Guidance

Supply Chain Plan guidance for projects of 300MW or more applying for a Contract for Difference

Updated 1 July 2022

Originally issued in July 2021 and updated in July 2022.

1. Purpose of this Guidance Document

1.1. In order to qualify for a Contract for Difference (CfD) Allocation Round, CfD applicants for a generating station with generation capacity of 300 MW or more will be required to provide National Grid ESO (as Delivery Body) with a statement by the Secretary of State for Business, Energy and Industrial Strategy approving the Supply Chain Plan submitted in respect of that station.^{[footnote 1]} Responses by the Applicant to the scored sections of the Supply Chain Plan questionnaire will be assessed to determine award of this Supply Chain Plan statement of approval, and hence eligibility to participate in the CfD scheme.

1.2. From the Fourth CfD Allocation Round, successful Applicants^{[footnote 2]} will also need to receive a further statement from the Secretary of State confirming they have successfully passed their Supply Chain Plan Implementation assessment (a ‘Supply Chain Implementation Statement’), confirming delivery of, or progress against, the activities and outcomes committed to in the scored sections of the Supply Chain Plan, in order to be able to fulfil one of their CfD Operational Condition Precedents (OCP).

1. 1.3. This Supply Chain Plan guidance provides detail for Applicants and Generators^{[footnote 3]} regarding:
   
   
   1. a. the process and timetable for Supply Chain Plan application submissions, monitoring and implementation assessment;
   2. b. Supply Chain Plan scoring;
   3. c. Supply Chain Plan publishing.
      
      
2. 1.4. This Supply Chain Plan guidance document has been prepared in relation to the Fourth CfD Allocation Round. Details of the Allocation Round, which is planned to open in December 2021, will be made available in due course.

1.5. Dates in this guidance document relating to the Fourth CfD Allocation Round are indicative only and subject to change. If any dates do change, this document will be updated.

1.6. This guidance provides Applicants with assistance in considering how they might wish to complete their applications, and guidance on the Supply Chain Plan process. Each application will be considered on its merits in accordance with the proper exercise of the Secretary of State’s discretion, as further described below.

Objectives of the Supply Chain Plan Process

1.7. The aim of the Supply Chain Plan process is to encourage competitive, productive and efficient supply chains for low carbon electricity generation projects, and to accelerate investments in a broad range of established and less established low carbon technologies.

1.8. The delivery of effective, open and competitive domestic and international supply chains will assist in bearing down on the costs of low carbon electricity generation in the UK, ensuring that unnecessary costs are not passed on to consumers, while encouraging investment in low carbon electricity generation to meet our net zero targets by 2050, and helping to ‘level up’ our economy and regions.

1.9. Low carbon electricity generation projects should not only contribute to decarbonising our economy once operational, but throughout their lifetimes, including during project development, construction, operations and eventually decommissioning. Many projects can benefit from locally based supply chains offering a low carbon footprint, and global supply chains can benefit from UK suppliers exporting competitive, low-carbon goods and services.

1.10. Competitive and adaptable supply chains should also give opportunities to new entrants and smaller businesses to contribute to the market and disrupt existing practices and methods, to:

• ensure costs stay competitive,
• to drive innovation, and to boost local economies while heading towards Net Zero;
• maximise investment in skills and new job opportunities; and
• invest in R&D to continue to find new and more efficient ways to reach our Net Zero objectives, and to stay internationally competitive

1.11. Supply Chain Plans should also align with the objectives of the relevant Sector Deals for a particular industry.

1.12. To support delivering these objectives, Supply Chain Plans will align with the objectives of the government strategy ‘Build Back Better: our Plan for Growth^{[footnote 4]}’:

• Green Growth: Net Zero and levelling up – ensure the push to Net Zero creates new economic opportunities for a range of actors, helps establish new low carbon industries, and decarbonises supply chains whilst levelling up our economy by creating new centres of industrial excellence.
• Innovation – nurturing and commercialising innovative technologies to create more efficient equipment, improved installation methods and new types of procurement and contracting strategies. This will then reduce the costs of projects and overcome the technical challenges of renewable electricity generation and contribute to reaching our Net Zero objectives.
• Infrastructure – removing barriers and increasing investment to help reach Net Zero and to provide the tools necessary to level up our economy, by encouraging sustainable investment in infrastructure.
• Skills – developing a diverse, skilled workforce and increasing employment opportunities by supporting the training and transitioning of the workforce to attain the skills needed for low carbon electricity generation, while ensuring the renewable energy industry reflects society as a whole, and operates ethically and safely.

1.13. Generating stations with a generating capacity of 300 MW or more are currently subject to Supply Chain Plan requirements because the government considers that this policy should capture projects large enough to materially influence their supply chains and make a material contribution to the government’s Supply Chain Plan objectives in the low carbon electricity generation market.

1.14. An overview of the Supply Chain Plan process can be found under Annex C.

2. Supply Chain Plans: Process and Timetable

Introduction

2.1. To qualify for the Fourth CfD Allocation Round, the Secretary of State will need to approve the Supply Chain Plan submitted for a generating station of 300 MW or more. The contents of a Supply Chain Plan will not have an impact on the Allocation Round criteria themselves, including the value of the strike price.

2.2. The government is committed to working with industry during the process of developing Supply Chain Plans. Accordingly, staff across BEIS and the Department for International Trade (DIT) will be willing to provide advice to developers and respond to queries prior to their submission of their Supply Chain Plans, and BEIS may share relevant questions with other parts of government (including DIT) and the devolved administrations for this purpose. However, it is important to note that plans cannot be endorsed and no assurances that a plan will pass the assessment process can be made outside of the formal assessment process.

2.3. Applicants can contact BEIS at [email protected] with any questions.

Application Process

2.4. During the calendar week before the opening of the Supply Chain Plan Application Window, prospective Applicants should email BEIS at [email protected] indicating their intention to submit a Supply Chain Plan for assessment. An area will be set up within a secure online document management platform for each Applicant. A link to the secure area, with instructions on how to submit a Supply Chain Plan electronically, will be provided.

2.5. Supply Chain Plans will not be assessed until after the Application Window closes. In cases where Applicants submit more than one version of any Supply Chain Plan, only the latest submission will be considered.

2.6. Applicants will receive an email to confirm receipt of their submission within 3 days of the closing of the Supply Chain Plan Application Window. If Applicants do not receive an email confirmation, or if they encounter any problems submitting documents, they should contact [email protected] at the earliest opportunity.

