Independent assurance statement to Reed Elsevier management

Reed Elsevier’s Corporate Responsibility Report 2008 (the Report) has been prepared by the management of Reed Elsevier Group plc who are responsible for the collection and presentation of the information within it. Our responsibility, in accordance with Reed Elsevier management’s instructions, is to carry out a limited assurance engagement on the 2008 environmental and health and safety data contained within the Report. We do not, therefore, accept or assume any responsibility for any other purpose or to any other person or organisation. Any reliance any such third party may place on the Report is entirely at its own risk.

What did we do to form our conclusions?

Our assurance engagement has been planned and performed in accordance with the International Federation of Accountants’ International Standard for Assurance Engagements Other Than Audits or Reviews of Historical Financial Information (ISAE3000). The environmental and health and safety data have been evaluated against completeness, consistency and accuracy criteria agreed with the management of Reed Elsevier as follows:

Completeness

  • Whether all material data sources have been included and that boundary definitions have been appropriately interpreted and applied.

Consistency

  • Whether the Reed Elsevier Environmental Guidance for completion of the Group Environmental Survey (updated 14 January 2009) has been applied to the environmental data.
  • Whether the Guidance for the completion of the Reed Elsevier Group Health & Safety Survey (updated 13 January 2009) has been applied to the health and safety data.

Accuracy

  • Whether site-level environmental and health and safety data has been accurately collated at Group level.
  • Whether there is supporting information for the environmental and health and safety data reported by sites to Group.

In order to form our conclusions we undertook the steps outlined below:

  1. Interviewed specialists responsible for managing, collating, and reviewing environmental and health and safety data at a Group level for internal and public reporting purposes.
  2. Reviewed a selection of management documentation and reporting tools including guidance documents and reporting databases.
  3. Undertook 11 visits to key locations to examine the systems and processes in place for collecting and reporting environmental and health and safety data against the reporting guidance prepared by Reed Elsevier Group. Eight sites were visited in the US, two sites in the UK and one in Ireland.
  4. Additional supporting documentation was sought for a sample of environmental data points for sites not visited through our work. Supporting documentation was sought and reviewed for 44 additional data points.
  5. Reviewed and challenged the environmental and health and safety data validation and collation processes at Group reporting level. This included following the sample of environmental data collected at each of the eleven sites visited through to the Group reported performance data, and reviewing the processes for Group level review and challenge of health and safety data.
  6. Reviewed the Report for the appropriate presentation of the data including the discussion of limitations and assumptions relating to the data presented.

Level of assurance

Our evidence gathering procedures have been designed to obtain a sufficient level of evidence to provide a limited level of assurance in accordance with ISAE3000.

Limitations of our review

Our scope of work was limited to the environmental data and a review of the Group consolidated health and safety data. We did not undertake a detailed review of health and safety incidents at each of the sites we visited, but reviewed the processes for reporting data to Group. We visited 11 sites and undertook tests on 44 environmental data points from 38 further sites, out of a total of 108 possible locations.

We have not sought evidence to support the statements or claims presented within the Report, other than those relating to the 2008 environmental and health and safety performance data. We have not reviewed normalised data or the trends described in relation to this data. Data relating to compensation claims and supplier emissions presented in the health and safety and environmental sections of the Report were not included within our scope.

Our conclusions

Based on our review:

  • We are not aware of any material reporting units which have been excluded from the scope of the environmental and health and safety data.
  • Nothing has come to our attention that causes us to believe that the environmental and health and safety data has not been properly collated from the information reported by sites.
  • With the exception of the limitations described in the report regarding occupational illness data, we are not aware of any errors that would materially affect the reported environmental and health and safety data.

Our observations

Our observations and areas for improvement will be raised in a report to Reed Elsevier’s management. Selected observations are provided below. These observations do not affect our conclusions on the Report set out above.

  • We observed that progress has been made in building more rigour and challenge around the reporting of health and safety data. We observed that the requirement to record accidents is well understood by the sites visited and processes have been established for monitoring and reporting health and safety incidents. However, there remains scope for improving the understanding of management in non-US sites of the Group requirements for incident classification.
  • The Group Environmental Survey process has continued to evolve since last year’s survey and at the sites we visited management were generally positive about participating in the Survey and the process improvements that had been made. The improvements to the survey process have enhanced the ability of Group to collect and review documentation supporting a site’s reported environmental performance.
  • Through the course of our work we observed some errors in the data reported by a small number of sites. Although corrected through the reporting process, these errors demonstrate the need for continued focus on data training and review.

Our independence

This is the third year Ernst & Young LLP has provided independent assurance services in relation to Reed Elsevier’s corporate responsibility reporting. With the exception of this work we have provided no other services relating to Reed Elsevier’s approach to corporate responsibility or any of the business processes relating to environmental and health and safety data collation and reporting.

Our assurance team

Our assurance team has been drawn from our global environment and sustainability network, which undertakes similar engagements to this with a number of significant UK and international businesses.

Ernst & Young LLP
London
April 2009