---
title: "Evidence records"
language: en
canonical: https://dossiertwist.com/dossiers/southern-water-services-limited/evidence-records/
as_of: 2026-10-17
keywords: ["Southern Water Services Limited","Southern Water","02366670","water and wastewater company","South East England","Greensands Holdings","Macquarie Asset Management","Macquarie Super Core Infrastructure Fund","Asterion Industrial Partners","Sandstone Water Holdings","Ofwat","Environment Agency","Drinking Water Inspectorate","sewage discharges","2025 recapitalisation","SWS Scheme","Greensands (UK) Limited administration","ownership history","board of directors","AMP8 frameworks"]
---

# Evidence records

**Question.** Which records support the articles?

**Answer.** Full assertions with source references, qualifications, responses and known outcomes. The topic articles explain these records in context.

## Southern Water: owners, rescue and enforcement record

- Documented: Southern Water Services Limited is a private limited company registered in England and Wales under company number 02366670. Companies House lists it as active, with its registered office at Southern House, Yeoman Road, Worthing, West Sussex, BN13 3NX. [src-094] [src-093] [src-017]
- Documented: Companies House data summarised by a company-information aggregator give Southern Water Services Limited's incorporation date as 1 April 1989 and show the same Worthing registered office throughout. [src-028]
  - Qualification: The incorporation date comes from the aggregator's summary of the register; the retained official register pages do not show it.
- Documented: The company's registered activity codes are water collection, treatment and supply (36000), sewerage (37000) and technical testing and analysis (71200). [src-028]
- Documented: In its annual report for the year ended 31 March 2026 Southern Water describes its business as providing water services to 2.7 million customers and wastewater services to around 4.8 million customers across Kent, Sussex, Hampshire and the Isle of Wight. [src-059]
- Documented: Companies House's filing history records new articles of association adopted by resolution and filed on 25 March 2025, and full accounts for the years to 31 March 2024, 2025 and 2026 filed on 25 November 2024, 9 September 2025 and 10 September 2026 respectively. [src-093] [src-040]

## Southern Water's owners before Macquarie, 1996–2021

- Documented: ScottishPower's annual report and Form 20-F for 2000/01, filed with the U.S. Securities and Exchange Commission, states that Scottish Power plc acquired Southern Water plc, the group to which Southern Water Services belonged, in 1996. As a condition of regulatory clearance ScottishPower gave assurances to the Secretary of State, and Southern Water Services' Appointment (its licence) was modified to ensure the management independence of Southern Water Services and strengthen the ring fencing of its finances: the regulated business had to be run as if it were a separate public listed company, with a board independent of ScottishPower that included two non-executive directors. ScottishPower remained the owner until the sale completed on 23 April 2002. [src-090] [src-078]
- Documented: ScottishPower's 2001-02 annual report, filed as an exhibit to its Form 20-F, states that the sale of Southern Water to First Aqua Limited, a company specifically formed to undertake the acquisition, was announced on 8 March 2002 and concluded on 23 April 2002. The group sold Aspen 4 Limited, the holding company of Southern Water plc, to First Aqua for a total consideration before expenses of £2.05 billion, including repayment and acquisition of intra-group non-trading debt and First Aqua's assumption of Southern Water's non-trading debt due to third parties. An exceptional charge of £1,187.5 million, including £738.2 million of goodwill previously written off to reserves, provided for the loss on disposal of the Southern Water business. The same report lists Southern Water Services Limited as a wholly owned principal subsidiary disposed of in that sale, and the Form 20-F exhibit list includes the sale and purchase agreement for the share capital of Aspen 4 Limited dated 8 March 2002. [src-077] [src-078]
- Documented: At the time of the 2002 sale ScottishPower described Southern Water as operating in an area of about 10,450 square kilometres in south-east England, collecting wastewater from about 1.7 million premises and supplying water to about 1 million. [src-078]
- Documented: Greensands Holdings Limited's annual report for 2020-21 describes Southern Water Capital Limited as the previous holding company for the Southern Water group, established as part of the sale of Southern Water by ScottishPower in 2002; it does not trade and holds preference shares in Southern Water Services. The same report describes Southern Water Services Group Limited as the immediate parent of the securitised group following the financial restructuring in 2003, when Southern Water set up a whole business securitisation after its sale by ScottishPower. [src-091]
  - Qualification: Greensands Holdings, incorporated in 2007, is named only as the author of the report.
- Attributed: According to a press report of 9 October 2007, the Royal Bank of Scotland, together with the French environmental services company Veolia, took over Southern Water in a deal worth £2 billion in 2003. The report said that, thanks to what it called an extraordinary ownership structure, RBS then owned about 49% of the company but controlled nearly 94% of the voting rights, and that the US hedge funds Perry Capital and DE Shaw were the other major shareholders. [src-092] [src-091] [src-059]
  - Qualification: Press report. ScottishPower's own report dates the sale of Southern Water to First Aqua Limited, for £2.05 billion, to 23 April 2002; the retained records do not explain how First Aqua's 2002 purchase relates to the 2003 RBS-Veolia takeover described in the press report, or which company's shares and votes the 49% and 94% refer to.
  - Outcome: Greensands Holdings' annual report for 2020-21 states that the Greensands group was established in September 2007 to acquire 100% of the share capital of Southern Water Capital Limited, then Southern Water's ultimate parent company, from the Royal Bank of Scotland, and that Greensands Holdings became the ultimate parent company of the Southern Water group on 15 October 2007; Southern Water's annual report for the year to 31 March 2026 gives the same account of the purchase from the Royal Bank of Scotland.
- Attributed: According to the same press report of 9 October 2007, a consortium led by the Australian company Challenger Financial Services had acquired Southern Water Capital from the Royal Bank of Scotland for £4.2 billion, a price that included about £2.8 billion of debt. Challenger Infrastructure Fund invested £300 million for a 27% equity interest; a fund advised by JPMorgan Asset Management's infrastructure investment group would invest 32%, Access Capital Advisers (for seven Australian superannuation funds) 18%, UBS 18%, Hermes Pension Management 4% and Paceweald Ltd 1%. [src-092] [src-091]
  - Qualification: Press report of the consortium shares agreed at the time of the deal. The company records do not give the 2007 percentages or the £4.2 billion price; they state that the Greensands group invested £1.9 billion of equity and debt to finance the acquisition.
  - Outcome: Greensands Holdings' annual report for 2020-21 states that on 15 October 2007 Greensands Holdings Limited became the ultimate parent company of the Southern Water group through the acquisition of Southern Water Capital by Greensands Investments Limited.
- Analysis: Reading the 2007 press report together with Greensands Holdings' 2020-21 report, three of the 2007 consortium investors appear to continue as shareholders until the 2021 Macquarie transaction: the fund advised by JPMorgan Asset Management (32% in 2007; in 2021 IIF Int'l SW UK ParentCo Ltd, part of the Infrastructure Investments Fund advised by J.P. Morgan Asset Management), UBS (18% in 2007; in 2021 a shareholding advised by UBS Asset Management) and Hermes Pension Management (4% in 2007; in 2021 Hermes Infrastructure funds, part of Federated Hermes International, formerly Hermes Investment Management). [src-092] [src-091]
  - Qualification: The link rests on the investors' names and the continuity of the Greensands group since 2007; no record ties the 2007 investors and the 2021 shareholders together by registration number.
- Documented: Greensands Holdings Limited (Jersey registered number 98700) was incorporated on 28 September 2007 as the parent of Greensands Europe Limited, whose subsidiaries include Greensands Investments Limited. On 15 October 2007 it became the ultimate parent company of the Southern Water group when Greensands Investments Limited acquired Southern Water Capital Limited. According to both the 2020-21 Greensands report and Southern Water's annual report for the year to 31 March 2026, the Greensands group was set up in September 2007 to buy 100% of the share capital of Southern Water Capital Limited, then Southern Water's ultimate parent, from the Royal Bank of Scotland, with £1.9 billion of equity and debt. The 2020-21 report adds that Greensands Holdings held 100% of the share capital of Greensands Europe and had no direct holdings in any other company. [src-091] [src-059]
- Documented: Greensands Holdings Limited was registered in Jersey but resident in the UK for tax. Its 2020-21 report says it was incorporated in Jersey because Jersey law allows greater choice than the UK as to the way distributions can be made to shareholders. Southern Water's annual report for the year to 31 March 2026 states that no interest or dividends were paid to the investors in Greensands Holdings before the change in ownership structure on 4 July 2025, and that Greensands Holdings, Greensands Europe Limited, Greensands UK Limited and Southern Water (Greensands) Financing plc, previous members of the group, are in the process of being closed and dissolved. [src-059] [src-091]
- Documented: Before the Macquarie transaction, Greensands Holdings' annual report for the year to 31 March 2021 describes the company as owned by a consortium of long-term investors (infrastructure investment funds, pension funds and private equity) with no single shareholder holding majority control: a shareholding advised by UBS Asset Management; IIF Int'l SW UK ParentCo Ltd, part of the Infrastructure Investments Fund advised by J.P. Morgan Asset Management; a shareholding managed by Whitehelm Capital for the Motor Trades Association of Australia and Prime superannuation funds; Hermes Infrastructure funds; and other minor holdings of infrastructure investment companies. The notes state that at 31 March 2021 no single investor owned a controlling shareholding. [src-091]
- Documented: According to Greensands Holdings' 2020-21 report, its board had five directors: three appointed by an infrastructure fund managed by JP Morgan Asset Management, one by infrastructure funds managed by UBS Asset Management and one by pension and infrastructure funds managed by Hermes; another shareholder could appoint a non-voting observer. The chairman of Southern Water was not a member, and no director of Greensands Holdings was also a director of Southern Water Services Limited. [src-091]
- Documented: Greensands Holdings' 2020-21 report states that, to comply with Condition P of Southern Water's licence, the shareholders considered to be the Joint Ultimate Controllers of Southern Water had given undertakings to provide all necessary information to the company, not to cause it to breach its obligations and to ensure that there were not fewer than three independent non-executive directors on the Southern Water board. [src-091]
- Documented: Greensands Europe Limited issued notes ("Eurobonds") with an aggregate principal of £359,725,975 to the shareholders of Greensands Holdings, in proportion to their shareholdings. The notes carried 12% annual interest, compounded if unpaid, and were repayable on 31 March 2038, and a payment-in-kind exercise in 2016 capitalised £489,788,024 of accrued interest. At 31 March 2021 the shareholder Eurobonds totalled £1,569.6 million including £720.1 million of accrued interest, and Eurobond interest payable to related parties for the year to 31 March 2021 was £168.2 million (previous year: £150.5 million). The largest listed holding was IIF Int'l SW UK Investment Ltd's £278.3 million of Eurobond principal; other holders included Phildrew Nominees Ltd for UBS funds, Hermes Infrastructure Fund partnerships, National Nominees Ltd for the Motor Trades Association of Australia Super Fund and Prime Super, and the Falkirk Council and Lothian pension funds. On 11 June 2021 the holders transferred the Eurobonds to Greensands Holdings in exchange for new shares, which did not change the percentage of shares held by each group of shareholders. [src-091]
- Documented: SWS Holdings Limited's accounts for the year to 31 March 2022 state that until 8 September 2021 Greensands Holdings Limited (Jersey 98700) was owned and controlled by a consortium of investors and had no ultimate parent or controlling party. On 8 September 2021, under an agreement with the existing shareholders, Macquarie Asset Management, through the Macquarie group company MSCIF Wight Bidco Limited, acquired a 62.24% majority stake in Greensands Holdings Limited, investing over £1 billion of equity. The accounts name MSCIF Wight Bidco Limited as the intermediate holding company and Macquarie Asset Management as the ultimate parent and controlling party. [src-089]