2.7. If Applicants are required to resubmit any Supply Chain Plans, or if additional information is requested, BEIS will also ask for this to be done on the online document management platform.

Assessment Timetable

2.8. BEIS will publish information on the dates of the Supply Chain Plan Application Window in respect of the Fourth CfD Allocation Round in due course. The Application Window will be open for one week, after which it will be closed except for resubmissions linked to rejected applications.

2.9. BEIS will not begin the substantive assessment of those Supply Chain Plans until the Supply Chain Plan Application Window has closed. However, if during the Supply Chain Plan Application Window it becomes apparent to BEIS that a submission contains material omissions (for example if it is evident that significant sections or annexes are missing), BEIS will endeavour to notify the Applicant as soon as is reasonably practicable (see paragraph 2.13 of this guidance).

2.10. BEIS will accept further information supplied in response to such a notice during the Supply Chain Application Window and by no later than 3 working days^{[footnote 5]} after the Applicant has been notified (information will still be accepted even if the Window has subsequently closed).

2.11. Subject to paragraph 2.15 of this guidance, the Department will endeavour to notify Applicants as to whether or not their Supply Chain Plan has been approved within 30 working days of the Supply Chain Plan Application Window closing date.

Information Requests during the Assessment Process

2.12. BEIS will begin the process of assessing submitted Supply Chain Plans in accordance with the assessment approach, set out in Section 3 of this guidance, from the closure of the Supply Chain Plan Application Window.

1. 2.13. BEIS may seek clarification from an Applicant in respect of their Supply Chain Plan (a Clarification Request) during this assessment period. This could, for example, include a request for:
   
   
   1. a. any potentially missing sections or annexes;
   2. b. clarifications or technical questions regarding the information submitted; or
   3. c. clarifications in respect of existing data where the Supply Chain Plan appears to include unsubstantiated claims.
      
      
2. 2.14. Applicants will need to provide in the Application contact details of one or more individuals who will act as the Applicant’s Authorised Representative(s) and preferred contact persons. Clarification Requests will be raised by BEIS with the Authorised Representative(s) and preferred contact persons and the Applicant should respond as soon as possible and by no later than 3 working days after the request.

2.15. Failure to respond to a Clarification Request adequately and in a timely fashion may result in BEIS being unable to process the application within the timescales described in paragraph 2.10 of this guidance.

Queries from Applicants

2.16. Queries regarding the process and response requirements may be submitted during the preparation phase of a Supply Chain Plan. Queries should be submitted in writing to [email protected].

2.17. BEIS will endeavour to respond to queries regarding Supply Chain Plans within 3 working days of receipt, but no guarantees can be made in this regard.

2.18. In the period leading up to the Supply Chain Plan Application Window and during the assessment process, individual queries and their responses may be published in a ‘question and answer’ circular which will be made available online. This is to ensure all potential Applicants have access to the same information. The identity of the Applicant making the query will not be included in the circular. BEIS reserves the right to amend the text of the query for publication, for example to ensure clarity or to remove any information that may reveal the identity of the Applicant making the query.

2.19. Applicants should state if they wish a query to be treated as confidential and include the reasons why they believe that the query should be so treated. If BEIS, in its sole discretion, determines that a question should not be treated as confidential, the Applicant will be given an opportunity to withdraw the query, otherwise BEIS may distribute the query and response to some (if technology specific) or all other Applicants.

2.20. Responses to queries which BEIS decides should be treated as confidential will be sent to the originating Applicant only.

Evaluation Results and Exchange of Letters

2.21. Applicants who submit a Supply Chain Plan that passes the assessment process will receive a written Statement of Approval, which can be submitted by the Applicant to the Delivery Body when they are applying to participate in the Fourth CfD Allocation Round. BEIS will also provide feedback on the successful application.

2.22. A Statement of Approval will usually be valid for a period of 12 months from the date of the notice. However, the Secretary of State may extend the time-period for which the approval is valid if they determine there is a compelling reason for the extension. For example, if an Applicant successfully challenges a Supply Chain Plan evaluation decision but misses the preferred year’s CfD allocation round, the Secretary of State could determine that the statement has effect for long enough to allow the project to enter into the next CfD allocation round without resubmitting their Supply Chain Plan, providing actions were still valid.

2.23. In the event that a Supply Chain Plan is rejected, BEIS will notify the Applicant of that rejection and will provide a written explanation of the reasons for the rejection and the further steps which may be available to the Applicant (a Statement of Rejection).

2.24. BEIS will consider revised Supply Chain Plans submitted in response to a Statement of Rejection. However, it is important to note that while BEIS will endeavour to notify Applicants as to whether or not their revised Supply Chain Plan has passed the assessment process before the Fourth CfD Allocation Round Application Window opens, no guarantee is made that BEIS will be able to do so. BEIS will notify applicants if a revised application could not be considered in time. Applicants are strongly encouraged to submit revised Supply Chain Plans at the earliest opportunity following receipt of a Statement of Rejection.

2.25. For the avoidance of doubt, BEIS will not accept any new Supply Chain Plan applications other than revised applications submitted in response to a Statement of Rejection from the closing of the Supply Chain Plan Application Window.

2.26. If an Applicant has not had a response of any kind (an acceptance or rejection) from BEIS after 30 working days following the closure of the Supply Chain Plan Application Window, they should contact the assessment team by emailing [email protected].

2.27. BEIS will notify the Delivery Body of each approved or rejected Supply Chain Plan.

3. Submitting a Supply Chain Plan

Introduction

3.1. This section provides a description of the practical process to be followed by Applicants when submitting a Supply Chain Plan for approval, and the approach that the government will adopt for the assessment of Supply Chain Plans.

3.2. Applicants should complete a Supply Chain Plan application. Any additional material provided to substantiate response statements should be presented as annexes to the main document.

Supply Chain Plan Application

3.3. The Supply Chain Plan application will comprise a questionnaire that must be completed by all Applicants with projects of 300 MW or more. The application is divided into 6 sections. The first 2 sections, ‘Project Summary’ and ‘Summary of Supply Chain Plan Outcomes’, are for Applicants to provide background information on the project and are therefore not scored. They nonetheless provide context on the project’s overall approach to supply chains. The remaining 4 sections contain questions that are aligned with the contents of the government’s central strategy, ‘Build Back Better: our plan for growth’.

