Verification Statement – Man’s 2011 Sustainability Report

To the management of Man

We have been asked to review the data underlying Man’s 2011 Sustainability Report (the Report) - downloadable as a pdf from the Sustainability website - in accordance with the scope of work agreed with Man’s management, and described below.

The scope of our work

This is the fifth year in which The Virtuous Circle (TVC) has verified the data within the Sustainability Report (also accessible via the dashboard on the website).

For the 2011 Sustainability Report, our approach entailed five phases, which started in late March 2011. These phases were to review and verify items to:

• Phase 1 – Ensure the data held on Man’s Credit 360 software system is complete.
• Phase 2 – Substantiate evidence of the data – including items such as utility and third party invoices, internal reports, and data externally audited as part of the company’s annual report and accounts.
• Phase 3 – Ensure the emissions factors linked to the energy data used in the environmental section, have been correctly applied with accurate calculations.
• Phase 4 – Ensure the normalising of absolute data is both accurate and relevant.
• Phase 5 - Ensure the data and the trends presented in the dashboard on the website are communicated in a relevant and accurate manner.

As a result of these five phases, we were able to complete this external verification statement for discussion with relevant Man management and subsequent publication.

Our approach to this work

In our approach, we have focused on data provided by Man’s management, and have not sought other data that may be materially relevant to Man’s stakeholders. However, from having assured the report in prior years, our view is that, for this year, the data coverage meets stakeholders’ needs in its Materiality, Completeness and Responsiveness, in line with Accountability’s AA1000 Assurance Standard’s key principles.

The approach we adopted was designed to ensure that we would:

• Focus on the accuracy and reliability of the data
• Ensure any conversion factors used were those most up to date
• Review any calculations used related to this data
• Offer opinions on strengths and weaknesses of the data provided
• Detail any concerns or recommendations that will enable the quality of data reporting to be improved in subsequent years’ reporting

We are conscious that some areas, such as Man’s supply chain and health and safety have not been covered in terms of the data provided for the content of this year’s report. Man’s management does not consider these areas to be material given the nature of its operation. Whilst we accept this may be a valid viewpoint, based on prior years’ reporting, we have recommended that the CR website should acknowledge, and provide an explanation for, the omission of commentary on these areas.

As part of this approach, we undertook the following actions:

Environmental verification (using the company’s Credit 360 CR database which covers all Man’s operations worldwide) including greenhouse gas emissions, we:

• Verified raw data, using the invoices as substantiation.
• Assessed the environmental data collated and assured ourselves that it was complete, or if not, that account was taken of it in an appropriate pro rata method.
• Confirmed that the greenhouse gas conversion factors used (based on Defra’s October 2010 guidance) were accurately and consistently applied.
• Reviewed the calculations used, both for conversion factors and whenever the data was reported upon in a pro rata basis for the report
• Assured ourselves that these calculations were applied correctly and consistently.

Other Sustainability data (again using the company’s Credit 360 CR database and as well as data analysis provided by individual departments (e.g. compliance data and supporting documentation from third parties), we:

• Reviewed the records held, using other documentation as substantiation.
• Assessed the range of data that has been collated (including that from the PeopleSoft Human Resources system), assessed its completeness and assured ourselves it was reported in an accurate and consistent manner.

Normalised data, we:

• Reviewed, where absolute levels of data were taken and normalised, the basis for the normalisation, and assured ourselves it was acceptable as a means of communicating performance.
• Reviewed the data used as the basis for normalisation, and assured ourselves of its completeness and its accuracy

Commentary in the dashboard of the website:

• Reviewed, where appropriate, the language and terminology used in commentaries provided in association with data and charts derived from data that were communicated via the dashboard to assure ourselves that the commentaries were reasonable and accurate.

In all the areas described above, we have viewed evidence ourselves, rather than rely on third parties, to be satisfied the data included in the report is reasonable and accurate.

The limitations of our activity

The data in the report is collated via the company’s Credit 360 software systems and is derived from submissions from Man’s global operations, covering sources such as:

• Its audited financial accounts and Annual Report
• Its PeopleSoft Human Resources system
• Central recording processes (as audited for financial accounts and Annual Report)
• The Charitable Trust’s records of donations to charities and other bodies
• Third party suppliers (such as travel agencies)

Where possible, we reviewed original source documents and we were able to establish a high level of confidence in the accuracy of the information used in the report, given the Credit 360 database stores both summary data and evidence documents such as invoices.

Where there was data provided by third party suppliers, such as air travel, we have only assessed the completeness of data presented in tables by reviewing the data presented to the central team from third parties via the individual operations. As such we have not been able to review the original data sources.

Man’s management has prepared and is responsible for the collection and presentation of information within the Sustainability Report. Our responsibility in performing our work is only to Man’s management in accordance with the scope of work agreed with them, and not to any other person or organisation.

Our conclusions

Our conclusions on quality of data included within the Report, based on our approach described above, are as follows:

• The data included in Man’s 2011 Sustainability Report reflects a fair and balanced representation of the progress that the company has made in the period 1st April 2010 to 31st March 2011.
• The data presented in tables and charts within the Report has been correctly transferred from the relevant company level data records.
• Where external data has been used, such as emissions factors, these have been correctly and consistently applied.

Other observations based on undertaking this work

There are several observations we would wish to make, which would ensure continued improvements in reporting, as has been the case for the past four years. These take account of the fact that Man’s Sustainability Reporting is now to be published in line with the publication of the company’s Annual Report and Accounts, and for the next cycle of Sustainability Reporting (December 31st 2011), we suggest there is a need to:

• ensure that the data used in normalising should, wherever possible, be in line with the data published in the Annual Report and Accounts. As an example, the Annual Report published average employee numbers, whereas, for the past five years, the Sustainability Report has used year end actual numbers of employees. This change would give a more balanced view of the sustainability performance, especially given that recent years have seen some redundancies towards the year end;
• consider in which CR areas the company wishes to set CR performance targets, and subsequently publish them;
• consider an updated stakeholder engagement survey, especially taking into account Man’s substantial acquisition of GLG, to ensure that the data included in the Sustainability Report continues to be considered to be material to all Man’s key stakeholders;
• consider incorporating GLG data (especially environmental data) for the nine months January – September 2010 (when it was independent of Man) so that like for like comparisons can be made more easily, rather than just including GLG data for the period October – December 2010, when GLG had become part of Man.

Our conclusions on the 2011 data, as presented above, are not affected by these observations.

Our independence

This is the fifth year that The Virtuous Circle Ltd has provided independent verification of the data included in Man’s Sustainability Reporting. In addition to this work we have provided advice and support to Man in its submission for Dow Jones Sustainability Index. We have not been involved in developing the Man Sustainability strategy or the preparation of any of the material in the Sustainability Report

Our team has been drawn from our team of Managing Consultants, who work on a range of CR related commissions with a number of significant UK and international businesses.

Tony Hoskins, Melissa Kittermaster

July 2011

The Virtuous Circle, established in 2000, is a specialist management consultancy operating in CR (including risk management), corporate reporting and reputation. It has a team comprising Managing Consultants supported by Associate Consultants and Strategic Partners. It works for leading corporations on an international basis.