## Macquarie and Southern Water, 2021–2025

- Documented: According to Ofwat, Southern Water announced on 9 August 2021 that a fund managed by Macquarie Asset Management (MAM) had agreed to acquire a majority stake in Greensands Holdings Limited, then the ultimate parent company of Southern Water. The transaction completed in September 2021: Macquarie Super Core Infrastructure Fund SCSp (MSCIF) injected about £1.073 billion of new equity into Greensands, including about £530 million invested as new equity into Southern Water, with the rest used to strengthen other Greensands group companies. Ofwat states that from that date MSCIF became the entity with legal control over Greensands and therefore Southern Water. [src-009]
- Documented: Southern Water's annual report for the year to 31 March 2026 describes the same transaction as an investment of £1.1 billion by funds managed by Macquarie Asset Management for a majority stake in the Greensands group in September 2021, used to repay £476.0 million of external debt and to inject £529.9 million into Southern Water Services through the settlement of an inter-company loan and the issue of new equity; a second equity injection of £550 million followed in October 2023. Ofwat's September 2026 consultation states that MAM-managed funds invested more than £1.6 billion into the group between 2021 and 2023. [src-059] [src-020]
- Documented: Ofwat's November 2022 conclusions on the change of control summarise the owners of Southern Water as of September 2021, after MSCIF had gained legal control over Greensands Holdings Limited, the ultimate parent, as: Macquarie Super Core Infrastructure Fund SCSp (MSCIF) 62%, funds managed by JP Morgan Asset Management 15%, funds managed by UBS Asset Management 8%, Hermes Infrastructure funds 8% and minority owners 7%. [src-009]
- Documented: Ofwat records that in November 2021, after completion, MSCIF syndicated part of its equity interest by selling part of its indirect shareholding in Wight Ventures S.à r.l to funds managed by AMF Pensionförsäkring AB (an 11.45% interest in Wight Ventures), MR Ergo (6.97%) and Retail Employees Superannuation Pty Limited as trustee for the Retail Employees Superannuation Trust (13.28%), together the co-investors. MSCIF retained full control over the affairs of Wight Ventures; MSCIF Luxembourg GP S.àr.l remained the general partner and Macquarie Asset Management Europe S.àr.l (MAMES) the manager responsible for managing the investment under the general partner's supervision. The percentages are interests in Wight Ventures, not direct holdings in Greensands or Southern Water. [src-009]
- Documented: Ofwat consulted on the change of ownership of Southern Water Services Limited from 3 August to 14 September 2022 and published its conclusions in November 2022. It identified MSCIF, acting by its general partner MSCIF Luxembourg GP S.àr.l, and Macquarie Asset Management Europe S.àr.l (MAMES) as the Ultimate Controllers of Southern Water, a licence term for any person that, in Ofwat's reasonable determination, is in a position to control or materially influence the policy or affairs of the company or any of its holding companies. Ofwat found no individual investor able to exert significant influence on MSCIF who would need to give an Ultimate Controller undertaking, reasoning that where underlying investors have no day-to-day control of a fund and cannot influence its decisions, the institution that manages the investment has the requisite influence and control. Ofwat saw no need to change Southern Water's licence because of the change of control. [src-009]
- Documented: Ofwat noted in the same document that it has no formal powers to approve or reject new owners of water companies, that it held a consultation in this case because of the complexity of identifying the Ultimate Controllers and its long-standing concerns about Southern Water's performance, and that it received four responses, all from individuals. [src-009]
- Documented: Ofwat's September 2026 change-of-ownership consultation states that, as of 31 March 2025, Greensands Holdings Limited was Southern Water's ultimate parent company and its majority shareholder was MSCIF Wight Bidco Limited, acting on behalf of infrastructure funds managed by Macquarie Asset Management. In the diagram of the corporate and ownership structure as of 31 March 2025, the Macquarie Super Core Infrastructure holding companies include MSCIF Wight Bidco Limited and MSCIF Wight Midco Limited; funds managed by MAM on behalf of long-term investors hold 87%, and minority investors hold about 13%, including institutional investors advised by UBS Asset Management and Hermes Infrastructure funds. These are snapshot figures for 31 March 2025; Greensands Holdings stopped being the parent on 4 July 2025. [src-020] [src-059]
- Documented: Companies House's register of people with significant control for MSCIF Wight Bidco Limited (company number 13469990) lists two active registrable entities, both notified on 22 June 2021: MSCIF Wight Midco Limited (13468085), holding 75% or more of the shares and voting rights and the right to appoint or remove directors, and Macquarie Infrastructure and Real Assets (Europe) Limited (03976881), registered only as having significant influence or control, without a shareholding. Both were listed as active on the register retrieved in October 2026. [src-044]
- Documented: The register for MSCIF Wight Midco Limited (13468085) lists one active registrable entity: Macquarie Infrastructure and Real Assets (Europe) Limited, notified on 21 June 2021 as having significant influence or control, without a shareholding. A statement that the company knew of no registrable person was notified and withdrawn on the same day. No shareholder of Wight Midco is named on the register. [src-080]
- Documented: Companies House lists Macquarie Asset Management UK Holdings No.1 Limited (12514361) as the active registrable entity of Macquarie Infrastructure and Real Assets (Europe) Limited (03976881), notified on 1 July 2020, with 75% or more of the shares and voting rights and the right to appoint or remove directors; a second, ceased entry for the same company was notified and ceased on 25 August 2020. Macquarie Group Holdings (UK) No.2 Limited (06357999) held the same controls from 6 April 2016 to 25 August 2020. [src-081]
- Analysis: The records use four different measures of Macquarie's position, which should not be read as one figure. Legal ownership: MSCIF Wight Bidco Limited acquired 62.24% of Greensands Holdings on 8 September 2021, and since 4 July 2025 Sandstone Bidco Limited has owned Greensands Junior Finance, the new top company of the group. Registers of people with significant control: Macquarie Infrastructure and Real Assets (Europe) Limited is registered at MSCIF Wight Bidco, MSCIF Wight Midco and the three Sandstone companies only as having significant influence or control, without a shareholding. Ofwat's licence designation: the Ultimate Controllers identified in November 2022 are MSCIF, acting by its general partner, and Macquarie Asset Management Europe S.àr.l, a status based on the ability to control or materially influence the company rather than on share ownership. Group percentages: Ofwat's 62% (September 2021) and 87% (31 March 2025) are shares of the Southern Water group held by MSCIF or by MAM-managed funds, and the 11.45%, 6.97% and 13.28% co-investor stakes are interests in Wight Ventures S.à r.l. [src-089] [src-015] [src-009] [src-020]
  - Qualification: Comparison of the cited records; the records do not show the shareholdings between Wight Ventures, MSCIF Wight Midco and MSCIF Wight Bidco.
- Documented: In a Form 605 notice of ceasing to be a substantial holder, made under section 671B of Australia's Corporations Act 2001 and dated 7 November 2017 (it concerned shares in Western Areas Ltd), Macquarie Group Limited (ABN/ACN 122 169 279, Sydney) listed its controlled bodies corporate in Annexure A. The list includes three Luxembourg entities: Macquarie Super Core Infrastructure Fund SCSp (RCS B 214.195), MSCIF Luxembourg GP S.à r.l. (B 214.067) and MSCIF Luxembourg C Holdings S.à r.l. (B218.732). The notice is a dated snapshot of 2017, before the Southern Water transaction. [src-027]
- Documented: A business-registry aggregator lists Macquarie Super Core Infrastructure Fund SCSp under Luxembourg register number B214195 (LEI 222100FWG5CYEJPG3J11), at 20 Boulevard Royal, 2449 Luxembourg, with the activity code for trusts, funds and similar financial entities, and its network view shows MSCIF Luxembourg GP S.à r.l. as general partner. The aggregator's own notes say that the view is an anonymous, incomplete extract and that the direction of the network links is not verified. [src-042]
- Documented: The same aggregator lists MSCIF Luxembourg GP S.à r.l. under register number B214067 at the same Luxembourg address, and shows it as general partner of Macquarie Super Core Infrastructure Fund SCSp and of other MSCIF partnerships, including Mscif A1 SCSp, Mscif Co-Invest SCSp, Mscif NC1 SCSp and Mscif Sophisticated Staff Investors Feeder SCSp, without verifying the direction of these links. [src-051]
- Documented: A business-registry aggregator lists Macquarie Asset Management Europe S.à r.l., formerly Macquarie Infrastructure and Real Assets Luxembourg S.à r.l., under Luxembourg register number B233546 (LEI 2221008OZQM47X2T5996) at 20 Boulevard Royal, Luxembourg, with the activity code for fund management. Its network view, retrieved in October 2026, shows Charles G. H. Roemers, Mark Roland Phillips and Cindyrella Amistadi among the company's current managing directors; the aggregator gives no appointment dates and does not verify the identities. [src-043]
- Documented: A business-registry aggregator lists MSCIF Luxembourg C Holdings S.à r.l. under Luxembourg register number B218732 (LEI 222100UGV5A9OTKCUO86) at 20 Boulevard Royal, Luxembourg, as a holding company. Its network view, retrieved in October 2026, shows Viktor Schuh, Charles G. H. Roemers, John William Lee and Philip Hogan as current managing directors, without appointment dates and with the aggregator's note that identities are unverified. [src-033]
- Documented: According to the publications shown by a business-registry aggregator, Mscif SC 6 S.à r.l. was registered in Luxembourg on 17 March 2022 (register number B265775) with a capital of €13,000, its shareholder at registration being MSCIF Luxembourg C Holdings S.à r.l.; the aggregator dates its change of name to Mscif Sandstone Holdings S.à r.l. to 6 June 2025. The aggregator's history lists Catherine Isabelle Harber and Charles Ghislain Hubert Roemers as managing directors from 21 May 2025 and Viktor Schuh from 13 March 2024, and William David George Price as managing director from 17 March 2022 to 17 June 2024; two other managing directors are listed for parts of the period from 17 March 2022 to 6 June 2025. [src-026]
  - Qualification: Aggregator data, which the aggregator says are generated automatically and may contain errors; it does not show the current shareholder in its free view.
- Documented: The same aggregator lists MSCIF Sandstone Ventures S.à r.l. under Luxembourg register number B266315, formerly named Mscif SC 9 S.à r.l. and Mscif Luppiter Holdings S.à r.l., as a holding company at 20 Boulevard Royal, Luxembourg. Its network view, retrieved in October 2026, shows Charles G. H. Roemers, Catherine Isabelle Harber and Viktor Schuh as current managing directors and William D. G. Price and Mark Roland Phillips as former managing directors, without dates and with the note that identities and link directions are unverified. [src-025]
- Documented: The aggregator connects the two Luxembourg Sandstone companies: on the page of Mscif Sandstone Holdings S.à r.l. it shows a publication of 10 April 2026, listed as coming via MSCIF Sandstone Ventures S.à r.l. and titled "Shareholding: Mscif Sandstone Ventures Sàrl", and its network view shows a former link labelled "62.2%" between the two companies. The free view does not show the direction or the current size of the holding. [src-026] [src-025]
  - Qualification: Aggregator data. The reading that Mscif Sandstone Holdings holds shares in MSCIF Sandstone Ventures depends on the aggregator's page layout; no primary Luxembourg register extract was retained.
- Analysis: The William David George Price shown by the aggregator as a former managing director of Mscif Sandstone Holdings and of MSCIF Sandstone Ventures is probably the Macquarie executive of that name who joined Southern Water's board in September 2021: the full name is the same, Southern Water's annual report describes Will Price as head of Macquarie Asset Management's utilities and networks team in Europe, the Middle East and Africa, and Companies House records the appointment of a William David George Price as a director of Sandstone Water Holdings Limited, the UK company owned by MSCIF Sandstone Ventures, on 20 December 2025. [src-026] [src-059] [src-022]
  - Qualification: Identity inferred from the name and the roles; the aggregator gives no date of birth or identifier and marks identities as unverified.

## Southern Water's holding and finance companies

- Documented: Companies House's register of people with significant control lists SWS Holdings Limited (company number 04324499) as the only registrable controller of Southern Water Services Limited, notified on 6 April 2016, with 75% or more of the shares and voting rights and the right to appoint or remove directors. Southern Water's annual report for the year to 31 March 2026 also names SWS Holdings Limited as the company's immediate parent undertaking. [src-001] [src-059]
- Documented: The register for SWS Holdings Limited (04324499) lists SWS Group Holdings Limited (04324498) as its only registrable controller, notified on 6 April 2016, with 75% or more of the shares and voting rights and the right to appoint or remove directors. [src-005]
- Documented: The register for SWS Group Holdings Limited (04324498) lists Southern Water Services Group Limited (04374956) as its only registrable controller, notified on 6 April 2016, with 75% or more of the shares and voting rights and the right to appoint or remove directors. [src-006]
- Documented: The register for Southern Water Services Group Limited (04374956) lists Southern Water Investments Limited (04650294) as its only registrable controller, notified on 6 April 2016, with 75% or more of the shares and voting rights and the right to appoint or remove directors. [src-007]
- Documented: The register for Southern Water Investments Limited (04650294) lists Southern Water Capital Limited (04608528) as its only registrable controller, notified on 6 April 2016, with 75% or more of the shares and voting rights and the right to appoint or remove directors. [src-008]
- Documented: Greensands Holdings' 2020-21 report describes SWS Holdings as the immediate holding company of Southern Water and SWS Group Holdings as an intermediate holding company, both part of the securitised group set up in 2003, whose immediate parent is Southern Water Services Group Limited. Lenders to this financing group are secured by a charge over the share capital of SWS Group Holdings, not over Southern Water's regulated operating assets. Southern Water's annual report for the year to 31 March 2026 likewise states that security granted to the lenders of the Southern Water Financing Group is limited to the share capital of SWS Group Holdings Ltd. [src-091] [src-059]
- Documented: The register for Southern Water Capital Limited (04608528) lists Greensands Finance Limited (11493345) as its active registrable controller, notified on 23 October 2018, with 75% or more of the shares and voting rights and the right to appoint or remove directors. Greensands Investments Limited (06301867) held the same position from 6 April 2016 to 23 October 2018. [src-010]
- Documented: The register for Greensands Finance Limited (11493345) lists Greensands Finance Holdings Limited (11493352) as its active registrable controller, notified on 23 October 2018, with 75% or more of the shares and voting rights. Greensands Investments Limited (06301867) was registered from 31 July 2018 to 23 October 2018 with 75% or more of the shares and voting rights and the right to appoint or remove directors. According to Greensands Holdings' 2020-21 report, Greensands Finance Holdings, Greensands Finance and Greensands Financing plc (the 'MidCo' entities) were incorporated in 2018 in a financial restructuring meant to improve Southern Water's financial resilience and reduce leverage within the Southern Water Financing Group. [src-011] [src-091]
- Documented: The register for Greensands Finance Holdings Limited (11493352) lists Greensands Investments Limited (06301867) as its only registrable controller, notified on 31 July 2018, with 75% or more of the shares and voting rights and the right to appoint or remove directors. [src-012]
- Documented: The register for Greensands Investments Limited (06301867) lists Greensands Senior Finance Limited (06335773) as its only registrable controller, notified on 6 April 2016, with 75% or more of the shares and voting rights and the right to appoint or remove directors. [src-013]
- Documented: The register for Greensands Senior Finance Limited (06335773) lists Greensands Junior Finance Limited (registration number given there as 6335757) as its only registrable controller, notified on 6 April 2016, with 75% or more of the shares and voting rights and the right to appoint or remove directors. [src-014]
- Documented: The register for Greensands Junior Finance Limited (06335757) lists Sandstone Bidco Limited (16482992) as its active registrable controller, notified on 4 July 2025, with 75% or more of the shares (no voting or appointment rights are listed). Greensands (UK) Limited (registration number given there as 6366235) was registered from 6 April 2016 to 4 July 2025 with 75% or more of the shares and voting rights and the right to appoint or remove directors. [src-015]
- Documented: The register for Sandstone Bidco Limited (16482992) lists two active registrable entities, both notified on 29 May 2025: Sandstone Midco Limited (16482495), with 75% or more of the shares and voting rights and the right to appoint or remove directors, and Macquarie Infrastructure and Real Assets (Europe) Limited (03976881), registered only as having significant influence or control, without a shareholding. [src-016]
- Documented: The register for Sandstone Midco Limited (16482495) lists two active registrable entities, both notified on 29 May 2025: Sandstone Water Holdings Limited (16482350), with 75% or more of the shares and voting rights and the right to appoint or remove directors, and Macquarie Infrastructure and Real Assets (Europe) Limited (03976881), registered as having significant influence or control. [src-018]
- Documented: The register for Sandstone Water Holdings Limited (16482350), the highest UK company in the chain, lists one active registrable entity: Macquarie Infrastructure and Real Assets (Europe) Limited (03976881), notified on 29 May 2025 as having significant influence or control, without a shareholding. No shareholder is named on that register; the company's shareholder appears in its confirmation statement. [src-021]
- Documented: In its confirmation statement dated 28 May 2026, Sandstone Water Holdings Limited (16482350) reported 81,376 ordinary shares in issue, all held at that date by MSCIF Sandstone Ventures S.à r.l., a Luxembourg company. [src-023]
- Documented: Southern Water's annual report for the year to 31 March 2026 states that on 4 July 2025 Sandstone Bidco Limited acquired the issued share capital of Greensands Junior Finance Limited and Southern Water (Greensands) Financing plc from Greensands (UK) Limited, which was then in administration, and became the new ultimate indirect UK holding company of Southern Water Services Limited, replacing Greensands Holdings Limited. Greensands Junior Finance Limited became the top company of the group and the parent undertaking of the largest and smallest group consolidating Southern Water's accounts. The report describes Sandstone Bidco as representing a consortium of long-term investors with the majority investment from funds managed by Macquarie Asset Management, whose funds indirectly own a majority shareholding of Sandstone Bidco and which is treated as a related party. [src-059]
- Documented: SW (Finance) I PLC (13677506) is a financing subsidiary of Southern Water Services Limited: the Companies House register lists Southern Water Services Limited as its only registrable controller, notified on 13 October 2021, with 75% or more of the shares and voting rights and the right to appoint or remove directors, and its own accounts for the year to 31 March 2026 name Southern Water Services Limited as its immediate parent. It issues bonds under a £6,000,000,000 multicurrency programme that, according to the supplementary prospectus of 30 July 2025, is unconditionally and irrevocably guaranteed by, among others, Southern Water Services Limited. The accounts also state that on 4 July 2025 Sandstone Bidco Limited became its new ultimate indirect UK holding company, replacing Greensands Holdings Limited, and that Greensands Junior Finance Limited is the parent of the only group consolidating it. [src-031] [src-017] [src-045]
- Documented: The register for SW (Finance) II Limited (13677558) lists Southern Water Services Limited as its only registrable controller, notified on 13 October 2021, with 75% or more of the shares and voting rights and the right to appoint or remove directors. [src-106]
- Documented: The register for Southern Water (NR) Holdings Limited (04772485) lists Southern Water Investments Limited (04650294) as its only registrable controller, notified on 6 April 2016, with 75% or more of the shares and voting rights and the right to appoint or remove directors. Southern Water Investments Limited is also the registered controller of Southern Water Services Group Limited, which sits above Southern Water Services. [src-107] [src-007]
- Documented: Southern Water Limited (company number 02366620) is a separate company from Southern Water Services Limited (02366670). Its register lists Southern Water (NR) Limited, a company registered in Scotland under number SC215844, as its only registrable controller, notified on 6 April 2016, with 75% or more of the shares and voting rights and the right to appoint or remove directors. Greensands Holdings' 2020-21 accounts list Southern Water Limited, Southern Water (NR) Limited and Southern Water (NR) Holdings Limited among the wholly owned subsidiaries of Greensands Europe Limited. [src-064] [src-001] [src-091]
- Documented: Alter Domus (UK) Limited (07562881), whose London office at 30 St Mary Axe is the correspondence address recorded for Sandstone Midco Limited, Sandstone Water Holdings Limited and MSCIF Wight Midco Limited in their entries as registrable controllers, was appointed company secretary of Sandstone Water Holdings Limited on 13 November 2025, according to the Companies House filing history. Its own register of people with significant control carries an active statement, notified on 22 November 2023, that the company knows of no registrable person or registrable legal entity; three individuals were registered as controllers from 11 April 2017 to 22 November 2023. No record shows Alter Domus holding shares in the Southern Water group. [src-016] [src-018] [src-044] [src-022] [src-082]
- Analysis: Read together, the PSC registers retrieved in October 2026 show a chain of UK companies above Southern Water Services Limited, each registered as holding 75% or more of the shares of the company below it: SWS Holdings, SWS Group Holdings, Southern Water Services Group, Southern Water Investments, Southern Water Capital, Greensands Finance, Greensands Finance Holdings, Greensands Investments, Greensands Senior Finance, Greensands Junior Finance, Sandstone Bidco, Sandstone Midco and Sandstone Water Holdings, whose sole shareholder at 28 May 2026 was the Luxembourg company MSCIF Sandstone Ventures S.à r.l. Until 4 July 2025 the line ran from Greensands Junior Finance to Greensands (UK) Limited and, according to the group accounts, through Greensands Europe to Greensands Holdings. At the three Sandstone companies Macquarie Infrastructure and Real Assets (Europe) Limited is registered alongside the shareholder as having significant influence or control. [src-001] [src-023] [src-015] [src-091]
  - Qualification: Analysis of the cited register entries. The register of Greensands Junior Finance lists Sandstone Bidco with shares only, without voting or appointment rights, and the links between Greensands (UK), Greensands Europe and Greensands Holdings come from the accounts rather than the PSC registers.