Response Structure

3.4. Supporting evidence should be in annexes. All supporting evidence in the annexes must be directly relevant to specific parts of the response and Applicants are encouraged to minimise the quantity of supporting material presented by including relevant extracts or sections of papers where appropriate, to support the efficient processing of plans.

3.5. Applicants should also note that information presented in annexes must be clearly referenced within the body of the response, where the relevance of this material should also be highlighted. Material not referenced in this way will not be considered during the assessment process.

1. 3.6. To assist BEIS in determining what it may have to legally disclose under the Freedom of Information Act and the Environmental Information Regulations, Applicants should clearly state any aspects of their responses which are commercially sensitive, indicating if this would still be true at:
   
   
   1. a. the point of CfD contract signing;
   2. b. the Milestone Delivery Date (MDD); and
   3. c. the CfD Start Date (for phased projects, of each phase).
      
      
2. 3.7. All financial information should be denominated in pounds sterling. If it is anticipated that a significant proportion of project expenditure will be transacted in another currency (for instance for the purchase of capital equipment) then details of these costs in the local currency should also be provided together with the exchange rate assumptions used to convert values to pounds sterling.

3.8. Any activity proposed by an Applicant should only be listed as an activity in response to one question. If an activity covers multiple aspects of the questionnaire, the applicant should clearly state with evidence how it contributes to each specific part of the Supply Chain Plan it is linked to. Activities that are duplicated without an explanation of how they contribute to each specific aspects of the Supply Chain Plan they are linked to will not be scored.

Scoring at application stage

3.9. Supply Chain Plans will be assessed on the merits of the application, taking into account the particulars of the relevant renewable technology, such as the development stage of the technology and its supply chain.

3.10. Supply Chain Plans will be scored on the commitments the Applicant makes that support the objectives of the Supply Chain Plan policy (as outlined in section 1 of this guidance).

3.11. The Supply Chain Plan Application has specific questions for the Applicant to answer, related to 4 criteria as flagged in paragraph 1.12. For questions that are scored, each question has been allocated a mark which is shown next to the question.

3.12. Marks will be awarded based on the quality of information provided, specifically: the level of ambition; feasibility; and the provision quantifiable outcome/measurable metrics contained in the responses and supporting evidence, including how delivery will be ensured (e.g., through contractual commitments, details of your company’s internal measurement/monitoring processes (including reporting) and obligations). BEIS recognises that not all questions can provide a commitment or measurable outcome, and scoring will reflect this where appropriate.

3.13. Note that at application stage, if an applicant proposes 2 options under a question because they have not yet decided which one they will pursue, they will be awarded a mark that is an average of the score of both options. Applicants will be notified in their feedback if that average includes an option that failed to receive a ‘pass’ mark, which will signal that such an option would also very likely fail the implementation assessment stage.

3.14. Applicants should include activities that are ongoing or will be undertaken and be specific about the timelines of their commitments. Where asked, Applicants should provide supporting information in an annex. Applicants may reference previous relevant work, but this should be used to support commitments made or projected outcomes.

3.15. Applicants should make use of the sections that require a supporting narrative –how an applicant explains and evidences their headline ambitions will be central to the scoring of commitments.

3.16. Applicants scoring less than 50% (as a percentage of marks available) in one or more sections of their Supply Chain Plan are unlikely to pass, and therefore unlikely to be issued with a statement by the Secretary of State approving their Supply Chain Plan.

3.17. This marking approach will enable the Secretary of State to make an assessment of whether the Supply Chain Plan sets out sufficient evidence of the projects’ contribution to the objectives set out in Section 1 and in the Supply Chain Plan questionnaire.

3.18. The scoring criteria can be found in Annex D.

4. Supply Chain Plan Monitoring and Assessment

Introduction

1. 4.1. If an Applicant receives a Supply Chain Plan statement, they will be referred hereafter referred to as ‘the Generator’ (as shorthand for Generator Party Applicant).
   
   
2. 4.2. Monitoring and Assessment comes in several stages:
   
   
   1. 4.2.1. After a Supply Chain Plan application is submitted and passed, and a project is awarded a CfD, BEIS will begin the monitoring process. The purpose is to gather information on the implementation of Supply Chain Plans, to identify any issues that may impede a Generator’s ability to meet their commitments, to draw up amendments to the Supply Chain Plan as necessary, and to issue a progress report that can give Generators confidence as to where they stand ahead of the Supply Chain Implementation Statement assessment after MDD.
      
   2. 4.2.2. After a Generator has passed their MDD, they can submit an application for a Supply Chain Implementation Statement (note that an application may be submitted shortly before MDD but it will not be assessed until after MDD). BEIS will then assess whether an Implementation Statement should be issued by assessing a Generator’s progress against their Supply Chain Plan commitments (including amendments). The Secretary of State will issue a Supply Chain Implementation Statement to projects that have met their commitments or are on track to do so. BEIS recognises that some commitments may not have started to be implemented at this stage, and this will be taken into consideration.
      
   3. 4.2.3. BEIS cannot issue an Implementation Statement before a project’s MDD, as it requires certainty that the project is viable and proceeding before it can assess the implementation of a Supply Chain Plan. A project’s viability is best evidenced by the requirements of its MDD.
      
   4. 4.2.4. Once a Supply Chain Plan Implementation Statement has been obtained by the Generator, project monitoring by BEIS will resume to keep track of the implementation of outstanding commitments until project completion. This will help BEIS establish whether all outstanding commitments have been met.
      
   5. 4.2.5. After project completion, BEIS will ask for a Supply Chain Plan Post-Build Implementation Report (Annex F) from the Generator. Projects that are found to not have fulfilled their outstanding commitments after MDD may be barred from applying to future CfD allocation rounds.

Principles of monitoring and assessment

1. 4.3. During the monitoring and assessment phases, BEIS will be looking for evidence that Generators have either:
   
   
   1. 4.3.1. met their commitments;
   2. 4.3.2. are on track to meet their commitments;
   3. 4.3.3. or can evidence substantial and sustained efforts to meet their commitments.
      
      
2. 4.4. If it becomes clear during the monitoring process that a commitment cannot be met, the Generator will propose an alternative and commensurate commitment (or commitments) that it shall agree with BEIS before adding them to its Supply Chain Plan.

