and incident response plans or highlight the changes made to the water stewardship and incident response plans.

# 4.3 Evaluate stakeholders’ feedback

# 4.3.1 Provide information on stakeholder consultation efforts

Stakeholders are an important source of feedback and can often provide sites with advanced warning of concerns before they manifest as more serious risks. As a result, stakeholder consultation on performance not only gives an “early warning system” if there are potential water-related conflicts emerging, but also helps build trust and relationships in the cases where conflict does arise.

Furthermore, stakeholder feedback on performance may in fact lead to insight and enhancement of operations, as well as ideas for collaboration and mutual benefits. Thus, there is a variety of potential forms of communication and feedback. This could be through physical meetings, letters, brochures, or electronic communication. The organization should report on the communications undertaken, and to which stakeholders and interest groups. As much as feasible, it should also report on feedback (considering any legal data sharing and confidentiality issues). We recognise the organization cannot insist on feedback from its stakeholders. Where feedback is difficult to gain, the organization should show an absence of serious objections and that the interests of vulnerable stakeholders are not negatively impacted.

The organization should report on its consultation efforts, the means of communication, and any feedback. The site must engage stakeholders at least once every year to review its water stewardship performance and provide written commentary from identified stakeholders on the site’s performance. This consultation is a good opportunity to confirm shared water challenges and Important Water_x0002_Related Areas in the catchment. The form of the consultation should be appropriate for the local context and the stakeholders engaged but does not need to be conducted in person. Note that this may be a rather “informal” consultation. More elaborate and formal engagements are recognized as well. This is also a chance to further gather input for the renewed water stewardship plan.

# 4.4 Evaluate and update water stewardship plan

# 4.4.1 Provide a copy of modified and adapted water stewardship plan

Continual improvement is a fundamental tenet of the Standard, and criteria 4.4 provides for the mechanism to ensure the plan is evaluated and updated periodically to ensure it is current and progressing positively. The site water stewardship plan requires that data be regularly collected, monitored and evaluated. On an annual basis, at a minimum, this data should be comprehensively reviewed and evaluated to determine whether:

The plan is delivering on the intended targets;
The data points are the right data points to be collected;
Context information has changed;
Any lessons learned/areas for improvement are noted;
Successful strategies and/or best management practices have emerged/been implemented;
Stakeholder engagement efforts have been well-received (including transparency);
Water risks have changed since the last evaluation (the last time Criterion 2.7 was evaluated);
Efforts have been effective and efficient in terms of costs/benefits (financially, socially, economically and environmentally to the site or the catchment).

This will be a combination of quantitative and qualitative analysis, and include:

Lessons learned from implementing the plan
Whether circumstances have changed or affected performance
A review of regulatory changes and enforcement
Areas of strong/weak performance
Changes in water risks and the catchment context
Whether water stewardship efforts are being effective in mitigating water risks, decreasing shared water challenges or creating value

Modifications to the water stewardship plan may be influenced by a range of reasons, of which the following are examples:

A target was achieved, so an action can be stopped or reduced in scope
A target was not achieved (or at too slow a pace), so new or modified actions may need to be implemented to improve on this.
Stakeholders objected to an action or its outcome
An action did not have the expected consequence or impact
An action caused an unexpected unwanted impact
An action proved to be disproportionately costly
There has been a change in regulation

This criterion pulls together the various evaluations conducted throughout Step 4 to update the primary plans developed in Step 2. Put another way, it ensures that the site revises its plans created in Step 2 with an evaluation (Step 4) of the data gathered in Step 1 and implemented in Step 3. This is the “check” part of a “plan, do, check, act” continuous improvement loop. As such, the site should revisit Step 1 to review the initial risk assessment performed there and evaluate changes.

# Step 5 - Communicate

Participants are required to communicate and disclose their water stewardship efforts.

# 5.1 Disclose relevant internal governance, including accountability

# 5.1.1 Document relevant internal governance, including accountability for legal and regulatory compliance

Water-related governance is ultimately focused on responsibility and accountability of water-related matters at the site. It is about having a clear line of authority in order to ensure that preventative measures are in place, as well as immediate corrective actions when things go wrong.

The governance disclosure effort needs to be publicly accessible in a suitable format for the target audience(s). The disclosure should:

Provide a summary of how water-related issues at the site are governed at the site level. This can be a general overview of the management systems in place.
Note positions accountable for compliance with water-related laws and regulations and note if this is a committee.
Indicate the hierarchy between those accountable for water and the senior-most leadership at the site level (CEO or equivalent) or the board.

In cases where sites are part of a larger organisation’s disclosure efforts, the larger corporate disclosure should indicate that site-level water-related governance is available upon request. If not, a separate site-specific report needs to be generated and made available to both verifiers and the target audience(s). The format of disclosure is at the discretion of the site but should be appropriate for interested parties (e.g. possibly a presentation to community members, website content for civil society groups, annual sustainability report for investors).