## The 2025 rescue of Southern Water's holding companies

- Documented: The joint administrators' proposals for Greensands (UK) Limited, dated 11 July 2025 and filed at Companies House, state that Greensands Holdings Limited (GHL) sent a consultation letter to its investors on 12 March 2025. As the administrators summarise it, the group had assessed after Ofwat's AMP8 final determination that the operating company, Southern Water Services Limited, needed additional funding of £900m to continue as a going concern and would otherwise likely be unable to comply with its Ofwat licences; that notes with about £427m outstanding, issued by Southern Water (Greensands) Financing plc and guaranteed by all the HoldCo companies, fell due during 2025 and could not be repaid from available liquidity; and that events of default on about £414m of MidCo facilities were expected from November 2025. [src-066]
- Documented: According to the same proposals, GHL wrote to its investors again on 28 March 2025 and, in late March 2025, issued a Rescue Issue Notice seeking about £1.3bn to meet the operating company's liquidity requirement and repay the HoldCo notes. No investor accepted the offer of Rescue Securities and the Rescue Issue was terminated on 10 April 2025. The one investor that had given a non-binding expression of interest then negotiated with the HoldCo and MidCo creditors; because a debt-for-equity arrangement would have needed a unanimous decision of GHL's investors, which was considered unlikely, the solution adopted was for a new company controlled by that investor ('New BidCo') to acquire the shares of the target companies and, subject to a scheme of arrangement at operating-company level, provide new equity. [src-066]
- Documented: The proposals record that Evercore, the group's financial adviser, wrote to GHL's investors on 6 June 2025 inviting fully financed binding offers for all the shares of the two target companies by midday on 19 June 2025, on terms that included repayment in full of the MidCo facilities and HoldCo notes on completion; five investors accessed the data room but no binding offer was submitted by the deadline. On 30 June 2025 the proposed administrators received an unconditional offer letter from Sandstone Bidco Limited for the entire share capital of the target companies. Completion, first expected on 30 June 2025, took place on 4 July 2025 after delays in executing the HoldCo and MidCo lock-up agreement. [src-066]
- Documented: The administrators describe Greensands (UK) Limited (company number 06366235) as incorporated on 10 September 2007, with no employees and no trade, acting as a holding company within the group that ultimately operates Southern Water. Its immediate parent, Greensands Europe Limited (company number 06366236), owned 100% of its 2,000,000 ordinary shares and was itself 100% owned by Greensands Holdings Limited; Macquarie Asset Management, through a Macquarie group company, was described as the majority shareholder in the consortium of investors owning Greensands Holdings Limited and therefore the ultimate controlling party of the group. At the date of the proposals its two directors were Richard Manning, a director since October 2023, and Alan Fort, a director since April 2025. [src-066]
- Documented: Companies House's filing history for Greensands (UK) Limited records these director changes between 2022 and 2023: Ian James McAulay's appointment ended on 30 June 2022 and Lawrence Karl Gosden was appointed on 1 July 2022; Sebastianus Antonius Theodorus Boelen's appointment ended and Nadim Ahmad was appointed on 31 July 2022; Nadim Ahmad's appointment ended and Stuart Neil Ledger was appointed on 27 January 2023; and Lawrence Karl Gosden's appointment ended and Richard Denley John Manning was appointed on 25 October 2023. [src-030]
- Documented: On 14 April 2025 the appointments of Stuart Neil Ledger (a director since 27 January 2023) and William David George Price as directors of Greensands (UK) Limited ended and Alan James Fort was appointed a director, according to filings made on 28 April 2025; Price's appointment date is not in the retained filing history. Richard Denley John Manning, appointed on 25 October 2023, remained a director, and the administrators' proposals name Manning and Fort as the company's directors in July 2025. [src-030] [src-066]
- Documented: Greensands (UK) Limited, an intermediate holding company of Southern Water Services Limited, entered administration on 4 July 2025. Its directors appointed Geoffrey Paul Rowley and Anthony John Wright of FRP Advisory Trading Limited, insolvency practitioners, as joint administrators in proceedings in the High Court of Justice (court reference 004563 of 2025), with consent given on 4 July 2025 by GLAS Trust Corporation Limited as holder of the qualifying floating charge; GLAS had replaced Deutsche Trustee Company Limited as security trustee on 12 June 2025. The notice of the administrators' appointment (form AM01) names the High Court of Justice and the directors as the appointing body. [src-066] [src-030] [src-052]
- Documented: Companies House's filing history for Greensands (UK) Limited records the notice of the administrator's appointment (AM01) and a change of registered office from Southern House, Worthing, to 2nd Floor, 110 Cannon Street, London EC4N 6EU, both filed on 17 July 2025, followed by the administrators' proposals (AM03, 18 July 2025), notice of deemed approval of the proposals (AM06, 1 August 2025), a statement of affairs (AM02, 18 August 2025), a progress report (AM10, 28 January 2026), revised proposals (AM09, 18 February 2026) and a notice of end of administration (AM21, 19 February 2026). [src-030]
- Documented: Companies House's appointment listing for Lawrence Karl Gosden, retrieved in October 2026, shows Greensands (UK) Limited with company status 'Active' and Gosden as a former (resigned) director. The company's filing history, as retained, ends with the notice of end of administration filed on 19 February 2026; the records do not show the company's status after that notice beyond this listing. [src-029] [src-030]
- Documented: On 4 July 2025, immediately after their appointment, the joint administrators of Greensands (UK) Limited sold its shareholdings in Greensands Junior Finance Limited and Southern Water (Greensands) Financing plc to Sandstone Bidco Limited in a pre-packaged sale. Sandstone's unconditional offer was to acquire the entire share capital of each target company for £1, and the proposals record a total sale consideration of £2. The offer also provided for a debt-for-equity exchange of the secured debt guaranteed by Greensands (UK) Limited and each target, a solvent winding-up or dissolution of Greensands (UK) Limited, the restatement and amendment of secured debt instruments of the targets' subsidiaries, and a commitment of at least £655,000,000 of new equity funding for those subsidiaries. [src-066]
- Documented: The administrators treated the sale as a connected-party transaction because Macquarie was linked both to Greensands (UK) Limited, whose group it controlled through its majority stake in Greensands Holdings Limited, and to the buyer, which was majority owned by funds managed by Macquarie Asset Management. Sandstone obtained an independent evaluator's qualifying report under the Administration (Restrictions on Disposal etc. to Connected Persons) Regulations 2021, which concluded that the consideration and the grounds for the disposal were reasonable. The administrators did not obtain a valuation, reasoning that no investor had been willing to provide further equity or buy Rescue Securities, so that value broke within the HoldCo notes. [src-066]
- Documented: Sandstone Bidco Limited (company number 16482992) was incorporated in England and Wales on 29 May 2025 by MSCIF Sandstone Ventures S.à r.l., with Richard Greenleaf, Catherine Harber and Susana Leith-Smith as its directors. According to the administrators, its two ordinary shares were owned by Sandstone Midco Limited, it was majority owned by funds managed by Macquarie Asset Management, and its primary purpose was a consensual recapitalisation of the target companies and their subsidiaries. The supplementary prospectus of 30 July 2025 describes it as a special purpose company established by Macquarie Asset Management to acquire control of the SWS Financing Group. [src-066] [src-017]
- Documented: The 2025–26 annual report states that on 31 March 2025 Greensands Holdings Limited was the ultimate parent company and controlling party of Southern Water Services Limited, with MSCIF Wight Bidco Limited as its majority shareholder on behalf of funds managed by Macquarie Asset Management, and that Greensands (UK) Limited was an intermediate parent company of Southern Water. Through the purchase of 4 July 2025, Sandstone Bidco Limited acquired Greensands Junior Finance Limited, which replaced Greensands Holdings Limited as the parent at the top of Southern Water's group, and so became an indirect holding company of Southern Water Services Limited from that date; Ofwat's consultation of September 2026 adds that MAM-managed funds remained the majority shareholder. The supplementary prospectus of 30 July 2025 states that Sandstone Bidco Limited was then 100% indirectly owned by MSCIF Luxembourg C Holdings S.à r.l. [src-059] [src-020] [src-017]
- Documented: Appendix F of the proposals lists five unsecured, intra-group creditors of Greensands (UK) Limited totalling £4,082,973,880: Greensands Europe Limited (£3,969,958,771), Greensands Holdings Limited (£112,944,591), Southern Water (Greensands) Financing Plc (£50,000), Greensands Investments Limited (£20,175) and Southern Water Services Limited (£343). The administrators expected no distribution to unsecured creditors, envisaged that the inter-company balances would be assigned to the purchaser on completion of the wider restructuring, pursued objective (c) of an administration (realising property to make a distribution to secured or preferential creditors) and proposed to take steps to dissolve the company. [src-066]
- Unresolved: The records give different figures for the holding-company debt dealt with in the restructuring. As summarised by the administrators, GHL's consultation letter of 12 March 2025 put the HoldCo notes at about £427m and the MidCo facilities at about £414m. The administrators' proposals state that £449m of principal was outstanding on the HoldCo loan-note facilities before their appointment and that the security trustee held security for lenders owed about £449m; their estimated outcome statement shows £401,000,000 due to the fixed-charge holder, while Appendix F shows 'Nil' against secured creditors. The 2025–26 annual report states that the restructuring included an agreement to reduce external holding-company debt by c.£450 million and to extend the maturities of the remaining debt of c.£415 million. [src-066] [src-059]
  - Qualification: The figures refer to different dates, instruments and measures (principal, creditor claims, amounts in an estimated outcome statement); none of the records reconciles them, and the secured-creditor line in Appendix F conflicts with the body of the same proposals.
  - Outcome: The 2025–26 annual report later states that the external loans issued by Southern Water (Greensands) Financing plc, shown among the 'Holdco' financing companies, were removed as part of the group restructuring during the year, and that the maturity dates of the loans of the 'Midco' financing companies were extended.
- Documented: On 8 July 2025 Southern Water Services Limited accepted an offer of equity support from a consortium led by funds managed by Macquarie Asset Management by signing up to an equity commitment letter (ECL) from Sandstone Bidco Limited (the 'Sponsor'). According to the supplementary prospectus of 30 July 2025, the ECL comprised a legally binding equity commitment of £655 million (the 'Initial AMP8 Equity Commitment') and confirmation of intent to provide further commitments of up to £545 million, with a minimum of £245 million, by December 2025; injection of the initial commitment was conditional, in particular on sanction of a scheme of arrangement (the 'SWS Scheme'). [src-017]
- Documented: The supplement lists the conditions to the Initial AMP8 Equity Commitment as at 30 July 2025: completion of a debt-for-equity exchange (the 'Holdco Debt Exchange') of existing debt of Southern Water (Greensands) Financing plc, Greensands Holdings Limited, Greensands (UK) Limited, Greensands Junior Finance Limited and Greensands Senior Finance Limited; satisfaction of the conditions to a restatement of the debt of Greensands Finance Limited ('Midco'), Greensands Finance Holdings Limited and a company the supplement calls Greensands Finance PLC, including, where required, a final sanction order for a Midco scheme of arrangement under Part 26 or Part 26A of the Companies Act 2006 binding the existing term facility lender; no termination of a separate Holdco/Midco lock-up agreement dated 8 July 2025; delivery of a final sanction order for the SWS Scheme; no downgrade by S&P or Fitch below investment grade; and satisfaction of all these conditions by 5:00 p.m. on 31 October 2025. [src-017]
- Documented: Also on 8 July 2025, SWS and the other obligors of its financing group entered into a lock-up agreement (the 'SWS LUA') with, among others, Sandstone Bidco Limited as Sponsor, MSCIF Luxembourg C Holdings S.à r.l. as 'Investor', and holders of Class A debt representing, at 30 July 2025, about £5.5 billion and more than 72 per cent by value of outstanding Class A debt (including all liquidity facility providers, 98 per cent of hedge counterparties and about 65 per cent of other Class A debt). Kroll Issuer Services Limited acted as lock-up agent. The agreement's principal purpose was to secure creditor support for the SWS Scheme and related STID proposals so as to facilitate the injection of the Initial AMP8 Equity Commitment; creditors acceding by one business day before the record date were entitled to a fee of £1,000. [src-017]
- Documented: The supplement explains that under SWS's Common Terms Agreement it was an event of default if any two rating agencies rated the Class A debt below investment grade (the 'Ratings EoD'), so that a further downgrade by Standard & Poor's or Fitch would be an event of default unless Moody's had first restored an investment-grade rating. The Ratings EoD was to be removed permanently if SWS received the full Initial AMP8 Equity Commitment in cash by 31 March 2026, and to be waived conditionally once SWS received £505 million of it (the 'Initial Equity Injection'), which SWS expected by early November 2025 with a long-stop date of 28 November 2025. [src-017]
- Documented: The supplement reports that, according to the compliance certificate dated 29 July 2025 for the calculation date of 31 March 2025, a Trigger Event in relation to SWS's Conformed Class A Adjusted ICR and Conformed Class A Average Adjusted ICR had occurred and was continuing, both ratios standing at -0.4 against trigger levels of 1.30x and 1.40x, and that SWS expected to remain in a Trigger Event until at least March 2026. It gave the ratings of the Class A unwrapped bonds as BBB- (CreditWatch Negative) from Standard & Poor's, Ba1 (stable) from Moody's and BBB- (stable) from Fitch. [src-017]
- Documented: The supplementary prospectus of 30 July 2025 states that each obligor of the SWS Financing Group, including Southern Water Services Limited, prepared its financial statements for the period ending 31 March 2025 on a going-concern basis with a material uncertainty: the directors expected the Initial AMP8 Equity Commitment to be received, but when the statements were finalised it remained subject to conditions outside their control. The supplement adds that if the obligors could not continue as going concerns this might lead to a special administration order for SWS. [src-017]
- Documented: Southern Water's annual report for 2025–26, approved on 15 July 2026, includes no material uncertainty on going concern. It states that a material uncertainty had been reported in the interim report for the six months to 30 September 2025 (the SW (Finance) I PLC report adds that SWS's 2024–25 accounts also contained one), relating to the possibility of a downgrade below investment grade by a second rating agency, and that it had been addressed by: £0.9 billion of equity received and a further £0.3 billion commitment received on 22 June 2026; a simpler holding structure with less holding-company debt; a lower mark-to-market value of derivatives; new revenue allowances supplemented by the Competition and Markets Authority's redetermination published on 10 March 2026; the removal from the company's debt documentation of the event of default for not holding two investment-grade ratings; and £1.5 billion of additional debt with terms of five to eight and a half years. [src-045] [src-059]
- Documented: Deloitte LLP made going concern a key audit matter in its reports on the financial statements for the year ended 31 March 2026 of both Southern Water Services Limited (signed 15 July 2026) and SW (Finance) I PLC (signed 29 July 2026). It identified no material uncertainty but described the going-concern assessment for SWS as judgemental, resting on SWS keeping sufficient liquidity and covenant headroom and at least two investment-grade ratings when one of its three ratings was already below investment grade, and said that a downgrade by one of the other two agencies could, depending on the circumstances and Ofwat's response, result in a breach of the company's licence. [src-045] [src-059]
- Documented: On 9 October 2025 Mr Justice Richards, in the High Court of Justice, Business and Property Courts of England and Wales, Insolvency and Companies List (ChD), sanctioned two schemes of arrangement under Part 26 of the Companies Act 2006 in [2025] EWHC 2690 (Ch) (cases CR-2025-005763 and CR-2025-005674): one of SWS Holdings Limited (the 'SWS Scheme') and one of Greensands Financing Plc (the 'MidCo Scheme'), which were conditional on each other. He had convened the creditors' meetings by orders of 2 September 2025, with reasons in [2025] EWHC 2318 (Ch). The National Archives' Find Case Law service lists these two judgments, handed down on 2 September and 9 October 2025, under the search term 'Greensands'. [src-103] [src-057]
- Documented: According to the sanction judgment, both schemes were approved by overwhelming majorities and no one appeared to oppose them. In the SWS Scheme, four class meetings were held on 30 September 2025: turnout was 100% in Classes A1, A2 and A3 and 93.45% by value in Class A4, where 758 scheme creditors attended (757 by proxy), and 100% of those voting in every class voted in favour. In the MidCo Scheme, nineteen creditors attended the single class meeting, representing 100% by value of the scheme debt, and all voted in favour. [src-057]
- Documented: The judge described the SWS Scheme as narrowing the definition of an event of default in exchange for much-needed equity funding: without the amendment, a ratings downgrade would accelerate principal and interest on the debt of the 'SWS Borrowers', and SWS Holdings Limited, which had throughout been a guarantor of that debt, would face 'ricochet' claims through a deed of contribution. The amendments were to become fully effective only if the Sponsor made the equity injection (the supplementary prospectus defines the Sponsor as Sandstone Bidco Limited); relying on Mr Ledger's evidence, the judge found a high degree of likelihood that the Sponsor would become unconditionally obliged to make it. He took into account a £1,000 consent fee for each creditor acceding to the lock-up agreement and found that it could have made no realistic difference to the vote. [src-057] [src-017]
- Documented: In the MidCo Scheme, CBA, the lender of record under the MidCo Facility Agreement, had been thought at the convening stage to oppose the scheme but voted its rights in favour; by the time of the meeting it had agreed to sell its interest in the facility to Bank of America Europe Designated Activity Company (the 'New Lender'), whose transfer completed too late for it to vote. Before the sanction hearing of 9 October 2025 the New Lender confirmed its support for the MidCo Scheme on its own behalf and for the other parties with an economic interest in the facility, and undertook not to frustrate it. The Find Case Law summary of the convening judgment identifies the borrower ('BorrowerCo') as Greensands Finance Limited, the MidCo Scheme company being Greensands Financing Plc. [src-057] [src-103]
- Documented: In finding that creditors could reasonably approve the MidCo Scheme, the judge noted projections that holders of MidCo Scheme debt could realistically expect 100% recovery under the scheme, against perhaps as little as 2.4% in the comparator scenario. He also approved the scheme's provisions releasing directors, noting that they preserved an insolvency office-holder's right to bring claims against advisers and directors. [src-057]
- Documented: On 2 October 2025, two days after the SWS Scheme meetings, SW (Finance) I plc issued £100 million of bonds (the 'Tap Bonds') that would not be bound by the SWS Scheme; according to the sanction judgment, their beneficial owners instructed the security trustee to execute the same amendment agreement, so that their terms were altered by contract in the same way as the scheme debt. [src-057]
- Analysis: The sanction judgment records that 'Mr Ledger' chaired the four SWS Scheme class meetings of SWS Holdings Limited on 30 September 2025, provided the chairperson's report and gave witness statements on both schemes. The judgment gives no first name. Companies House lists Stuart Neil Ledger as a director of SWS Holdings Limited and of Greensands Financing Plc, the two scheme companies, and the 2025–26 annual report names Stuart Ledger as Southern Water's Chief Financial Officer; on that basis this dossier identifies the chairperson as Stuart Neil Ledger, a director of SWS Holdings Limited in September 2025. [src-057] [src-037]
  - Qualification: Identification by surname, office and role in the scheme companies; the judgment itself does not give his full name.
- Documented: The 2025–26 annual report states that, as a result of changes to the Common Terms Agreement implemented in October 2025, the agreement no longer provides for a standalone event of default if two of Fitch, Moody's and S&P downgrade the Class A debt below investment grade. It also states that a credit-rating Trigger Event was continuing because at least two ratings were at or below BBB/Baa2, which prevents the company from paying dividends to its shareholders, and that the company expected to leave the debt-covenant Trigger Event when it submitted its compliance certificate to lenders at the end of July 2026. [src-059]
- Documented: The 2025–26 annual report states that after the restructuring the investors of Sandstone Bidco Limited (SBL) injected £505.0 million of equity into the group in November 2025 and a further £395 million in March 2026, all received indirectly by Southern Water, bringing total investment into the group since 2021 to over £2.5 billion; none of the proceeds were paid to the existing shareholders of Greensands Holdings Limited. SBL also committed a further £300 million of binding equity to be drawn on or before 31 March 2027, to support a reduction in net debt to regulatory capital value from about 74% at 31 March 2025 to 65% from 2029. Ofwat's September 2026 consultation likewise states that in March 2026 Southern Water announced the receipt of new equity totalling £900 million from SBL, via funds managed by Macquarie Asset Management. [src-059] [src-020]
- Documented: The same report records that the second equity injection after the 2021 Macquarie purchase, £550 million made in October 2023, was split between £375.0 million injected into Southern Water Services and £175 million retained in group companies to support interest payments on external debt. [src-059]
- Documented: Companies House's filing history for Southern Water Services Limited records allotments of shares on 13 November 2025 (statement of capital GBP 37,776,665, filed 21 November 2025) and on 31 March 2026 (GBP 37,976,665, filed 16 April 2026). The 2025–26 annual report's share notes state that 100,000 ordinary shares were issued to SWS Holdings Limited on 13 November 2025 at £5,050 each (premium £504.9 million), and two further blocks of 100,000 ordinary shares on 26 March 2026 at £1,500 each (premium £149.9 million) and at £2,338.31 each (premium £233.7 million). Its statement of changes in equity shows shares issued in 2025–26 of £822.4 million (£0.3 million share capital and £822.1 million premium), the addition to share premium being shown net of issue costs of £66.4 million. [src-040] [src-059]
- Unresolved: The date of Southern Water Services Limited's second 2025–26 share issue differs between the records: the annual report gives 26 March 2026 for both March blocks of shares issued to SWS Holdings Limited, whereas the Companies House filing history describes the return as a statement of capital following an allotment of shares on 31 March 2026. [src-040] [src-059]
  - Qualification: Only the filing-history description of the March 2026 return was retained, not the form itself; neither record explains the difference.
- Documented: Earlier entries in Southern Water Services Limited's filing history show a statement of capital of GBP 176,665 on 22 July 2022 (form SH02, filed 2 May 2024) and, after an allotment of shares on 19 October 2023, a statement of capital of GBP 37,676,665 (second filing RP04SH01, filed 5 May 2024). [src-040]
- Analysis: The dates of these capital filings coincide with funding events described elsewhere: the 19 October 2023 allotment falls in the month in which the 2025–26 annual report places the £375.0 million equity injection into Southern Water Services, and the SH02 statement of capital dated 22 July 2022 bears the date on which, according to the annual accounts of Southern Water (Greensands) Financing plc, the Southern Water Services board approved a distribution to Southern Water Capital Limited that included a partial redemption of preference shares. [src-040] [src-059] [src-104]
  - Qualification: Date comparison only; the filing-history entries do not state the purpose of the allotment or of the SH02 statement.
- Documented: Sandstone Water Holdings Limited (company number 16482350), which the 2025–26 annual report describes as a parent company of Greensands Junior Finance Limited whose principal investors are funds managed by Macquarie Asset Management, filed statements of capital following allotments of shares on 13 November 2025 (GBP 50,000) and 31 March 2026 (GBP 81,376), the same dates as Southern Water Services Limited's allotments. It registered a charge (164823500001) created on 13 November 2025, filed on 18 November 2025, and a statement of satisfaction of that charge in full was filed on 3 July 2026. [src-022] [src-059]
- Documented: A return of allotment (SH01) for Sandstone Water Holdings Limited, signed for Alter Domus (UK) Limited, reports an allotment of 20,345 ordinary shares of £1 each, after which 101,725 ordinary shares of a single class were in issue, ranking equally for voting, dividends and distributions on a winding-up. The filing history dates this allotment to 12 August 2026 (statement of capital GBP 101,725.00, filed 21 August 2026); another allotment on the same day took the capital to GBP 81,380. The form does not name the subscriber. [src-038] [src-022]