4.5. BEIS recognises that it is sometimes not feasible to make alternative and commensurate commitments, or that events outside a Generator’s control and influence prevent a commitment from being met. In such scenarios, BEIS will not penalise off-track or missed commitments where there is evidence to show that the Generator made sustained and substantial efforts to reach a successful outcome, but despite those efforts, a commitment could not be fulfilled. In such circumstances, BEIS will recognise the effort even if the commitment could not be met.

4.6. Commitments that are not met because of a lack of substantial and sustained effort by the Generator will receive zero/low marks in the assessment for that commitment.

4.7. Substantial and sustained effort will mean that a developer has evidence to show that it tried to solve emerging problems through a range of solutions and considered every reasonable alternative approach, and that it notified BEIS as early as possible of emerging issues.

4.8. The monitoring process will be used to track progress and identify emerging problems with the default position being to solve issues or find alternative commitments, rather than penalising Generators.

4.9. At assessment stage, the Secretary of State may refuse to issue a Supply Chain Implementation Statement if there is evidence that a Generator has failed or is on track to fail in any scored section of the Supply Chain Plan, and the Generator cannot produce evidence in those instances that it made a sustained and substantial effort to rectify those issues. Commitments that were unfulfilled but nonetheless the subject of substantial and sustained efforts from the Generator will not be classed as failed, or on track to fail. Commitments that will only be realistically completed after MDD will be assessed at Implementation Statement stage on the basis of whether they are on track at the time of assessment, or if they are off-track, whether they are the subject of agreed rectification measures by the Generator.

4.10. The scoring methodology at assessment stage will mirror the methodology in the original Supply Chain Plan questionnaire assessment but has been adapted to measure outcomes (see Appendix A). Generators will continue to be scored on their original (and amended) ambitions, to ensure a level playing field between plans that meet a majority of their commitments but had a lower level of ambition and plans that had very high ambitions but were able to meet fewer commitments.

Frequency of monitoring

4.11. BEIS will hold a monitoring meeting with the Generator on Supply Chain Plan implementation, if the project is awarded a CfD, every 2 months until assessment of a Supply Chain Implementation Statement application. The frequency of monitoring is to ensure that all emerging issues are identified and addressed before Supply Chain Implementation Statement application.

4.12. Once, and if, a Supply Chain Implementation Certificate has been issued, monitoring will resume at a lower frequency. A meeting between BEIS and the generator will be held at least every 6 months until project completion, with the option to have more meetings at the request of either party if issues arise.

4.13. Each monitoring meeting is expected to last around 2 hours.

The monitoring process up to Supply Chain Implementation Statement application

4.14. The monitoring meetings will be based on the Generator’s Supply Chain Plan (as amended). Each commitment will be examined in turn, and evidence of progress or difficulties will be required for each meeting. The Generator should provide a colour-coded RAG rating summarising progress against each of their commitments, using the ratings outlined below under paragraph 4.16. The Generator may make use of the template in Annex E for this purpose.

4.15. All supporting documents from the Generator must be submitted no later than one week before the scheduled meeting. Failure to submit supporting documents one week before will result in the meeting being delayed until BEIS has had a chance to review all documents.

1. 4.16. No later than 2 weeks after each meeting, BEIS will issue its own RAG rating, under the format of a colour-coded table based on the list of the Generator’s commitments which will summarise the department’s assessment of progress against these. The template of this table can be found in Annex E. The Generator will have the opportunity to comment on the table to ensure it reflects what was discussed in the monitoring meeting. The categories used will be:
   
   
   1. 4.16.1. On track or fulfilled (green)
   2. 4.16.2. Off-track but still deliverable (amber)
   3. 4.16.3. Commitment not met or unlikely to be met (red)
      
      
2. 4.17. The Generator should provide notice as soon as reasonably practicable to BEIS of any potential issues arising relating to the delivery of their Supply Chain Plan commitments, be that activities to be undertaken and/ or outcomes to be achieved.

4.18. Where commitments are off-track, cannot be met or are unlikely to be met, both parties will be able to suggest corrective actions, or alternative commensurate commitments which if agreed by both BEIS and the Generator, can then be recorded in the amended Supply Chain Plan.

4.19. Commensurate means achieving the same outcome as previously committed to by other means, or different outcomes whose total impact will be at least as valuable to the Supply Chain as the original commitment.

4.20. At the mid-way point before the expected MDD (at the nearest month to the mid-point), after the regular monitoring meeting, BEIS will issue a ‘progress report’ no later than 2 weeks after the meeting, based on the evidence presented during monitoring meetings. The report will be in the form of a formal letter, using the updated table in Annex E as the basis for its contents. This progress report can be used by Generators to evidence their progress on Supply Chain Plans to their stakeholders. The progress report will not be a guarantee of obtaining a Supply Chain Implementation Statement but will present a snapshot of Supply Chain Plan delivery at the mid-point before assessment.

4.21. Following receipt of the report and at least 2 months before implementation assessment, the Generator will update their Supply Chain Plan accordingly, including any agreed amendments.

Assessment and Supply Chain Implementation Statement

4.22. Once a Generator has passed their MDD, they can apply for a Supply Chain Implementation Statement from the Secretary of State. A successful application for a Supply Chain Implementation Statement will satisfy the Supply Chain Plan Operational Condition Precedent (OCP).

4.23. As part of their application for a Supply Chain Plan Implementation Statement, a Generator must submit their Supply Chain Plan as amended and supporting evidence to show how they have fared against each commitment. While it is up to the Generator to choose a format to present their evidence against each commitment, Generators can use the template in Annex E. Guidance on how to use evidence can be found in Annex B.

4.24. Generators will receive an email to confirm receipt of the submission of these documents within 3 working days. If a Generator does not receive an email confirmation, or if they encounter any problems submitting documents, they should contact BEIS at the earliest opportunity.

4.25. BEIS will then assess the evidence against the commitments in the Supply Chain Plan and rescore the Supply Chain Plan similarly to the CfD application stage, including level of stated ambition, to determine the extent to which the Generator has implemented or is on track to implement the commitments made. If a Generator over-delivers on a commitment it is possible to receive a higher mark than originally awarded.

4.26. We would expect all generators to have in place unconditional contract agreements for the key components set out in Table PS1. In the event of variation from the answers set out below, we would expect to see the rationale for said changes and evidence of new commitments that derive a similar impact to the commitments made throughout your Supply Chain Plan.

4.27. Generators that score less than 50% (as a percentage of marks available) in one or more sections of their Supply Chain Plan are unlikely to pass and to be issued with a Supply Chain Plan Implementation statement by the Secretary of State.