# 5.2 Communicate the stewardship plan with stakeholders

# 5.2.1 Provide evidence of communication of water stewardship plan and its contribution to AWS outcomes to relevant stakeholders

Communication should be of a level of detail, language and format most relevant to each relevant stakeholder group.

# 5.3 Disclose annual water stewardship summary

# 5.3.1 Provide copy of annual summary of performance, quantified against targets, and evidence of disclosure

This aspect of disclosure should be a summary of the results (and/or efforts) the site has achieved in addressing its water-related challenges by making references to the site’s water-related targets, as well as the site’s commitment.

The disclosure of water stewardship performance needs to be accessible in a suitable format for the target audience(s) with results that pertain to material issues for the target audience;

The site is not requested to report on all results from its water stewardship plan (as detailed in 3.2) but should include all results that are material to the concerns of the target audience(s) and are encouraged to present as many results as possible in order to highlight the association of specific results with the site water risks and opportunities (e.g. creation or restoration of water-related assets such as natural and built water infrastructure).

Sites are not requested to disclose any financial figures unless they are not bound to confidentiality and figures help demonstrate the site’s water stewardship performance in terms of financial, social, cultural or environmental shared value benefits.

Sites are encouraged to discuss any of the challenges and opportunities that arose in the context of their efforts to affect change. This helps provide an understanding of the enabling conditions and impediments to achieving the proposed targets. If not, a separate site-specific report needs to be generated and made available to both verifiers and interested parties.

The format of making the site’s performance results available is at the discretion of the site but should be appropriate for interested parties (i.e. in local languages and a format that can be understood). This could include formats such as a community notice board, the site’s website, annual sustainability report for investors, etc.

# 5.4 Disclose efforts to collectively address shared water challenges

# 5.4.1 Provide evidence of disclosure of shared water challenges and efforts to address them

Shared water challenges are identified, and should be drawn from, Criterion 1.6. The site should:

List all shared water challenges
Describe actions/efforts undertaken to address shared water challenges
Discuss stakeholder engagement efforts, with an emphasis on engagement directed toward shared water challenges
Actively disclose this information to target audience(s) and actively communicate this information to interested stakeholders in a suitable format(s).

Disclose efforts to collectively address shared water challenges, including associated efforts to address the challenges; engagement with other companies, organisations and community groups in the area; and coordination with public-sector agencies.

# 5.4.2 Provide evidence of efforts to engage stakeholders and support public agencies

In addition to formal disclosure, sites are required to communicate efforts to address shared water challenges to relevant stakeholders in a manner that is both active and accessible. This means that the site should not be passive (i.e. requiring that stakeholders come to them) but instead should undertake efforts to provide such information to interested stakeholders. See details on stakeholder engagement at the beginning of the Guidance for more details.

The format of making the shared water challenges and responses available is at the discretion of the site but should be appropriate for interested parties (i.e. in local languages and in a format that can be understood). This could include formats such as a community notice board, the site’s website, annual sustainability report for investors, etc.

# 5.5 Communicate compliance transparency

# 5.5.1 Provide evidence of disclosure of compliance violations and corrections

A summary of compliance may be provided, but any and all significant water-related violations should be made available. It is helpful to provide the context for such violations to allow others to understand why/how they occurred and how they might be prevented in the future. A site also may report in this section that it has gone “above and beyond” compliance through the completion of the Standard.

In certain contexts, actively communicating such violations could cause undue attention and therefore heighten reputational water risks. Accordingly, this criterion does not require active communication of compliance violations. However, in all cases, sites should provide the relevant information to any stakeholder requesting the information. The fact that such information is available will be made known through the site’s Water Stewards Verification Programme status.

The format of making the compliance violation available is at the discretion of the site but should be appropriate for interested parties (i.e. in local languages and in a format that can be understood). This could include formats such as a community notice board, violations noted on the site’s website, annual sustainability report for investors, and others.

# 5.5.2 Provide evidence of disclosure of actions to prevent future violations

The site needs to also disclose what corrective actions it took to address the items raised in 5.5.1 (evidence of disclosure of compliance violations and corrections).

# 5.5.3 Provide evidence of disclosure of violations that may pose significant risk to human or ecosystem health and communicate to public agencies.

“Significant” water-related violations are any that heavily (materially) affect the company’s finances, the freshwater ecosystems surrounding the site, or local people’s use and enjoyment of fresh water. For example, a large number of complaints by stakeholders would indicate a “significant” water-related violation; a large fine for a water-related compliance violation also would be significant.

In cases where there is an immediate threat to local stakeholders, including ecosystems, note that the site should notify the relevant public sector agencies of the violation immediately. Sites found delaying in such instances will not be eligible for certification.

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