## Southern Water's debt, results and credit ratings

- Documented: Companies House's register of charges for Southern Water Services Limited, as retrieved for this review, shows four registered charges, three outstanding and one satisfied. [src-039]
- Documented: The most recent registered charge, code 0236 6670 0004, was created on 30 September 2022 and delivered on 12 October 2022 in favour of Deutsche Trustee Company Limited (and its successors in title and permitted transferees); the register describes it as containing a fixed charge and lists it as outstanding. [src-039]
- Documented: Two charges created on 23 July 2003 remain listed as outstanding: a security agreement (delivered 7 August 2003) giving fixed and floating charges over the company's undertaking, and a security trust and intercreditor deed (delivered 6 August 2003), both in favour of Deutsche Trustee Company Limited as security trustee for itself and the secured creditors. For both, the register notes that part of the property or undertaking no longer forms part of the charge. [src-039]
- Documented: An earlier debenture created on 28 June 2002 (delivered 9 July 2002) in favour of The Royal Bank of Scotland PLC as trustee for the secured parties is shown as satisfied on 3 September 2003. [src-039]
- Documented: SW (Finance) I PLC (company number 13677506) is a non-trading financing company whose parent is Southern Water Services Limited. Under their loan agreement it on-lends to Southern Water Services Limited an amount equal to each bond or other debt it raises externally, at the same interest rate and on the same repayment terms. Its annual report for the year ended 31 March 2026 shows loans to Southern Water Services Limited of £6,941.0m (2025: £5,280.4m), long-term borrowings of £6,654.1m (2025: £4,943.1m), and finance income from the loan to Southern Water Services Limited equal to its finance costs, £427.3m (2025: £335.6m). [src-045]
- Documented: At 31 March 2026 SW (Finance) I PLC's loans and other borrowings totalled £6,955.5m (2025: £5,294.9m): Class A bonds of £6,045.6m (2025: £4,418.3m), including three issues with no balance a year earlier (£750m 6.875% fixed rate 2032, £625m 5.750% fixed rate 2030 and £450m 6.125% fixed rate 2033), while the £350m 6.640% 2026 bond, carried at £351.8m a year earlier, no longer appeared; two index-linked 'Artesian' loans from SW (Finance) II Limited of £473.5m (£165m 4.076% 2033) and £421.9m (£156.5m 3.635% 2032); and a £14.5m reserve facility. £301.4m fell due within one year. [src-045]
- Documented: SW (Finance) I PLC's report for the year ended 31 March 2026 states that these loans are guaranteed and secured under a guarantee and security agreement (the Security Agreement) over the entire property, assets, rights and undertaking of each of Southern Water Services Limited, SW (Finance) I Plc, SW (Finance) II Limited, SWS Holdings Limited and SWS Group Holdings Limited, in the case of Southern Water Services Limited to the extent permitted by the Water Industry Act 1991 and its licence. [src-045] [src-091]
  - Qualification: The 2020-21 annual report of the group's then parent describes the financing group's security as a charge over the share capital of SWS Group Holdings, with no security over Southern Water's individual regulated operating assets; the records do not reconcile the two descriptions.
- Documented: Events after the balance-sheet date reported by SW (Finance) I PLC: on 24 April 2026 Southern Water Services Limited repaid the £14.5 million reserve facility on its behalf; on 14 May 2026 SW (Finance) I PLC issued a new £300 million 6.875% bond maturing on 14 November 2034 and advanced the same amount to Southern Water Services Limited on identical terms, and on the same day Southern Water Services Limited repaid £181.0 million of intercompany debt, which the issuer used to buy back for cancellation, through a public tender offer, £181.0 million of its A14 bond maturing on 30 March 2027. [src-045]
- Documented: SW (Finance) I PLC's report for the year ended 31 March 2026 names Stuart Ledger and Richard Manning as the directors who served during the year and up to the date of signing, Richard Manning as company secretary in the period and at signing, HSBC Bank Plc as its bankers and Deloitte LLP as its auditor; Deloitte states that it was appointed by the board on 10 June 2022 to audit the financial statements for the year ending 31 March 2023 and later periods, and its report is dated 29 July 2026. [src-045]
- Documented: SW (Finance) I PLC's report states that on 28 July 2026 Fitch Ratings upgraded the company's senior secured debt rating from BBB- to BBB (stable outlook), reflecting sustained equity support from Macquarie Asset Management and, latterly, Asterion Industrial Partners as announced on 22 June 2026, an ongoing operational turnaround, improved outcome delivery incentives and environmental performance, and an improved Competition and Markets Authority appeal outcome. [src-045]
- Documented: The key highlights of Southern Water's annual report for the year ended 31 March 2026 show total revenue of £1,443.2m (2024–25: £992.7m; 2023–24: £886.5m), capital investment of £1,167.1m (2024–25: £976.6m) and no external dividends; the report states that Southern Water Services has paid no dividends to external shareholders since 2017–18, and records additional investment into the group by shareholders of £900 million, with a further £300 million committed after the year end. [src-059]
- Unresolved: The 2025–26 annual report gives two figures for the company's loss for the year ended 31 March 2026. Its key highlights show a loss for the financial year of £(112.6)m (2024–25: £(99.0)m; 2023–24: £(229.6)m). The audited income statement shows operating profit of £304.2m (2024–25: operating loss of £(17.4)m), net finance costs of £(445.3)m including fair-value losses on derivatives of £(138.4)m, a loss before taxation of £(139.4)m, a tax credit of £11.1m and a loss for the financial year of £(128.3)m (2024–25: £(99.0)m); the statement of changes in equity also uses £(128.3)m. [src-059] [src-065]
  - Qualification: Both figures appear in the same published report and the record does not reconcile them; the audited primary statements use £(128.3)m.
  - Response: According to a press report of 28 July 2026, Southern Water accepted that the £112.6 million figure was wrong, the audited income statement putting the loss at £128.3 million.
- Documented: The same highlights give a regulatory capital value of £8,391.5m at 31 March 2026 (2024–25: £7,449.7m; 2023–24: £6,787.6m), a ratio of net debt to regulatory capital value of 67%, and a total shareholder return for the regulated business of -4.7% for 2025–26. [src-059]
- Documented: Note 32 of the 2025–26 accounts analyses the company's net debt at 31 March 2025 as £6,702.8m, comprising cash and cash equivalents of £557.0m, derivative financial instruments of £(1,488.0)m net, borrowings due within one year of £(365.0)m, borrowings due after one year of £(5,365.3)m, leases of £(41.7)m and smaller items for unamortised issue costs and gilt-lock proceeds. [src-059]
- Documented: In assessing going concern, the directors of Southern Water Services Limited cite liquidity of £2,205.8 million at 31 March 2026 (2025: £629.0 million): cash on hand of £1,158.8 million (2025: £557.0 million), cash on deposit of £125.0 million (2025: nil), committed undrawn bank facilities of £422.0 million (2025: £72.0 million) and a committed undrawn bond backstop facility of £500 million. [src-059]
- Documented: The financial statements of Southern Water Services Limited for the year ended 31 March 2026 were approved by the board and authorised for issue on 15 July 2026 and signed on its behalf by Stuart Ledger, Chief Financial Officer. The statement of changes in equity shows no equity dividends paid in 2024–25 or 2025–26. [src-059]
- Unresolved: The 2025–26 annual report describes Moody's rating of the Class A debt inconsistently. A ratings panel shows Standard & Poor's at BBB- (negative outlook), Fitch at BBB- (stable outlook) and Moody's at Ba1 (stable outlook), while the adjacent text says the Class A debt is currently rated BBB- stable by Fitch, Baa3 negative by Moody's and BBB- negative by S&P; the report adds that in November 2025 S&P removed its CreditWatch and placed the company on negative outlook. Deloitte's going-concern key audit matter in the same report states that one of the three ratings was already below investment grade. [src-059] [src-065]
  - Qualification: On Moody's scale Ba1 is below investment grade and Baa3 is the lowest investment-grade rating. The report states that the ratings on its panel are as at the date of publishing the accounts, which points to Ba1; the adjacent text is not explained. The supplementary prospectus of July 2025 gave Moody's rating as Ba1 (stable).
  - Response: According to a press report of 28 July 2026, the company said that the correct Moody's rating was Ba1 with a stable outlook; the report added that the company's Annual Performance Report records Ba1 stable.
- Documented: Deloitte LLP is the statutory auditor of Southern Water Services Limited. The supplementary prospectus of 30 July 2025 states that Deloitte audited the company's accounts without qualification for the year ended 31 March 2024, and without qualification but with an emphasis of matter on material uncertainty for the year ended 31 March 2023. Deloitte signed the auditor's report on the 2025–26 financial statements on 15 July 2026, and the directors' report states that it will be re-appointed for the year ending March 2027. [src-017] [src-059]
- Attributed: A company-information aggregator, summarising the accounts for the year to 31 March 2026 filed on 10 September 2026, gives Southern Water Services Limited's turnover as £1.44B, cash in bank as £1.16B, total assets as £11.11B, total liabilities as £9.5B and net assets as £1.61B, with an employee count shown as 3K and a 'debt ratio' of 86%, and notes three outstanding charges. [src-028]
  - Qualification: Rounded figures from an aggregator's summary of the filed accounts; the debt ratio is the aggregator's own measure.
- Documented: SWS Holdings Limited (company number 04324499), a non-trading holding company for Southern Water Services Limited whose immediate parent is SWS Group Holdings Limited, reported in its accounts for the year ended 31 March 2022 that it received no dividends from Southern Water Services Limited in that year (previous year: £4.0m) and paid none to SWS Group Holdings Limited (previous year: £4.0m). Its net assets of £437.6m (2021: £46.3m) consisted of its investment in Southern Water Services Limited, which recorded a loss of £761.5m for the year to 31 March 2022 and had net assets of £589.0m at that date. [src-089]
- Documented: The same accounts of SWS Holdings Limited, approved on 29 July 2022, state that its share capital had been provided as security under a fixed charge for the borrowings of Southern Water Services (Finance) Limited and Southern Water Services Limited. [src-089]
- Documented: The accounts of Southern Water (Greensands) Financing plc (company number 07581353) for the year ended 31 March 2022 record that on 22 July 2022 the board of Southern Water Services Limited approved a distribution of £17.5m to Southern Water Capital Limited, comprising a partial redemption of preference shares of £5.3m including accrued interest and a payment of £12.3m of outstanding accrued preference-share interest, to facilitate interest payments at the 'Midco' and 'Holdco' levels over the following 12 months. [src-104]
- Documented: The same accounts describe Southern Water (Greensands) Financing plc, whose immediate parent was Greensands (UK) Limited, as a non-trading financing company for Greensands Senior Finance Limited. Its facility agreements of £75m, £150m, £100m and £250m, maturing in 2025 and 2026 and on-lent to Greensands Senior Finance Limited, stood at £390.8m at 31 March 2022 (2021: £723.8m), after £353.8m of £736.1m of external loans was repaid early following Macquarie Asset Management's acquisition of a majority stake in September 2021. The facilities were guaranteed under a group Security Agreement over the property of Southern Water Services Limited, Southern Water Services (Finance) Limited, SWS Holdings Limited and SWS Group Holdings Limited (for Southern Water Services Limited, to the extent permitted by the Water Industry Act 1991 and its licence). [src-104]
- Documented: According to the supplementary prospectus of 30 July 2025, Ofwat's PR24 final determination for 1 April 2025 to 31 March 2030, published on 19 December 2024, gave Southern Water Services Limited a total expenditure allowance of £8.6 billion (about £8 billion subject to cost sharing), 11% lower than in the company's draft determination response, and removed the 'inadequate' categorisation and £54 million financial penalty because the company had improved its plan. It allowed £6.6 billion to be collected through bills over 2025–30, increasing average household bills by £221 (53%) between 2024–25 and 2029–30 before inflation. The company's board asked Ofwat to refer the final determination to the Competition and Markets Authority, which obtained an extension of its deadline to 17 March 2026. [src-017] [src-045]
  - Outcome: SW (Finance) I PLC's 2025–26 report and the company's 2025–26 annual report state that the CMA's redetermination was published on 10 March 2026.
- Documented: On 5 November 2025, publishing its Monitoring Financial Resilience report for 2024–25, Ofwat said that Thames, Southern and South East were in cash lock-up under their licences and could not pay dividends without Ofwat's consent. The table in the same press release lists 'South East and Southern' together with Thames against the 'Action Required' financial-resilience status, for which Ofwat's monitoring approach is 'Active'. [src-115]
  - Qualification: The table was retained as extracted text, with 'South East and Southern' on a separate row following the 'Action Required' row.
- Documented: The equity totals differ by source and scope. In a press release of 22 June 2026, Asterion Industrial Partners said the new capital followed £900 million of equity committed during 2025 and would complete the £1.2 billion package announced in July 2025, and that with the over £1.65 billion invested since Macquarie Asset Management's initial acquisition in 2021, total equity investment in Southern Water stood at more than £2.8 billion; it also said more than £1.1 billion had been invested in the first year of the 2025–2030 regulatory period. Southern Water's 2025–26 annual report states that MAM-managed funds invested over £1.6 billion into the group between 2021 and 2023 and that total investment into the group since 2021 was over £2.5 billion after the £900 million of 2025–26, before the further £300 million commitment. [src-048] [src-059]
- Attributed: A press report of 22 June 2026 stated that a consortium led by Macquarie Asset Management was providing an additional £300 million of equity to Southern Water, which the report said came from funds managed by Asterion Industrial Partners, and that this would bring total equity investment in Southern Water by funds managed by Macquarie Asset Management and co-investors since the acquisition to more than £2.8 billion. The report also said Southern Water's debt had been reported at about £9 billion as of July 2025, and that in March 2026 Southern Water was among five UK water companies not allowed to raise bills by as much as they had requested following a Competition and Markets Authority decision. [src-095] [src-020]
  - Qualification: Press account; the £9 billion debt figure is attributed by the report to another news organisation and is not a figure from the company's accounts.
  - Outcome: Ofwat's consultation of September 2026 states that, after the European Commission cleared the acquisition in July 2026, the transaction completed in August 2026 with Asterion taking a 20% minority shareholding in the group, and that the £300 million equity commitment is expected to be drawn down in full on or around 31 March 2027.