4.28. BEIS will undertake to assess the submitted documentation within 30 working days of receipt and the Secretary of State will then issue or reject a Supply Chain Plan Implementation Statement based on the evidence received. If BEIS has not responded to the Generator within 60 days of receiving the Generator’s Supply Chain Implementation Statement application, then the application is deemed to have been approved. If an application for a Supply Chain Implementation Statement is missing information, BEIS will endeavour to notify the applicant within 3 working days.

4.29. If the Supply Chain Implementation Statement is issued, BEIS will submit a copy to the Generator and the Generator will pass this to Low Carbon Contracts Company (LCCC), as CfD Counterparty. The provision of a Supply Chain Implementation Statement to the LCCC is an Operational Condition Precedent within the CfD Contract.

4.30. If the Supply Chain Implementation Statement is not issued by BEIS, Generators will receive a letter within the 30 working days of receipt of the application for an Implementation Statement, stating the reasons for rejection and Generators may re-submit a revised application for a Statement for assessment until the CfD Longstop Date if they have rectified the outstanding issues. The Generator should notify the LCCC if a Supply Chain Implementation Statement is rejected.

4.31. Generators must obtain a Supply Chain Implementation Statement, which the Generator will transmit to the LCCC, in order for the relevant OCP to be fulfilled and to be able to receive CfD payments. OCPs are existing milestones within the CfD contract; all CfD Generators must fulfil their OCPs before CfD payments can commence. If the Generator does not fulfil an OCP by the end of the CfD Target Commissioning Window, then their 15-year CfD payment term will be reduced until the OCP is fulfilled. If the OCP is not fulfilled by the CfD Longstop Date, LCCC will have the right to terminate the CfD contract (as is the case with other OCPs).

4.32. Generators that do not achieve at least 50% (as a percentage of total marks) in each section of their Supply Chain Plan commitments at implementation stage are unlikely to fulfil their OCP, which may lead to contract termination. Termination of a CfD contract is recognised to be a significant consequence and is a last resort. This is consistent however, with the use of Supply Chain Plan statements as an eligibility requirement for the CfD. Commitments are made on which eligibility for a CfD is assessed, and the government considers that these commitments should be delivered upon, with consequences for non-delivery.

Evidence Required

Green Growth

4.33. In this section, BEIS is looking for evidence that a project has strengthened supply chains, irrespective of their location, and that it has expanded capability and capacity, and improved visibility and access to opportunities to a wider range of businesses on a non-discriminatory basis. In addition, supply chains should have embedded sustainable business practices, in particular aiming for a low carbon footprint. This is not looking for Generators to commit to procure any percentage of content in the UK. Generators can choose their suppliers regardless of the origin or location of the supplier. We have set out below more detail on how each question in this section is scored. You will need to score 50% of the total marks across the whole section to be likely to achieve a Supply Chain Implementation Statement.

4.34. When it comes to applying for a Supply Chain Implementation Statement, BEIS expects Generators to provide more detail in their application than would normally be the case for a regular Supply Chain Plan monitoring meeting, alongside the required supporting evidence. BEIS will assess the Supply Chain Implementation Statement application against what was committed to in the Project’s approved Supply Chain Plan, and whether they have been delivered - and if not, an explanation on why commitments could not be implemented. BEIS will also assess any alternative commitments that were agreed during the monitoring process to replace commitments made at the application stage.

4.35. BEIS recognises that not all commitments will have started or finished by the time an application for a Supply Chain Implementation Statement is submitted. For commitments not started, those commitments will be awarded the same score they received at the application stage. Commitments that have started and are on track, will also receive the same score as at the application stage. Commitments that are not on track may score a lower mark depending on the reason and whether reasonable effort has been made to resolve an issue. If little or no effort is made to rectify an issue, BEIS could consider failing a commitment. Any commitments that have over delivered can score higher than at the application stage.

4.36. For Question 1.1, it is important to note that it is not the anticipated level of UK content under Question 1.1(i) that is scored. Any data provided on anticipated levels of UK content in response to Question 1.1(i) is for information purposes only and will not be scored. Accordingly, in the event that Generators indicate no or a low percentage of UK content, this will not affect the score received for Question 1.1, including the response to Question 1.1(ii). What is scored is the information provided in Q1.1(ii), which is the explanations and evidence provided for your procurement choices. When carrying out the implementation assessment BEIS is looking for evidence that, when narrowing down your choices, you have carefully studied and understood the options available in the supplier market, as well as the extent to which the suppliers chosen, whether in the UK or other countries, contribute to increasing the capacity, capability and efficiency of supply chains. If changes are made to the original procurement strategy, we are looking to ensure that they are explained and continue to contribute to the objectives of the supply chain policy, for instance, supplier capacity, capability, space in order books, ability to meet required technical specifications etc. Where completed you should summarise the outcome of your procurement decisions or in cases where procurement is not complete the next steps in the process.

4.37. The scoring of Question 1.1(ii) will be irrespective of the origin of the supplier and irrespective of any anticipated levels of UK content. The envisaged percentage of UK content provided is not relevant to how the delivery of your procurement strategy commitments are monitored and assessed. In particular, the anticipated level of UK content you may have provided in response to Question 1.1(i) is not seen as a commitment by you and so will not be assessed as the project is monitored and implemented.

4.38. You will not be penalised for choosing non-UK suppliers if you had originally envisaged using UK suppliers in your Supply Chain Plan application, and vice-versa, and you do not have to provide any reasons related to the origin of suppliers to justify your choice of a UK supplier over a non-UK supplier, and vice versa.

4.39. The Supply Chain Plan monitoring meetings can clarify the exact supporting evidence required to suit the individual requirements of each project. However, it is likely we will request to see confirmation of signed procurement contracts, evidence that you have met a range of suppliers, evidence that you were clear with the market about your required technical specifications in a timely way, and evidence that you looked for innovative solutions. It is important to underline again however, as you were not required to commit to any level of UK content, that you are not required to meet the percentage of UK content indicated at the application stage to be awarded an Implementation Statement, and that any change in the anticipated level of UK content will not impact the scores given.

4.40. On Question 1.2 which is about reducing your carbon footprint we are looking for concrete actions taken to reducing emissions in the manufacturing, transport, services or alternatively where you have made use of green finance. It would strengthen the answer if you include a description of how you collect and monitor data on your carbon footprint and therefore how you are able to track the outcomes. If you have targets for emission reductions please include these.