## Asterion's 20% stake in Southern Water, 2026

- Documented: SW (Finance) I PLC's financial statements for the year ended 31 March 2026 state that on 22 June 2026 the Southern Water group announced a further £300 million of committed equity from Sandstone Bidco Limited, to be drawn down on or around 31 March 2027. Subject to EU Merger Regulation clearance, the majority of this commitment was to be funded by subscriptions for new shares in the Southern Water group by Asterion Industrial Partners, described as an independent European infrastructure investment manager headquartered in Madrid, and the balance by funds managed by Macquarie Asset Management. Following completion Asterion was to become a new indirect minority shareholder of the group, with MAM-managed funds remaining the majority shareholder. [src-045]
- Attributed: According to Asterion Industrial Partners' press release of 22 June 2026, Asterion joined the consortium led by Macquarie Asset Management as a new minority shareholder with approximately 20 per cent in Southern Water, committing the majority of the £300 million of equity investment, subject to customary regulatory approvals. The release says the new capital completes the £1.2 billion equity support package announced by the company in July 2025 and marks Asterion's entry into the UK water sector. A press report the same day, citing Macquarie, said Asterion would acquire a 20% stake in Southern Water, subject to regulatory approval. [src-048] [src-095] [src-041] [src-020]
  - Qualification: Announcement by the investor itself, made before EU merger clearance and completion. Ofwat and the group's financial statements describe the stake as a minority shareholding in the group (a holding company of Southern Water), not a direct shareholding in Southern Water Services Limited.
  - Outcome: On 20 July 2026 the European Commission decided not to oppose the notified concentration, and Ofwat's consultation of September 2026 states that the transaction completed in August 2026 with Asterion taking a 20% minority shareholding in the group; the equity commitment is expected to be drawn down in full on or around 31 March 2027.
- Attributed: In the same press release Martin Bradley, described as Senior Managing Director at Macquarie Asset Management, said that the additional £300 million of equity support delivered the full £1.2 billion investment package announced in 2025 and welcomed Asterion Industrial Partners as a new minority shareholder in Southern Water. [src-048] [src-095]
  - Qualification: Statement by a representative of the majority investor's manager; his title is as given in the release of 22 June 2026.
- Attributed: Asterion's press release of 22 June 2026 quotes Jesús Olmos, described there as CEO and Founding Partner of Asterion Industrial Partners, saying the investment provides primary capital for Southern Water's capital programme and marks Asterion's entry into a new sector in one of its core geographies. A press report the same day called him "AIP Chief Executive" when quoting the same statement. [src-095] [src-048]
  - Qualification: His titles here are those used by Asterion's release and by the press report in June 2026. Spain's CNMV register lists him as chairman (presidente), director and consejero delegado (managing director) of Asterion Industrial Partners SGEIC, S.A.
- Documented: On 22 June 2026 the European Commission received notification of a proposed concentration, case M.12488 – ASTERION / MACQUARIE / SOUTHERN WATER, published in the Official Journal (C/2026/3488) on 1 July 2026 as a candidate case for the simplified procedure. The undertakings concerned were Asterion Industrial Partners, SGEIC, S.A. (Spain); MSCIF Sandstone Ventures S.à r.l (Luxembourg), controlled by Macquarie Group Limited (Australia); and Southern Water Services Limited, controlled by Macquarie Group Limited. According to the notice, Asterion and Macquarie Group Limited would acquire joint control of Southern Water by way of purchase of shares. [src-024] [src-020]
  - Qualification: The notice gives the notified description of the transaction; it does not state the size of Asterion's stake or the rights on which joint control rests. Ofwat and the company describe Asterion's interest as a 20% minority shareholding in the group.
- Documented: On 20 July 2026 the European Commission decided not to oppose the notified concentration M.12488 – ASTERION / MACQUARIE / SOUTHERN WATER, by which Asterion Industrial Partners and Macquarie Group Limited were to acquire joint control of Southern Water Services Limited, and declared it compatible with the internal market under Article 6(1)(b) of the EC Merger Regulation. The decision was published in the Official Journal (C/2026/4127) on 28 July 2026. [src-041] [src-024]
- Documented: Ofwat, notified of a change in ownership affecting Southern Water Services Limited, opened a consultation on 23 September 2026 on whether any issues arise from the change of control, asking for views on its assessment of the new owner and on its identification of the Ultimate Controllers. The consultation closes on 30 October 2026. Ofwat states that a new investor has taken a substantial minority stake in a holding company of Southern Water and in its view meets the licence definition of an Ultimate Controller. [src-019] [src-020]
  - Outcome: The consultation was still open when the evidence was collected in October 2026; no outcome is in the record.
- Documented: Ofwat's September 2026 consultation states that in June 2026 Southern Water announced the additional £300 million equity commitment, the majority to be funded by the new investor Asterion through subscriptions for new shares and the balance by MAM-managed funds; that the commitment was unconditional except for EU merger clearance in respect of Asterion's investment; that the European Commission cleared the acquisition in July 2026; and that the transaction completed in August 2026 with Asterion taking a 20% minority shareholding in the group. The commitment is described as binding and expected to be drawn down in full on or around 31 March 2027. [src-020]
- Documented: Ofwat identifies the new investor in Southern Water as funds managed by Asterion Industrial Partners SGEIC, S.A., registered in Madrid and regulated by Spain's financial regulator, the CNMV, under register number 138. Ofwat describes Asterion as an independent European infrastructure investment manager established in 2018 and headquartered in Madrid; it states that Southern Water is the fund's first direct investment in an appointed water and sewerage undertaker in England and Wales and that, apart from Southern Water, Asterion has no investment or other interest in any other UK water business. Ofwat concluded that Asterion is a credible and experienced minority shareholder. [src-020]
  - Qualification: Ofwat's assessment rests on information provided by the new owner and Southern Water and on Ofwat's own review of public information; Asterion confirmed to Ofwat that it is not aware of any actual or perceived conflicts of interest.
- Documented: According to Ofwat, Asterion Industrial Infra Fund III, FCR is the legal holder of the minority (20%) investment in Southern Water. The fund is a pool of assets without legal personality, with a diverse investor base and no single majority investor; under Spanish law its management, representation and powers of control are vested in Asterion Industrial Partners SGEIC, S.A., which Ofwat describes as exercising effective control over the fund without owning it. [src-020]
- Documented: In the same consultation Ofwat states that Macquarie Super Core Infrastructure Fund SCSp, Macquarie Asset Management Europe Sarl and Sandstone Water Holdings Limited, already identified as Ultimate Controllers of Southern Water, have each provided compliant undertakings, that their role as Ultimate Controllers is unaffected by the change in ownership and that their undertakings remain in place; and that Asterion Industrial Infra Fund III, FCR is the legal holder of a large minority investment (a 20% shareholding) in Southern Water, with all management, representation and control powers in respect of the fund vested in Asterion. [src-020]
  - Qualification: Ofwat does not give the dates on which the three were first identified as Ultimate Controllers.
- Documented: Ofwat describes Sandstone Water Holdings Limited as the last UK holding company of the Southern Water group and the company through which funds are invested in Southern Water. Certain matters are reserved to its board and shareholders, and under a shareholders' agreement certain investors, including Asterion, have a right to nominate one or more non-executive directors for appointment to the board of Southern Water. [src-020]
  - Qualification: Ofwat does not name the parties to the shareholders' agreement other than Asterion, nor the holding company in which Asterion's fund holds its 20%.
- Documented: Ofwat's consultation identifies Asterion Industrial Partners SGEIC, S.A. as an Ultimate Controller of Southern Water Services Limited, because of its effective control over the fund and its right to nominate representation on Southern Water's board, which make it a person able to exert material influence over Southern Water. Asterion provided the required Ultimate Controller undertakings to Southern Water dated 12 August 2026, which Ofwat considers compliant with the licence. Ofwat identified no other new Ultimate Controllers and no issues under its board leadership, transparency and governance principles. [src-019] [src-020]
  - Qualification: Stated in a consultation that invites views on the identification of the Ultimate Controllers.
  - Outcome: The consultation closes on 30 October 2026, after the evidence cutoff; no final decision is in the record.
- Documented: Ofwat states that Asterion's senior leadership brings direct UK water-sector expertise, with several team members having previously held key roles at South Staffordshire Plc, including the positions of CEO and Chairman. [src-020]
  - Qualification: Ofwat does not name these team members.
- Documented: Sandstone Water Holdings Limited (company number 16482350) filed a confirmation statement made up to 28 May 2026 showing 81,376 ordinary shares, all held by MSCIF Sandstone Ventures S.à r.l. Its Companies House filing history then records two statements of capital following allotments of shares on 12 August 2026: one filed on 12 August 2026 showing share capital of GBP 81,380, and one filed on 21 August 2026 showing GBP 101,725.00. A resolution adopting new articles of association and the new memorandum and articles were filed on 21 August 2026. [src-022] [src-023]
- Analysis: Analysis: the Companies House filings of Sandstone Water Holdings Limited are consistent with Asterion's fund having taken its 20% by subscribing for new shares in that company. The return of allotment filed on 21 August 2026 records 20,345 ordinary shares of £1 allotted on 12 August 2026, after which 101,725 shares were in issue; 20,345 is exactly one fifth (20%) of 101,725. Before the August allotments MSCIF Sandstone Ventures S.à r.l. held all 81,376 shares, and Ofwat describes Sandstone Water Holdings as the company through which funds are invested in Southern Water and reports that the transaction completed in August 2026 with Asterion taking a 20% minority shareholding. [src-038] [src-022] [src-023] [src-020]
  - Qualification: The return of allotment does not name the allottee, the retained records contain no later shareholder list of Sandstone Water Holdings, and Ofwat does not name the holding company in which the stake is held; the identification of this allotment with Asterion's stake is an inference from the matching size and date.
- Documented: On 12 August 2026 Companies House recorded the appointment of Martin Bradley, Neil Robert Vint Corrigall, Adrian Peter Page and Stephen Glynn Hurrell as directors of Sandstone Water Holdings Limited, and the termination on the same day of the directorships of Catherine Isabelle Harber (director since 29 May 2025), Pooja Hitesh Shah (director since 3 March 2026) and William David George Price (director since 20 December 2025). The four directors appointed on 12 August 2026 are listed as active on the officers register retrieved in October 2026. [src-022] [src-111]
- Documented: Companies House's officers register for Sandstone Water Holdings Limited lists Alter Domus (UK) Limited as company secretary since 13 November 2025, and two earlier directors: Richard Greenleaf (29 May 2025 to 3 March 2026) and Susana Durante Teixeira Gomes Leith-Smith (29 May 2025 to 20 December 2025). On 22 December 2025 the company's registered office moved from Ropemaker Place, 28 Ropemaker Street, London to care of Alter Domus (UK) Limited, 30 St Mary Axe, London. [src-111] [src-022]
- Documented: Companies House lists William David George Price as a director of Sandstone Midco Limited (company number 16482495), Sandstone Bidco Limited and Sandstone Water Holdings Limited from 20 December 2025 until his resignation on 12 August 2026. [src-049] [src-111]
- Documented: Southern Water's annual report for the year ended 31 March 2026, in the chair's statement dated 15 July 2026, states that Martin Bradley and Steve Hurrell will join the Southern Water board as investor-nominated non-executive directors once Ofwat's new fitness and propriety processes are completed, and that following the recent equity transaction Asterion Industrial Partners are expected to nominate a non-executive director. The same report describes Will Price as an investor-nominated non-executive director who receives no fees from the company. [src-059]
  - Qualification: A statement of intention as at July 2026. The retained records do not show whether, or whom, Asterion has nominated to Southern Water's board.
- Documented: Asterion's website, on the page of its Southern Water press release retrieved in October 2026, describes Adrian Page as an Industrial Advisory Board member at Asterion Industrial Partners who was Group CEO, having previously been CFO, of South Staffordshire Plc, a UK water company. [src-048]
  - Qualification: The website gives the name "Adrian Page" only; the identification with Adrian Peter Page of the Companies House records is set out separately as an analysis. The page does not say that he holds any role in the Southern Water group.
- Documented: A Companies House officer record for Adrian Peter Page lists him as a director of South Staffordshire Water Plc (company number 02662742) from 1 July 1998 and of South Staffordshire Limited (04295398) from 4 December 2003, both until 29 April 2020; as a director of Waterflo Limited and Brightwater Limited from July 2019 to 29 April 2020; and as a director of Energy Assets Group Holdings Limited (12390729) since 2 July 2021, listed as active on the record retrieved in October 2026. [src-110]
- Analysis: Analysis: the dossier treats the Adrian Peter Page appointed a director of Sandstone Water Holdings Limited on 12 August 2026, the Adrian Peter Page of a second Companies House officer record (South Staffordshire Water Plc, South Staffordshire Limited, Energy Assets Group Holdings Limited) and the "Adrian Page" whom Asterion's website lists as an Industrial Advisory Board member as one person. The basis is that the two Companies House records give the same full name and the same partial date of birth (not reproduced here), and that the website's career description (Group CEO and earlier CFO of South Staffordshire Plc) matches the second record's directorships of South Staffordshire Water Plc and South Staffordshire Limited until April 2020. Ofwat separately states, without naming them, that several Asterion team members previously held key roles at South Staffordshire Plc. [src-111] [src-110] [src-048] [src-020]
  - Qualification: No source states that Adrian Peter Page was appointed to the board of Sandstone Water Holdings as Asterion's nominee or that he represents Asterion; the records show only that his appointment was registered on the same day as the other board changes and share allotments of 12 August 2026.