4.41. On Questions 1.3, 1.4 and 1.6 you will need to provide evidence of the activities you have undertaken to identify gaps in capabilities and improve visibility of opportunities, especially for new entrants. This could include evidence of training or guidance provided to suppliers; evidence of work with supply chain growth partnerships such as OWGP; evidence of how you have facilitated suppliers to access technical and financial advice; evidence of different contracting methods; evidence of meet the buyer events; and evidence of establishing or developing supplier portals. It is important to evidence outcomes from these initiatives as well as any lessons learnt. For Question 1.5 this should allow you to evidence how your contracting process was open and fair from Expression of Interest stage through to Invitation to Tender. A big part of this will be evidence of providing feedback to unsuccessful bidders so lessons can be learnt for the future.

Infrastructure

4.42. Infrastructure is the backbone of our future growth, prosperity and sustainability. Investment in the infrastructure of low carbon electricity generation, transmission and distribution is needed to boost productivity in our renewable power sector and deliver on our Net Zero commitment.

4.43. Infrastructure may include, but is not limited to, fabrication and assembly halls; port storage, laydown areas, quaysides, dry docks and navigation channels; onshore and offshore docking and refuelling stations for autonomous vehicles; and manufacturing plants.

4.44. Throughout this section applicants need to show how you are undertaking individual or collective efforts to invest in supply chain infrastructure. This could involve co-ordinating the design and construction of infrastructure across projects to enable joint planning applications and shared protocols and codes of conduct. We want to see you involving suppliers in the early stages of creating design specifications, organising site visits to advise on project requirements and forming design specifications and contracting strategies that take account of relevant infrastructure and manufacturing capabilities.

4.45. For Questions 2.1 and 2.2 you might provide evidence of feasibility studies that have been carried out; design specifications and contracting strategies that take account of local infrastructure and manufacturing capabilities; and evidence that you have adopted new technologies to overcome local capacity constraints.

4.46. We are keen to see, where possible, coordination with other developers to facilitate shared infrastructure within supplier clusters; and incentivising consortia building and partnering between UK suppliers, as well as between UK suppliers and international suppliers as may be applicable.

4.47. For Questions 2.3 and 2.4 evidence could include Community Benefit agreements, memorandum of agreements with local partnerships or letters of intent demonstrating the outcome of discussions with local bodies and good faith intentions.

Innovation

4.48. Innovation drives growth, creates jobs and helps make our technology cleaner. Developing and deploying new ideas, products and processes is central to our ambition of being the world’s most innovative economy.

4.49. In Question 3.1 and Question 3.2 we are looking to see whether you and your large suppliers are assigning sufficient resources to R&D and supporting the whole supply chain, with specific consideration for SMEs, in the development of innovative and next-generation technology and techniques. We want to see how you are introducing impactful innovation and novel technology, by increasing prevalence of automation, smart grids and electrification of the wider economy.

4.50. For Question 3.3 we want to see how you are investing in public or private R&D facilities and buildings, for example laboratories and testing centres or how you are funding research projects and the commercialisation of innovation. This might involve the secondment of employees to research institutions, and sponsorship of PhDs and post-doctorate positions. It might involve collaboration with the network of Catapults to facilitate research and carry out technology test and demonstration activities and crucially sharing data to benefit the whole industry.

4.51. Finally, for Question 3.4 we want to see innovation in your business practices and methods. Here you can evidence different types of business models, financing arrangements, procurement and contracting strategies, digital analytics, and health and safety advancements. It is important to evidence the difference they have made and the lessons learnt.

Skills

4.52. A skilled workforce will be crucial to delivering our green growth ambitions. As the renewable energy sector expands, opportunities will emerge for the sector to contribute to the provision of new skills and quality jobs in a diverse way.

4.53. For Questions 4.1 and 4.2 and 4.4 we want to see comprehensive skills strategies that identifies the skills requirements across the project, support transitioning of the UK workforce from non-renewable sectors to the low carbon electricity generation sector and promotes diversity and inclusion. We are keen to see evidence of your open and fair recruitment practices. We are looking for evidence of collaboration across the industry to resolve shortages in the long term.

4.54. For Question 4.3 we want to see how you are delivering training to employees to attain the skills they need and providing long term jobs with opportunities for advancement and upskilling. It is about creating apprenticeships and other opportunities, conducting outreach to schools and other education centres, and investing in training facilities.

4.55. For Questions 4.5, 4.6 and 4.7 we want you to demonstrate a commitment and to ensure that no modern slavery or labour exploitation is used in your project or any part of your supply chain; that you are ensuring there are fair rates of pay and fair working hours in the supply chain and that you are taking steps to mitigate operational and safety risks such as construction activities. We would like to see evidence of concrete actions and plans to ensure that incidents that arise are dealt with effectively. It is important to focus on measurable outcomes with clear targets for improvement.

Scoring at implementation assessment stage

4.56. When a Generator applies for a Supply Chain Plan Implementation Statement, they will be assessed by BEIS using the same scoring system which was used when they first submitted their Supply Chain Plans. It will, however, be appropriately adapted to measure outcomes. This means that scoring will be based on the Supply Chain Plan’s initially stated ambitions (as amended), and quantifiable outcome/measurable metrics showing completion or progress towards the commitment, and the quality of the evidence provided.

4.57. The scoring criteria can be found in Annex D.

Monitoring after award of Supply Chain Implementation Statement

4.58. If and when a Supply Chain Implementation Statement has been awarded, monitoring meetings between BEIS and the Generator will resume on a 6 monthly basis (or more if desired by either party).

4.59. The monitoring process will work in the same way to the pre-MDD monitoring meetings, with the same requests for evidence against the outstanding commitments.

4.60. Once a project has been completed, Generators will be asked to submit a Supply Chain Plan Post-Build Report. Refer to Annex F for a suggested template. The Supply Chain Plan Post-Build Implementation Report should summarise which commitments have been met, and which have not, with appropriate evidence. Failure to meet the majority of the outstanding commitments (as a percentage of marks available per section) may result in the Generator being barred from subsequent allocation rounds.

5. Publishing Supply Chain Plans

5.1. To share information with the supply chain and to support implementation, BEIS may publish an approved Supply Chain Plan (which is approved prior to the CfD round) within 3 months after the date on which the developer of the relevant project has signed the CfD contract, with due consideration to commercial sensitivities.

5.2. BEIS may publish its decision on Supply Chain Implementation Statement applications within 3 months of approval, with due consideration to commercial sensitivities.

5.3. Applicants/Generators should clearly mark information that is commercially sensitive in their Supply Chain Plans and subsequent amendments and supporting documents.

5.4. As a general rule, BEIS will take the following approach to publishing documents from Generators.

What does not get published:

• Anything related to project ownership structures or that is manifestly commercially sensitive
• Any detailed breakdown of component tables and UK content calculations (but headline UK content figures will get published)
• Company names within a developer’s supply chain
• The specifics of any new technologies being invested in

What may get published if no substantive reasons not to have been provided by the Generator:

• Size of project and key locations, key delivery dates
• By default, all of the answers to the scored sections of the Supply Chain Plan questionnaire appropriately redacted for commercial sensitivities as identified in the previous column. A Generator may make a request for further specific redactions for justifiable commercial sensitivity reasons, which BEIS will consider.

5.5. It is the Applicant’s/Generator’s responsibility to ensure that all documents provided for publishing on the GOV.UK website are securely locked to prevent redacted text being uncovered.

5.6. To assist BEIS in complying with the Public Sector Bodies Accessibility Regulations, every document on GOV.UK must be accessible. All documents for publishing should be provided in a form suitable for users of assistive technology. Guidance on how to make your documents accessible can be found at: https://accessibility.campaign.gov.uk/

5.7. BEIS has a duty to comply with the Freedom of Information Act 2000 and the Environmental Information Regulations 2004 (which both set out legal requirements for the government to disclose held information, within specified limits). It will be important for the government to understand the nature of any harm which disclosure of potentially commercially sensitive information might result in when considering whether it is required to disclose a Supply Chain Plan, Updated Supply Chain Plan, Supply Chain Implementation Report and reported information in response to such a request.

5.8. BEIS may also share unredacted Supply Chain Plans and associated documents with other parts of government, including the devolved administrations, for the purpose of developing a joined-up approach to the development of supply chains in the low carbon electricity generation sector.

Annex A: Indicative Timetable and Process for the Fourth CfD Allocation Round

A1. The indicative timetable for the Fourth CfD Allocation Round is as follows:

• July – August 2021: BEIS workshops on Supply Chain Plans to answer any outstanding queries on the questionnaire
• September 2021: Supply Chain Plan application window to open (likely first week of September). The window will open for a week. BEIS will then assess and issue results once the window is closed.
• September – December 2021: failed Supply Chain Plans can be resubmitted, BEIS will endeavour to assess before CfD auction begins.
• December 2021: CfD Allocation Round 4 opens to applications

Annex B: Evidence accepted during monitoring and assessment

B1. During the monitoring and assessment process, BEIS will require evidence of progress or of efforts made against each commitment in a Generator’s Supply Chain Plan.

B2. If BEIS publishes evidence provide by an applicant or Generator, it will check with the Generator what it considers to be commercially sensitive and redact the appropriate passages.

B3. This evidence may take a range of forms, but should conform to the following principles:

• A wide range of evidence will be acceptable in general, so long as its authenticity or source can be easily verified.
• Where a Generator uses a table provided under the Supply Chain Plan questionnaire (e.g. on contracting plans or UK content), the developer generator should also provide – where possible and applicable - any supporting documents to confirm the content of those tables (e.g. contracts).
• Where contracts are provided as evidence, BEIS would only need to see the first headline pages. BEIS however reserves the right to ask for more information during the monitoring and assessment process.
• Where figures and data are provided, they should be accompanied by their source and/or relevant methodology.
• Where correspondence is provided between the Generator and relevant supply chain partners or other institutions, they may be redacted to protect personal information.

B3. BEIS may seek to confirm various aspects of evidence presented with the Low Carbon Contracts Company.

Annex C: Flowchart of Supply Chain Plan Process

Flowchart of Supply Chain Plan Process: Accessible version

1. Supply Chain Plan Submission pre-CfD allocation round (30 days max).

• If Pass, go to step 2
• If Fail, re-submission (until auction begins).

2. If project is successful in CfD auction, ongoing monitoring of SCP by BEIS (Every 2 months). Go to Step 3.

3. Progress report issued at 8-10 months, amendments made to SCP if agreed by BEIS. Go to Step 4.

4. Ongoing monitoring by BEIS (Every 2 months). Go to Step 5.

5. Application for a Supply Chain Plan Implementation Statement shortly after MDD.

• If Pass, go to step 7.
• If Fail, go to step 6.

6\ Opportunity to resubmit revised SCP Implementation Statement Application up until Longstop Date.

• If Pass, go to step 7.
• If Fail, CfD termination right or return to Step 6.

7. SCP OCP fulfilled. Go to Step 8.

8. Ongoing monitoring by BEIS (Every 6 months). Go to Step 9.

9. Submission of Post Build Report.

Annex D: Scoring guidance at application and assessment stage

Scoring Criteria at application stage* (For scored sections of the questionnaire only)		Scoring Criteria at implementation assessment stage (For scored sections of the questionnaire only)
Marks will be awarded for the comprehensiveness of response, scale of ambition in activities and anticipated outcomes, feasibility, whether you identify quantifiable outcomes with measurable metrics, and how delivery will be assured (e.g. through contractual commitments, details of your company’s internal measurement/monitoring processes and obligations, including reporting). A high weighting is placed on the scale of ambition.	-	Marks will be awarded for the comprehensiveness of response, scale of ambition of agreed commitments and delivered outcomes, whether you have identified quantifiable outcomes with measurable metrics, and/or how you are assuring delivery (e.g. through contractual commitments, details of your company’s internal measurement/monitoring processes and obligations, including reporting). A high weighting is placed on the scale of your initial ambition.	-
Fully comprehensive responses to all parts of question with activities and/or processes delivering in aggregate a high material contribution to international and UK supply chains to support the low carbon electricity sector, supported by detailed evidence of feasibility, assurance of delivery, and measurable outcomes.	4	Fully comprehensive reporting against the agreed commitment, with activities and/or processes delivering in aggregate a high material contribution to international and UK supply chains to support the low carbon electricity sector, supported by detailed evidence of delivery or ongoing efforts to deliver, and measurable outcomes.	4
Responses to all parts of question with activities and/or processes delivering in aggregate a high material contribution to international and UK supply chains to support the low carbon electricity sector, supported by evidence of feasibility, assurance of delivery, and measurable outcomes.	3	Good or fully comprehensive reporting against the agreed commitment with activities and/or processes delivering in aggregate a moderate or high material contribution to international and UK supply chains to support the low carbon electricity sector, supported by evidence of delivery or ongoing efforts to deliver, and measurable outcomes.	3
Partial responses to the question with activities and/or processes delivering in aggregate a moderate contribution to international and UK supply chains to support the low carbon electricity sector, supported by evidence of feasibility, assurance of delivery, and measurable outcomes.	2	Partial reporting against the agreed commitment with activities and/or processes delivering in aggregate a moderate contribution to international and UK supply chains to support the low carbon electricity sector, supported by evidence of delivery or ongoing efforts to deliver, and measurable outcomes.	2
Incomplete responses to question with activities and/or processes delivering in aggregate a low contribution to international and UK supply chains to support the low carbon electricity sector.	1	Incomplete reporting against the agreed commitment with activities and/or processes delivering in aggregate a low or moderate contribution to international and UK supply chains to support the low carbon electricity sector, supported by limited evidence of delivery or ongoing efforts to deliver, and measurable outcomes.	1
No or minimal information and supporting evidence provided and/or required tables not completed	0	No or minimal information and supporting evidence provided and/or required tables not completed, and/or no evidence of delivery nor of efforts to deliver the agreed commitment.	0