## Asterion Industrial Partners: owners and managers

- Documented: Spain's securities regulator, the CNMV, lists Asterion Industrial Partners, SGEIC, S.A. (tax identification number A88155247) in its register of venture capital management companies under official register number 138, registered on 20 September 2018. [src-046]
- Documented: The CNMV register's board-of-directors view for Asterion Industrial Partners, SGEIC, S.A. (data date 14 September 2026, retrieved in October 2026) lists Jesús Olmos Clavijo as director (consejero), consejero delegado (managing director) and chairman (presidente), each effective from 20 September 2018; Winnie Wutte as director from 20 September 2018; and Guido Mitrani as director from 8 April 2019. For members of the first board the register gives the date of the company's registration with the CNMV. [src-046]
  - Qualification: Listed as current on the register retrieved in October 2026. Asterion's own release and a press report describe Olmos as CEO or Chief Executive; the CNMV register uses the titles above.
- Documented: The CNMV register's shareholders view for Asterion Industrial Partners, SGEIC, S.A. lists three partners with holdings of 5% or more, calculated on total shares: "ANDROVANDI DE INVERSIONES Y SERVICIOS S.L." with 48.40%, Warrington Investments, S.L. with 23.30% and Selfina Inversiones, S.L. with 23.30%. None of the listed holdings exceeds half of the shares. [src-047]
  - Qualification: The page, retrieved in October 2026, gives no date for the holdings and does not identify holders below 5%. The 48.40% holder is reproduced with the CNMV spelling; its identification with Aldrovandi de Inversiones y Servicios SL is set out separately as an analysis.
- Documented: Asterion's website describes Jesús Olmos Clavijo as a Founding Partner and CEO of Asterion Industrial Partners and a member of its Investment Committee, and Guido Mitrani and Winnie Wutte as Founding Partners and members of the Investment Committee. It says that before founding Asterion, Olmos was Global Co-Head of KKR Infrastructure, Mitrani a Director at KKR Infrastructure and Wutte a Director at KKR Client & Partner Group Europe. [src-048]
  - Qualification: Self-description on the company's website, retrieved in October 2026.
- Documented: According to a business-registry aggregator's summary of BORME publications for Asterion Industrial Partners SGEIC SA, the appointments of Jesús Olmos Clavijo as chairman and director and of Winniefried Wutte as director were registered on 17 August 2018 and that of Guido Lucio Mitrani as director on 23 May 2019; Olmos Clavijo's appointment as consejero delegado was registered on 5 September 2018 and, after a cessation registered on 1 October 2024, again on 29 October 2024. On 1 October 2024 the re-election of Olmos Clavijo as chairman, of Olmos Clavijo, Wutte and Mitrani as directors and of Deloitte Auditores SL as auditor was registered. The aggregator also lists Wutte and Mitrani as holders of powers of attorney (apoderados) of the company since 11 June 2019. [src-070] [src-071] [src-069]
  - Qualification: Aggregator summary of BORME acts, matched by name; the aggregator notes that its listings may correspond to more than one person. The registration dates differ from the CNMV effective dates (20 September 2018 and 8 April 2019), which for the first board are the CNMV registration date. The names Winniefried Wutte and Guido Lucio Mitrani are those used in BORME; CNMV lists the same company's directors as Winnie Wutte and Guido Mitrani.
- Documented: The Madrid Mercantile Register entries published in BORME no. 138 of 20 July 2020 record the incorporation of Selfina Inversiones SL, registered on 10 July 2020, with operations from 3 July 2020, share capital of €3,000 and the object of holding, managing, acquiring and disposing of securities and shares in companies, investment vehicles or funds on its own account. The entry declares the company a sole-member company, names Guido Lucio Mitrani as its sole member (socio único) and appoints him sole administrator (administrador único). [src-060]
- Documented: The same BORME issue records the incorporation of Warrington Investments SL, registered on 10 July 2020, with operations from 3 July 2020, share capital of €3,006, the same object and the same registered office in Madrid as Selfina Inversiones SL. The entry declares the company a sole-member company, names Winniefried Wutte as its sole member (socio único) and appoints Wutte sole administrator (administrador único). [src-060]
- Documented: Business-registry aggregators still list Winniefried Wutte as sole member (socio único) of Warrington Investments SL and Guido Lucio Mitrani as sole member of Selfina Inversiones SL from 10 July 2020, without an end date. The aggregator's list of Warrington's published acts (2020–2025) contains a single declaration of sole-member status, that of July 2020, and no later change of sole member or loss of that status; the acts listed for Mitrani likewise include only the July 2020 declaration for Selfina. One aggregator names Wutte as the owner (propietario) of Warrington. [src-101] [src-071]
  - Qualification: Sole-member status is documented by the BORME incorporation entries of July 2020. That it continued rests only on the aggregators' lists of published acts showing no change; no current register extract or shareholder list was retrieved, so this is not confirmation of the present shareholders of either company. For Selfina the only later source is the aggregator's page for Mitrani, which lists acts naming him; a change recorded without his name would not necessarily appear there.
- Documented: According to business-registry aggregators' summaries of BORME acts, Warrington Investments SL's share capital was increased from €3,006 to €180,000 by a registration of 5 February 2021; Winniefried Wutte, its sole administrator from 10 July 2020, ceased in that role by a registration of 26 February 2021; and from a registration of 2 March 2022 the company has had two joint and several administrators (administradores solidarios), one of whom is Wutte. [src-101] [src-070]
  - Qualification: The other joint administrator, a private individual, is not named here. Wutte is listed as a current joint administrator on the aggregator pages retrieved in October 2026.
- Documented: BORME acts summarised by business-registry aggregators show that Warrington Investments SL and Aldrovandi de Inversiones y Servicios SL both moved their registered offices to C/ Príncipe de Vergara 33, 2º Derecha, Madrid, by registrations of 15 October 2025 published in the BORME of 22 October 2025. [src-101] [src-061] [src-087]
  - Qualification: The records show only the common address; they do not explain the moves or show any other relationship between the two companies.
- Documented: Business-registry aggregators' summaries of BORME acts describe Aldrovandi de Inversiones y Servicios SL (tax identification number B85610962) as a company registered with the Madrid Mercantile Register, incorporated by deed of 20 January 2009 under the name Inversiones Aldrovandi SL and renamed by a registration of 30 April 2018. Its object covers business consultancy and, since a registration of 23 October 2019, the purchase, holding, management and sale of securities and shares in any type of company. Jesús Olmos Clavijo was registered as its sole administrator on 30 April 2018, was one of two joint administrators from 27 April to 15 June 2020, and has been sole administrator again since a registration of 15 June 2020. Its share capital, €150,000 after registrations of 30 April 2018, was increased to €834,920 (registered 27 April 2020), €6,334,920 (22 June 2021) and €7,534,920 (11 January 2023). [src-061] [src-069]
  - Qualification: Aggregator summaries of published registry acts. None of the acts listed names the company's shareholders. Olmos Clavijo is listed as current sole administrator on the pages retrieved in October 2026; the company's earlier administrator and its proxies are not named here.
- Analysis: Analysis: the dossier identifies the holder that the CNMV lists with 48.40% of Asterion Industrial Partners, SGEIC, S.A. as "ANDROVANDI DE INVERSIONES Y SERVICIOS S.L." with Aldrovandi de Inversiones y Servicios SL (B85610962) of Madrid. The two names differ by a single letter (N in place of L in the first word); the rest of the name and the legal form (S.L.) are identical; Aldrovandi is registered in Madrid, where Asterion is also registered, and its object has included holding shares in other companies since 2019; and its sole administrator, Jesús Olmos Clavijo, is listed by the CNMV as Asterion's chairman and consejero delegado. [src-047] [src-061] [src-087] [src-069] [src-046] [src-020]
  - Qualification: No register entry or filing in the record names Aldrovandi as a shareholder of Asterion, and no retained record names Aldrovandi's own shareholders. The identification rests on the near-identical name and the common administrator; it assumes that the CNMV entry misspells the name.
- Analysis: Analysis: read together, the CNMV and BORME records indicate that the management company Asterion Industrial Partners, SGEIC, S.A. is held mainly through companies connected with its three CNMV-listed directors and founding partners: Warrington Investments SL (23.30%), whose sole member at incorporation in July 2020 was Winniefried Wutte; Selfina Inversiones SL (23.30%), whose sole member at incorporation was Guido Lucio Mitrani; and the 48.40% holder listed by the CNMV as "Androvandi", identified in this dossier with Aldrovandi de Inversiones y Servicios SL, whose sole administrator is Jesús Olmos Clavijo. The three listed holdings add up to 95.0% (48.40 + 23.30 + 23.30). The BORME names Winniefried Wutte and Guido Lucio Mitrani are taken to be the CNMV directors Winnie Wutte and Guido Mitrani because the BORME entries for Asterion's own board name Winniefried Wutte and Guido Lucio Mitrani as its directors. [src-046] [src-048] [src-069] [src-047] [src-060] [src-070] [src-071] [src-020]
  - Qualification: The register lists only holdings of 5% or more and does not attribute the remaining 5.0%. Wutte's and Mitrani's sole membership is documented only at incorporation in 2020 (later status rests on aggregator lists showing no change), and Aldrovandi's shareholders are not documented, so the records show who administers Aldrovandi, not who owns it. Ofwat states that the fund holding the Southern Water stake is controlled by Asterion without being owned by it.
- Documented: A business-registry aggregator's list of BORME acts under the name Jesús Olmos Clavijo shows, besides his Asterion positions, earlier directorships of Kohlberg Kravis Roberts (España) Asesores SL (23 April 2015 to 13 August 2018) and Acciona Energía Internacional SA (25 November 2014 to 6 April 2018), among other energy and infrastructure positions that ended in 2017 and 2018; and, more recently, the positions of director and chairman of Fivebioenergy SL (8 February 2024 to 20 March 2026) and joint administrator of Demeter Bidco SL (10 March 2026 to 24 September 2026). [src-069]
  - Qualification: Aggregator listing matched by name; the aggregator notes that it may correspond to more than one person. Dates are registration dates of the published acts.
- Documented: The Madrid Mercantile Register entry published in BORME on 20 July 2020 records the appointment of Winniefried Wutte as a director (consejero) of Marques Bidco SL, registered on 10 July 2020, when the company changed from joint administrators, one of whom was Guido Lucio Mitrani, to a board of directors. A business-registry aggregator lists Wutte as a director of Marques Bidco SL until 8 June 2023 and of Centaurus Bidco SL from 2 July 2020 to 18 February 2025. [src-060] [src-070]
  - Qualification: The aggregator listing is matched by name; dates are registration dates of the published acts. The records do not state the owners of Marques Bidco SL or Centaurus Bidco SL.
- Documented: A business-registry aggregator's list of BORME acts under the name Guido Lucio Mitrani shows him as a director of Centaurus Bidco SL from 2 July 2020 to 3 August 2023 and of Trident Bidco SL since 11 August 2023, and as sole administrator of Terraluce Real Estate SL since 19 November 2024. The BORME of 26 November 2024 records the incorporation of Terraluce Real Estate SL (operations from 7 November 2024; object: real-estate activities including letting with hotel-type services, renovation, development and construction; share capital €1,500,000), registered on 19 November 2024, as a sole-member company whose sole member is Selfina Inversiones SL, with Mitrani as sole administrator. [src-071] [src-102]
  - Qualification: The aggregator listing is matched by name; dates are registration dates. Mitrani's positions at Trident Bidco SL and Terraluce Real Estate SL are listed as current on the page retrieved in October 2026.

## Environment Agency prosecutions, 2013–2026

- Documented: According to the Court of Appeal's judgment of 23 January 2014 in R v Southern Water Services Limited ([2014] EWCA Crim 120), Southern Water Services Limited discovered in late December 2010, or at some time before 7 January 2011, that its sewage-pumping station at Margate, which discharged into the sea off the Kent coast, was faulty and was discharging untreated sewage, but did not notify the Environment Agency until 17 January 2011. Three of the four transfer pumps had failed, further untreated discharges followed until July 2011, and the company did not disclose their full extent until the Environment Agency required it to do so. [src-085]
- Documented: On 2 July 2013 Southern Water Services Limited pleaded guilty at Canterbury Magistrates' Court to contravening conditions imposed under regulations 12(1), 38(1)(a) and 39(1) of the Environmental Permitting (England and Wales) Regulations 2010 in respect of the Margate discharges, in a prosecution presented by the Environment Agency. The case was committed to the Crown Court at Canterbury, where on 23 August 2013 Her Honour Judge Adele Williams fined the company £200,000. [src-085]
  - Outcome: The company appealed against the fine; the Court of Appeal dismissed the appeal on 23 January 2014.
- Documented: On 23 January 2014 the Court of Appeal (Criminal Division) - the Lord Chief Justice, Lord Thomas of Cwmgiedd, with Mr Justice Simon and Mr Justice Irwin - dismissed Southern Water Services Limited's appeal against the £200,000 fine ([2014] EWCA Crim 120, case no. 2013/04867/A4). The court said it would not have interfered with a very substantially greater fine, recorded that the company had 160 previous offences - some minor and represented by cautions, some of strict liability - which taken as a whole it called a record of persistent offending, and said that the company's main board had apparently failed to appreciate the seriousness of the criminality involved. [src-085]
  - Response: On appeal the company argued that the failure stemmed from a design fault that would have been very difficult to anticipate and that it had caused no damage; the court accepted that there was no evidence of actual harm, but held that the company had put no evidence before the sentencing judge to explain the design fault or the delay. A statement from the company secretary told the court that no dividends had been distributed out of the profits it referred to; the court held that this was irrelevant.
  - Outcome: Appeal dismissed.
- Documented: During an Environment Agency investigation into potential breaches by Southern Water Services Limited of its obligations under the Environment Act 1995, Agency officers visited several of the company's wastewater treatment works between 11 and 13 July 2016. Five employees of the company were then prosecuted and convicted at Folkestone Magistrates' Court of intentionally obstructing Environment Agency officers, contrary to section 110(1) of the Act. The company itself was also charged with obstruction but was acquitted: the district judge found that the prosecution had not proved the company criminally liable for its employees' actions. [src-086]
  - Response: According to the High Court judgment, several of the employees told the officers that they were acting on instructions - from the company's legal team or solicitor, or from a manager - in refusing to let records be removed or the officers enter a site.
  - Outcome: On 29 January 2019 the High Court allowed the appeals of two of the five employees and quashed their convictions; the convictions of the other three were upheld ([2019] EWHC 443 (Admin)).
- Documented: On 29 January 2019 the High Court (Administrative Court; Lord Justice Leggatt and Mr Justice Holgate), hearing the five employees' appeal by case stated against the Environment Agency ([2019] EWHC 443 (Admin)), quashed the obstruction convictions of two employees because the district judge had made no specific finding that either had committed an offence by a specific act or omission, and dismissed the appeals of the other three. [src-086]
  - Response: The employees argued, among other points, that the officers' powers to enter premises and to remove records for copying could be exercised only with the occupier's consent, which the court rejected. For the two employees whose convictions were quashed, the district judge had found that they were relaying the company's position on the instructions of its lawyer or solicitor, and the High Court held that the district judge had made no finding that either had gone beyond reporting that position to obstructing the officers.
- Documented: The Crown Court's sentencing remarks of 17 July 2026 record that in December 2016 Her Honour Judge Adele Williams, then Resident Judge at Canterbury, fined Southern Water £2,000,000 for discharges from the Margate pumping station, having sentenced it for offences at the same site in August 2013, and that the company had given the court assurances in 2016 about a 24/7 staff presence at the site. [src-105]
- Documented: On 9 July 2021, in an Environment Agency prosecution at Canterbury Crown Court, Mr Justice Johnson fined Southern Water a record £90 million after it pleaded guilty to 51 offences committed between 2010 and 2015 at 16 wastewater treatment works and one storm overflow in Kent, Hampshire and Sussex. The company admitted causing 6,971 illegal discharges lasting 61,704 hours in total. The Environment Agency described the case as the largest criminal investigation in its 25-year history and said the fine would be paid out of company operating profits. [src-067] [src-105]
  - Qualification: The July 2026 sentencing remarks describe the 2021 offences as committed across 17 sites in Kent; the 2021 Environment Agency release places them in Kent, Hampshire and Sussex.
- Attributed: According to the Environment Agency, the court in the 2021 prosecution (Canterbury Crown Court, 9 July 2021) found that the offences were caused by deliberate failings causing major (Category 1) harm, and was told that Southern Water had deliberately presented a misleading picture of compliance to the Environment Agency. As quoted in the Divisional Court's judgment of 22 July 2026, Mr Justice Johnson said in sentencing that he was sure each of counts 1 to 50 had been committed deliberately, through an intentional breach of, or flagrant disregard for, the law by the company's board of directors and/or a deliberate failure by the board to put in place and enforce adequate systems. [src-067] [src-055] [src-091]
  - Qualification: The 2021 sentencing remarks themselves are not in the record; the findings are reported by the Environment Agency and quoted in a later judgment. They concern the board as a body: the 2026 judgment notes that the remarks did not identify the company's then chief executive as complicit.
  - Response: The company pleaded guilty. Before sentencing, the 2020-21 annual report of its then parent group stated that Southern Water was committed to working with the Environment Agency to ensure a swift conclusion to the case and noted that the levels of culpability and environmental harm were disputed. As quoted in the 2026 judgment, its then chairman's evidence at sentencing repeatedly emphasised that there had been a complete culture change in the company.
  - Outcome: Fine of £90 million imposed on 9 July 2021.
- Documented: The Environment Agency's release of 17 July 2026 states that three years after the 2021 fine of £90 million, Southern Water received a penalty of £330,000 for pollution in a lake near Southampton. [src-056]
  - Qualification: The release gives no court, date or offence details for the £330,000 penalty.
- Documented: The Environment Agency charged Southern Water with 13 offences arising from unpermitted discharges of untreated sewage and permit breaches at its Margate and Broadstairs wastewater pumping stations in Kent between 2019 and 2021. The company pleaded guilty at Medway Magistrates' Court on 22 April 2025, on a written basis of plea accepted by the Environment Agency, and District Judge Stephen Leake committed the case to the Crown Court for sentence. [src-056] [src-105]
  - Qualification: The Environment Agency's release states that all 13 offences were contrary to regulations 12(1)(b) and 38(1)(a) of the Environmental Permitting (England and Wales) Regulations 2016; the sentencing remarks describe counts 1-9 as discharge offences under regulation 12(1) read with 38(1)(a) of the 2016 Regulations and counts 10-13 as permit-condition offences under regulation 38(2), citing the 2010 Regulations.
  - Outcome: Sentenced at the Crown Court at Canterbury on 17 July 2026.
- Attributed: In its supplementary prospectus of 30 July 2025, Southern Water stated that at a court appointment on 22 April 2025 it had pleaded guilty to the 13 Margate and Broadstairs charges, "although two of these remain in dispute", and that it had recognised a provision of £2.0 million for possible fines and legal costs. Its annual report for the year ended 31 March 2026 states that the company pleaded guilty to the charges, that sentencing was expected later in July 2026 and that the provision was £4.5 million, and adds that other Environment Agency prosecutions over historic events were due to be progressed by the courts later in the year. [src-017] [src-059] [src-105]
  - Qualification: Company disclosures; the company said the provisions were not intended to indicate or predict any particular level of fine. The prospectus does not say which two charges remained in dispute.
  - Response: In both disclosures the company described the levels of culpability and environmental harm as disputed.
  - Outcome: On 17 July 2026 the Crown Court fined the company £7,127,083, with £149,000 prosecution costs and a £181 surcharge.
- Attributed: According to the Environment Agency, the Margate and Broadstairs offending included a discharge of around 10 million litres of sewage over almost 24 hours in July 2019, reported to the Agency only the next day; at least 16 million litres released from Margate over two days around the August 2020 bank holiday, with a further 1.6 to 3.2 million litres from Broadstairs that the company reported only weeks later; a February 2021 control failure at Broadstairs; simultaneous failures in June 2021 after which Thanet District Council closed 11 beaches; and an October 2021 power shutdown at Broadstairs after which 10 beaches were closed. The company also admitted 35 further illegal discharges between 2019 and 2021 and that a network pump had been out of action for more than a year. [src-056] [src-105]
  - Qualification: Volumes and timings are the Environment Agency's figures from its press release; the sentencing remarks give per-count volumes in cubic metres and different reporting intervals for some incidents.
  - Response: The company pleaded guilty on an agreed basis of plea and argued at sentencing that all its failings were negligent; it said the unscreened Broadstairs discharge of August 2020 occurred over half a kilometre out to sea and was diluted by rainfall.
  - Outcome: Fined £7,127,083 on 17 July 2026.
- Documented: On 17 July 2026, in Environment Agency v Southern Water at the Crown Court at Canterbury, Mr Justice Johnson sentenced Southern Water for the 13 Margate and Broadstairs offences to fines totalling £7,127,083 (imposed on counts 1, 2, 4, 5, 7, 8 and 13, with no separate penalty on the others), prosecution costs of £149,000 and a statutory (victim) surcharge of £181. The judge gave full one-third credit for the guilty pleas, stating that after a trial he would have imposed £10,690,625. Costs and surcharge were due by 14 August 2026, half of the fine (£3,563,541) by 15 January 2027 and the balance (£3,563,542) by 16 July 2027. No compensation or confiscation order was made. [src-105] [src-056]
  - Qualification: Paragraph 21.1 of the remarks gives the count 1 fine as £604,197, while the attached calculation table gives £604,167; the stated total of £7,127,083 matches the table.
- Attributed: In his sentencing remarks of 17 July 2026, Mr Justice Johnson found the company's culpability deliberate on counts 1, 5 and 10 (count 6 being treated together with count 5): after a 24/7 staff presence had been put in place at Margate as a result of the incidents behind the earlier prosecution, the company withdrew that cover in 2018 with no documented decision showing that sufficient measures were in place and no appropriate risk assessment. He assessed the other counts as negligent, and the harm on counts 5 and 6 (discharges of 16-17 June 2021, after which 11 bathing sites were closed between 17 and 23 June 2021) and on count 7 as category 1. [src-105]
  - Qualification: Findings of the sentencing court made to the criminal standard on the agreed basis of plea; the Environment Agency had argued for deliberate culpability on counts 1, 5, 6 and 10 and recklessness on count 7.
  - Response: The company argued that all its failings were negligent; it said it withdrew the 24/7 cover in 2018 because there had been a major investment programme and reliability and resilience had increased, and denied that this was a cost-saving measure. The court accepted its submission that the harm on counts 1 and 10 fell within category 3.
  - Outcome: Fined £7,127,083 on 17 July 2026.
- Documented: The sentencing remarks of 17 July 2026 record that Southern Water had 174 previous convictions, had been convicted every year from 1999 to 2016 and as recently as April 2026, and that after its August 2013 fine of £200,000 for Margate discharges (unsuccessfully appealed) it was convicted on 13 further occasions, excluding the present case, including a £2,000,000 fine for Margate discharges in December 2016 and the £90,000,000 fine of July 2021. Mr Justice Johnson treated this record as an exceptionally serious aggravating factor. [src-105] [src-085]
  - Qualification: The Court of Appeal recorded 160 previous offences in January 2014; the 174 previous convictions are the 2026 court's figure.
- Documented: In mitigation, the sentencing remarks of 17 July 2026 record that, unlike in 2021, Southern Water fully cooperated with the Environment Agency's investigation, and that Lawrence Gosden, the Chief Executive Officer of Southern Water, apologised to the court, the Environment Agency, customers and the communities of Thanet; the judge accepted the apology as genuine and indicative of remorse and took account of remedial works and the reinstatement of a 24/7 staffing model at Margate and Broadstairs. [src-105]
- Documented: On 7 April 2026 Southern Water pleaded guilty at Medway Magistrates' Court to all five charges brought by the Environment Agency under regulations 12(1)(b) and 38(1)(a) of the Environmental Permitting (England and Wales) Regulations 2016 for pollution in north Kent: sewage effluent discharged into Faversham Creek between 4 and 8 March 2020; diesel discharged to coastal waters at Whitstable on or before 31 July 2019; and untreated sewage discharged to coastal waters between 5 March and 3 October 2020, on 6 August 2021 (when around 70 dead fish were found) and between 31 July and 23 August 2021. [src-072] [src-075]
  - Outcome: On 22 September 2026 the Environment Agency announced that Southern Water had been fined £2.4 million at Bromley Magistrates' Court and ordered to pay £69,894.04 in costs and a £190 victim surcharge.
- Documented: The Environment Agency announced on 22 September 2026 that District Judge Stephen Leake, sitting at Bromley Magistrates' Court, had fined Southern Water £2.4 million (given in the release as £2,416.666.67) for the Faversham and Whitstable pollution of 2019-2021, and ordered it to pay £69,894.04 in costs and a victim surcharge of £190; a further pollution incident at Faversham in December 2019 was taken into account. The Agency called it its second successful prosecution of the company in 2026. [src-075]
- Documented: On 14 July 2026 Southern Water pleaded guilty at Medway Magistrates' Court to two Environment Agency charges under regulation 38(2) of the Environmental Permitting (England and Wales) Regulations 2016: on 13 March 2023 the discharge from its Fullerton wastewater treatment works into the River Test in Hampshire exceeded its permit limits of 50 mg/l of suspended solids and 8,000 micrograms per litre of total iron. Two further charges are to be taken into consideration at sentencing. [src-076]
  - Response: According to the Environment Agency, Southern Water noted after the incident that it had missed at least two opportunities to alert the Agency, and said it recognised that its procedure for raising concerns internally and with the Agency about effluent quality had failed before and on the day of the incident.
  - Outcome: Sentencing date to be set (Environment Agency, 15 July 2026); the record contains no sentence.
- Attributed: According to the Environment Agency, it was also prosecuting Southern Water for other pollution incidents in Kent in 2019-2021, including at Faversham and Whitstable, and in Hampshire in 2023 (release of 17 July 2026), and the company was due to appear in court in December 2026 over unrelated pollution incidents at Herne Bay, where 49 homes and businesses were flooded with sewage, near Canterbury in Kent and near Andover in Hampshire (release of 22 September 2026). [src-056] [src-075]
  - Qualification: Pending proceedings: the record contains no charges, pleas or outcomes for the Herne Bay, Canterbury and Andover incidents.
  - Response: The record contains no response from the company on these cases.
  - Outcome: The Faversham and Whitstable case was sentenced in September 2026; the record contains no outcome for the other cases, and the releases do not say whether the Hampshire 2023 case is the River Test (Fullerton) prosecution.
- Attributed: According to the Environment Agency (July 2026), its inspections that year included over 730 checks of Southern Water sites, 68% of which were compliant with their permits, and it gave the company over 400 improvement actions; in September 2026 an Agency manager said it had made 700 inspections of the company's sites in the past year, detailing 400 improvements needed. [src-076] [src-075]
  - Qualification: The two releases give slightly different inspection counts (over 730 and 700) for overlapping periods.
  - Response: The record contains no response from the company to these figures.
- Attributed: On 22 July 2026 the Environment Agency announced that it had commenced criminal proceedings against Southern Water Services Limited and former employees. Four former employees - Matthew Wright, whom the Agency describes as the company's former Chief Executive Officer, and three other former officers or senior operations managers - face a charge of conspiracy to defraud: the Agency alleges that between 1 January 2012 and 31 December 2017 they conspired to defraud the Environment Agency and Ofwat by implementing artificial no-flow events at wastewater treatment works operated by Southern Water in order to manipulate the operator self-monitoring (OSM) compliance testing regime. Conspiracy to defraud is a common-law offence with a maximum sentence of 10 years' imprisonment. Southern Water separately faces charges of breaching environmental permits linked to the same conduct, and three further individuals face charges linked to failure to comply with environmental permits. [src-054] [src-055] [src-074] [src-059]
  - Qualification: These are charges, not findings: no plea or trial is recorded. The Agency said it could not comment further on live proceedings.
  - Response: According to a press report of 11 September 2026, Mr Wright denies any wrongdoing and has cooperated with the Environment Agency's investigation, as his solicitor said after an earlier High Court hearing. In its financial statements for the year ended 31 March 2026, authorised for issue on 15 July 2026 before the charges were announced, the company said that it had continued to assist the Agency's investigation and could not yet predict how it would plead; the record contains no plea or later public statement by the company on these charges.
  - Outcome: On 11 September 2026 the defendants appeared at Bromley Magistrates' Court and the case was sent to Maidstone Crown Court, where they were due to appear on 9 October 2026; the record contains no later step.