*Note that at application stage only, question 4.3 and 4.4 (i) will be scored as follows: 100% of marks will be attributed to the application that proposes and evidences the highest number of positions or direct jobs per MW, and all other applications will be scored against this benchmark with the lowest proposal getting 50% of marks. Not providing any information on this question will award no marks. Note that for 4.4(i) the score is based on total number of jobs (UK and RoW combined), with no distinction between the two in the marking. For 4.4 (ii), scoring will be based on the same methodology as the rest of the questionnaire. Question 4.4 will be split equally in terms of marks between parts (i) and (ii).

Annex E: template table for monitoring meetings and progress report

E.1 Note that RAG ratings and information and entries are examples only.

E.2 Generators may use this table to set out their progress at each monitoring meeting.

E.3 BEIS will use this table as the basis to draft the progress report.

Progress to date and RAG ratings are examples of the type of information that could feature.

Reference	Marks available	Detail of commitment	Progress to date	RAG
Project summary
S1	0	Project size and location
S2	0	Ownership structure
S3	0	Project Milestones
S4	0	Core components
S5	0	Written summary
Green growth	500			Overall
1.1	175	UK Content rationale		G
1.2	75	Low carbon footprint in supply chains	Original level of ambition? KPIs met? Evidence provided?	A
1.3	50	Supply chain development		G
1.4	75	Visibility of opportunities to suppliers		G
1.5	25	Contracting strategy and procurement process		R
1.6	100	Promote new entrants and SMEs		G
Infrastructure	500			Overall
2.1	125	Coordinate supply chain activity		G
2.2	225	Supply chain infrastructure		A
2.3	100	Alignment with local economic strategies		A
2.4	50	Community engagement		G
Innovation	500
3.1	135	Developer investment in R&D
3.2	135	Supply chain partners investment in R&D
3.3	135	Innovation and novel technologies
3.4	95	Innovative business processes and methods
Skills	500
4.1	50	Market information on skills
4.2	50	Project recruitment and hiring strategy
4.3	125	Apprenticeship, trainee and scholarship
4.4	175	Number of jobs: UK and RoW
4.5	50	Workforce equality of opportunity
4.6	25	Health and safety standards
4.7	25	No modern slavery or labour exploitation
Overall assessment of progress to date

Annex F: Suggested structure of a Post-Build Report

F.1 The report should be limited to 10 pages (not including annexes) and be able to demonstrate:

• The project’s contribution to the competitiveness and capacity of the supply chain
• What the main commitments were in the approved Supply Chain Plan, and a summary of whether they were met.
• Actions undertaken to meet these commitments.
• A narrative which sets out how these actions contributed to the 4 scored criteria individually and overall.
• The reasons for any deviation from the approved plan, or for any commitments that could not be met
• What amendments (if any) were made to the plan, the reason for the amendment, and what was their outcome

Suggested structure

Executive Summary

An overview of the Project and its milestones and deliverables.

An overview of how the key/overarching commitments made in the SCP have been met or not, and how they have delivered the aims and objectives of the Supply Chain Plan Policy.

Main Section

A detailed account on how the SCP was implemented by category (Green Growth, Infrastructure, Innovation, Skills), its successes and areas where they were unable to meet the commitments made. Details as to how each section has had an impact on the capacity and competitiveness of the supply chain.

Green growth

• KPIs against your most impactful commitments.
• Reasons for not meeting any commitment.
• How the fulfilled commitments have helped strengthen Net Zero industries and meeting the Net Zero target.

Infrastructure

• KPIs against your most impactful commitments.
• Reasons for not meeting any commitment.
• How the fulfilled commitments have materially improved the infrastructure supporting Supply Chains, while being respectful of the local area and communities

Innovation

• KPIs against your most impactful commitments.
• Reasons for not meeting any commitment.
• How the fulfilled commitments have helped improve the competitiveness of the supply chain by using new or improved technologies, and how they contribute to reaching Net Zero faster or more efficiently.

Skills

• KPIs against your most impactful commitments.
• Reasons for not meeting any commitment.
• How the fulfilled commitments have helped improve the range of skills, or access to skills provision, and how commitments have helped to make the Supply Chain safer, more representative of the population as a whole, and ethical.

A developer may wish to include evidence to support statements made in the Post Build Report, such as a copy of the final template for monitoring commitments in Annex E, list of innovations developed/deployed, and copy of your skills strategy.

1. This requirement applies to all technologies defined in The Contracts for Difference (Definition of Eligible Generator) Regulations 2014 and is in accordance with The Electricity Market Reform (General) Regulations 2014 and The Contracts for Difference (Allocation) Regulations 2014 (as amended). ↩

2. Throughout this guidance, the term ‘Applicant’ is used according to the definition in Regulation 9 of The Electricity Market Reform (General) Regulations 2014 (as amended). ↩

3. In this guidance document, an Applicant is referred to as a Generator once they have secured a CfD in the allocation round. ↩

4. The plan can be found at: Build Back Better: our plan for growth ↩

5. ‘Working day’ is defined in The Contracts for Difference (Allocation) Regulations 2014 (as amended). ↩