## Ofwat enforcement, 2017–2026

- Documented: Ofwat formally investigated Southern Water from June 2017 for breaches of licence conditions and statutory obligations. In its final decision published on 10 October 2019 (press notice PN 21/19), Ofwat found that Southern Water had failed to operate a number of wastewater treatment works properly, including by not making the necessary investment in time, leading to equipment breakdowns and unpermitted spills, and that it had manipulated wastewater sampling processes, misreporting the performance of a number of sewage treatment sites and so avoiding penalties under Ofwat's incentive regime. [src-068] [src-091]
  - Qualification: Ofwat stated that its findings concerned regulatory obligations only and that it made no findings about environmental harm, site-specific permit failures or whether the company's acts were criminal, which were matters for the Environment Agency.
  - Response: Southern Water proposed the package of rebates and undertakings that Ofwat consulted on and accepted; Ofwat's chief executive said the company was "committed to putting things right". The 2020-21 annual report of the company's then parent group described the customer rebates as reflecting the seriousness of the breaches identified in the investigation, and the undertakings as measures to ensure that the issues identified had ceased and could not be repeated.
  - Outcome: Penalty and rebate package of £126 million; the company became bound by formal undertakings.
- Documented: Under Ofwat's October 2019 decision, Southern Water was to pay £126 million in penalties and rebates: £123 million returned to existing and former wastewater customers (£91.2 million of underperformance penalties it should have paid under the price review incentive regime and £31.7 million of additional compensation in lieu of a greater fine) and a fine of £3 million. Ofwat reduced the fine from £37.7 million to £3 million in recognition of the company's remedial steps and proposed rebates; it said the package equalled 6.7% of the company's wholesale wastewater turnover, the largest proportion it had imposed, and that existing customers could receive an average bill rebate of about £60 over five years. The company also committed to greater transparency and to stronger assurance on paying bonuses, and was bound by formal undertakings. The Environment Agency later described the package as a £126 million penalty imposed on the company in 2019 for regulatory failings over the same period as the 2010-2015 offences sentenced in 2021. [src-067] [src-068]
- Documented: In its November 2022 conclusions on the change of control of Southern Water, Ofwat stated that the company must continue to comply with the undertakings it gave in 2019 after Ofwat's enforcement investigation into its operation of wastewater treatment works and associated regulatory reporting. Ofwat's February 2026 notice records that these section 19 undertakings were signed on 9 October 2019, that their monitoring period ran to October 2024 and that Southern Water complied with the specific actions they contained. [src-009] [src-083]
- Attributed: Southern Water's annual report for the year ended 31 March 2026 states that Ofwat's investigation into the management, operation and performance of the company's wastewater treatment works concluded in 2018-19 with a financial penalty of £3.0 million, that the company agreed direct customer rebates of £122.9 million in 2017-18 prices over 2020-25, that the related provision was fully released in the year to 31 March 2025, and that Ofwat has now released the 2019 undertakings. [src-059] [src-068]
  - Qualification: Company disclosure; the report dates the conclusion to 2018-19, whereas Ofwat published its final decision on 10 October 2019. The rebate figure is expressed in 2017-18 prices, whereas Ofwat's 2019 notice gave £123 million of customer returns in total.
- Documented: In November 2021 the Environment Agency and Ofwat launched an investigation into the sewage treatment works of all combined water and wastewater companies in England and Wales. Ofwat did not open a separate enforcement case against Southern Water in 2022 or 2024, when it opened cases against other companies, because it was still monitoring the 2019 undertakings, but kept the company within the sector-wide investigation. Southern Water's 2025-26 annual report states that Ofwat has concluded its investigation into the company with new undertakings and no financial penalty, and that all combined companies remain subject to the ongoing Environment Agency investigation, for which the company cannot yet reliably estimate any obligation. [src-059] [src-083]
- Documented: In February 2026 Ofwat issued a notice under section 19(3) of the Water Industry Act 1991 accepting enforceable undertakings, dated 3 February 2026, from Southern Water Services Limited to secure its compliance with Regulation 4 of the Urban Waste Water Treatment (England and Wales) Regulations 1994, section 94 of the Act and Condition P12 of its licence, instead of imposing an enforcement order, and decided not to impose a financial penalty. Ofwat concluded that, despite progress under the 2019 undertakings, the company was not yet fully compliant and was still failing duties on the performance of its wastewater treatment works and collecting systems, effectual drainage and the running of its business. Ofwat also found that the company's senior management and board had concentrated on metrics that did not reflect its full compliance with the 1994 Regulations. [src-083] [src-059]
  - Response: Southern Water acknowledged Ofwat's findings in its undertakings; in its response of 6 October 2025 to the draft assessment it said it broadly agreed, but disagreed with some aspects, in particular the requirement for an investigation when a site meets less than 108% of its flow-to-full-treatment level.
  - Outcome: Ofwat accepted the undertakings instead of imposing an enforcement order and decided not to impose a financial penalty; the company's annual report for the year ended 31 March 2026 states that Ofwat has concluded its investigation into the company, that a new set of undertakings was agreed and that no financial penalty was imposed.
- Documented: In giving the February 2026 undertakings, Southern Water accepted that it had breached its duties under Regulation 4(4), Regulation 4(2) and Schedule 2 of the Urban Waste Water Treatment (England and Wales) Regulations 1994, its general duty under section 94 of the Water Industry Act 1991 by systemically breaching those duties, and Condition P12 of its licence on the adequacy of its resources and systems of planning and internal control. [src-083]
- Documented: Ofwat decided in February 2026 that a financial penalty was not warranted, citing the company's progress during the 2019 undertakings period and the penalty framework applied in its sector-wide wastewater investigation. The undertakings include a commitment by Southern Water and its shareholders to £13.5 million of additional investment, not funded by customers in the 2025-30 price control and not subject to cost sharing, including £2 million of new activity committed in response to the breaches. [src-083]
- Documented: On 5 November 2025 Ofwat reported that Southern Water was one of six water companies that triggered its new rule prohibiting directors' performance-related pay for 2024/25 - a rule introduced in June 2025 under powers in the Water (Special Measures) Act 2025 - and that all six complied by not giving their directors an annual bonus or other relevant performance-related pay. [src-115]
  - Qualification: Ofwat gives the triggering reasons for the six companies collectively ("a variety of performance failures, mostly involving category 1 pollution incidents") and does not say which standard Southern Water triggered.

## The flow-monitoring case, 2025–2026

- Attributed: In its supplementary prospectus of 30 July 2025, Southern Water Services Limited stated that it continued to cooperate with the Environment Agency in a separate investigation into legacy issues relating to wastewater sampling compliance for 2013 to 2017, that the investigation stage had concluded and that charges against the company were expected; its board considered that it was not yet possible to estimate reliably any resulting financial obligation. [src-017] [src-054] [src-091]
  - Qualification: Company disclosure in a bond prospectus; it does not describe the conduct under investigation. The investigation was disclosed earlier: Greensands Holdings' annual report for 2020-21 said that Southern Water was assisting the Agency's separate investigation into sampling compliance and reporting issues, which it dated 2010 to 2017.
  - Outcome: On 22 July 2026 the Environment Agency announced criminal proceedings against the company and former employees.
- Attributed: Southern Water's annual report for the year ended 31 March 2026 states that the company has continued to assist the Environment Agency in its investigation into legacy issues relating to wastewater sampling compliance for 2013 to 2017, that the investigation stage has concluded and charges against the company are in train, and that court proceedings are not expected to conclude for several years. The company said it could not yet predict how it would plead or how the court would apply the sentencing criteria, and disclosed the matter as a contingent liability rather than making a provision. [src-059] [src-054]
  - Qualification: Company disclosure; no plea by the company is recorded.
  - Outcome: Charges announced by the Environment Agency on 22 July 2026; the company is to face charges of breaching environmental permits linked to the same conduct.
- Attributed: As summarised in the Divisional Court's judgment of 22 July 2026, the Environment Agency alleges a deliberate plan by officers of Southern Water to manipulate the OSM regime by contriving operational circumstances so that there was no flow through a site when it was believed it would or might fail the OSM test. The court recorded that the detail of the allegations involves carefully planned and extensive fraud and dishonesty at a high level within the company, including arranging for wastewater to be removed by tankers to create no-flow results, and that the Agency says that, by the company's own assessment, it avoided penalties of the order of £45 million, and more on the Agency's assessment. [src-055] [src-074]
  - Qualification: Allegations only: the court described them for the purpose of the judicial review and did not decide the merits.
  - Response: Mr Wright denies any wrongdoing, his solicitor said (as reported in September 2026).
  - Outcome: The criminal case was sent to Maidstone Crown Court on 11 September 2026.
- Documented: According to the Divisional Court's judgment of 22 July 2026, the Environment Agency applied to Medway Magistrates' Court for a summons charging Matthew Wright, the company's Chief Executive Officer at the material times, and three former officers or senior operations managers with conspiracy to defraud at common law. Mr Wright opposed the application on the ground that the Agency had no power to bring such proceedings. District Judge Leake heard argument on 23 May 2025 and granted the application; the summons was issued on 24 September 2025 and served on Mr Wright on 29 September 2025, with reasons in a judgment dated 1 October 2025. The district judge also issued summonses against the company and another group of individuals. [src-055] [src-074]
  - Qualification: The judgment dates the Agency's application to 9 December 2025 and the promulgation of the district judge's reasons to 18 October 2015; both conflict with its other dates (summons issued 24 September 2025; reasons promulgated 18 October 2025 according to a later paragraph) and appear to be typing errors.
  - Response: Mr Wright contended that the Agency had no power to institute the proceedings and that the summons was a nullity; his counsel did not suggest that the summons would have been wrongly issued had the Crown Prosecution Service or the Serious Fraud Office sought it.
  - Outcome: Permission for judicial review refused on 22 July 2026. According to a press report, Mr Wright appeared on the charge for the first time at Bromley Magistrates' Court on 11 September 2026, and the case was sent to Maidstone Crown Court.
- Documented: In R (Matthew Wright) v Medway Magistrates' Court ([2026] EWHC 1842 (Admin), case AC-2025-LON-003760), after a rolled-up hearing on 23 and 24 June 2026, the Divisional Court (Lord Justice Popplewell, with whom Mr Justice Hilliard agreed) held on 22 July 2026 that section 37(1) of the Environment Act 1995 allows the Environment Agency to prosecute any offence where the prosecution is capable of being, and in the Agency's opinion is, conducive or incidental to its functions, and that the district judge was right that the Agency could prosecute Mr Wright and the three other former managers for conspiracy to defraud. The court found the claim not arguable and refused Mr Wright permission to apply for judicial review. The Environment Agency was an interested party; the three co-accused did not appear. [src-055] [src-054]
  - Outcome: The anonymity order was set aside the same day, and the Environment Agency announced the prosecution.
- Documented: On 13 November 2025 Mr Justice Mansfield, dealing on paper with what he was told was an urgent application, granted Matthew Wright anonymity and a reporting restriction in the judicial review proceedings and stayed the criminal proceedings; the Environment Agency applied on 20 November 2025 to discharge the order. On 22 July 2026 the Divisional Court set the anonymity order aside to allow full reporting of the proceedings, including his identity, holding that a person who has been charged has no reasonable expectation of privacy outweighing open justice. The court also found that Mr Wright had seriously breached his duty of candour by not telling the court that the hearing date relied on for urgency had been adjourned on 11 November 2025, and that the Agency had breached its own duty by not notifying the court promptly. [src-055] [src-054]
  - Response: Mr Wright argued that identification would so damage his reputation as to end his career prospects; his counsel accepted that he would not be entitled to anonymity if permission for judicial review were refused.
  - Outcome: Anonymity order set aside on 22 July 2026; the Environment Agency named the four accused former employees the same day.
- Attributed: In refusing anonymity, the Divisional Court noted on 22 July 2026 that the company's earlier Operation Garden prosecution - guilty pleas to 51 offences concerning almost 7,000 discharges over six years - largely overlapped with Matthew Wright's tenure in his senior position at the company, and recorded his own evidence that Ofwat's 2019 report contained many of the allegations now covered by the conspiracy charge but did not identify him as involved. The court stated that neither the Ofwat report nor the 2021 sentencing remarks identified him specifically as complicit in the criminal activity involved. [src-055] [src-067] [src-074]
  - Qualification: Observations made in deciding anonymity, not findings on the charge.
  - Response: Mr Wright denies any wrongdoing, his solicitor said (as reported in September 2026).
  - Outcome: The criminal case was sent to Maidstone Crown Court on 11 September 2026.
- Attributed: According to a press report of 11 September 2026, Matthew Wright and the three other former employees accused of conspiracy to defraud the Environment Agency and Ofwat appeared at Bromley Magistrates' Court that day to face the charge for the first time, together with the three further individuals. District Judge Stephen Leake said he was satisfied that the charges were all related and sent the case to Maidstone Crown Court, where the defendants were to appear on 9 October 2026; all were granted unconditional bail. The report adds that Southern Water has separately been charged with dozens of offences of failing to comply with or contravening an environmental permit condition. [src-074] [src-054]
  - Qualification: Press account. The report says the three further individuals were accused of "the same offence", whereas the Environment Agency describes their charges as linked to failure to comply with environmental permits.
  - Response: Mr Wright denies any wrongdoing, his solicitor said, according to the same report.
  - Outcome: Case sent to Maidstone Crown Court; the record contains no later step.
- Analysis: The Matthew Wright charged in 2026 is identified in this dossier with Matthew Reginald Wright, a director of Southern Water Services Limited from 28 February 2011 to 31 December 2016, on the following basis: the Environment Agency describes the accused as the company's former Chief Executive Officer; the Divisional Court states that the claimant Matthew Wright was the company's Chief Executive Officer at the material times; and a press report says he was chief executive between 2011 and 2016, joined from United Utilities in 2011, left in December 2016 and went on to be managing director of Orsted. These dates match Companies House's appointment records for Matthew Reginald Wright, which list him as a director of United Utilities Water Limited from 27 September 2007 to 25 February 2011, of Southern Water Services Limited from 28 February 2011 to 31 December 2016 and of Orsted (UK) Limited from 1 June 2017 to 24 April 2020. [src-074] [src-054] [src-055] [src-004] [src-073]
  - Qualification: Identity rests on the official descriptions of the accused as the former chief executive and on matching career dates; no record gives an identifier linking the accused to the Companies House officer record.

## Drinking water prosecutions, incidents and court records

- Documented: The Drinking Water Inspectorate's prosecution and caution record lists a caution issued to Southern Water on 9 January 2023 after the company supplied water unfit for human consumption to consumers on 30 July 2021; the record adds that the company subsequently changed its policy, procedures and training to prevent a recurrence. [src-119]
  - Response: According to the Inspectorate, the company subsequently changed its policy, procedures and training to prevent a recurrence.
  - Outcome: Caution issued on 9 January 2023.
- Documented: The Drinking Water Inspectorate's prosecution record lists Southern Water Services Ltd's guilty plea on 5 April 2022 to an offence under regulation 33(3)(a) (applying or introducing a substance or product into water in contravention of regulation 31(1)) concerning chlorate at High Park between 1 April and 31 May 2018. On 24 May 2022 Hove Crown Court imposed a fine of £16,000 and a victim surcharge of £170, with costs of £49,401.95. [src-119]
  - Response: The company pleaded guilty on 5 April 2022.
  - Outcome: Fined £16,000 with a £170 victim surcharge and £49,401.95 costs at Hove Crown Court on 24 May 2022.
- Documented: The Drinking Water Inspectorate's prosecution record lists Southern Water Services Ltd's guilty plea on 27 July 2018 to an offence under section 70 of the Water Industry Act 1991 for supplying water unfit for human consumption (discoloured and highly turbid) from the Cooks Castle water supply reservoir at Shanklin between 31 January and 12 February 2013. On 10 August 2018 Newport Crown Court fined the company £65,000, with costs of £44,620.99. [src-119]
  - Response: The company pleaded guilty on 27 July 2018.
  - Outcome: Fined £65,000 with £44,620.99 costs at Newport Crown Court on 10 August 2018.
- Documented: The Drinking Water Inspectorate's prosecution record lists Southern Water Services Ltd's guilty plea on 14 August 2017 concerning discoloured water after a burst main in October 2015. On 25 August 2017 Southampton Magistrates' Court fined the company £400,000 for supplying water unfit for human consumption (section 70) and £80,000 for using non-approved products (regulation 33), with costs of £50,000. [src-119]
  - Qualification: The record gives the plea and sentencing years in two-digit form ('17').
  - Response: The company pleaded guilty.
  - Outcome: Fined £400,000 for the section 70 offence and £80,000 for the regulation 33 offence, with £50,000 costs, at Southampton Magistrates' Court.
- Attributed: According to a press report of 19 December 2025, millions of plastic bio-beads used in wastewater treatment were released into the sea from Southern Water's Eastbourne wastewater treatment works in October 2025 and washed up on Sussex beaches from Hastings to Camber Sands, also polluting Rye Harbour Nature Reserve; the company admitted responsibility, and the incident was the subject of a criminal investigation by the Environment Agency. Southern Water's annual report for the year ended 31 March 2026 states that operators at Eastbourne saw on 28 October 2025 that some bio-beads had escaped from containment equipment into the works, that after reports of beads at Camber Sands late on 6 November the company concluded on 9 November that they had probably been released from the site, that its investigation found around 4.6 tonnes of beads was likely to have entered the sea, and that clean-up, compensation and investigation costs were £5.6 million in the year. [src-096] [src-059]
  - Qualification: Under investigation: the record contains no charge or outcome. Accounts of the timing differ: the press report dates the release to October 2025 and says the company admitted responsibility only two weeks later, while the annual report refers to late October and early November 2025 in its account of the clean-up and to November 2025 elsewhere; its own timeline records beads seen escaping inside the works on 28 October.
  - Response: The chief executive's statement in the annual report repeats an "unreserved apology" to customers and communities on the south coast; the company says it met the cost of the clean-up, strengthened containment at the works and will share the findings of an independent investigation.
  - Outcome: In December 2025 the Environment Agency described its investigation as active. The company's annual report for the year ended 31 March 2026 states that the board has been kept updated on the investigations following the release; the record contains no charge or other outcome.
- Attributed: According to the same press report of 19 December 2025, Southern Water answered an Environment Agency summons to an interview by saying it would attend only once it had concluded its own investigation; the Agency wrote again that the meeting was not optional, and the company confirmed it would attend an interview on 4 February. The Member of Parliament for Hastings and Rye wrote to Lawrence Gosden, Southern Water's chief executive, about the company's cooperation, and the Environment Agency's chief executive said he had received a letter from Mr Gosden apologising personally and confirming attendance. Another newspaper reported that the company had twice refused to release internal emails about the incident, saying this could prejudice regulators' inquiries. [src-096]
  - Qualification: Press account of correspondence not in the record; the reported refusal to release emails comes from another newspaper and is relayed second-hand.
  - Response: A Southern Water spokesman said: "We're complying fully with the Environment Agency investigation, and can confirm we'll be attending the interview under caution that's been requested."
  - Outcome: The Environment Agency said in December 2025 that the investigation was active; the record does not show whether the interview of 4 February took place and contains no charge or other outcome.
- Attributed: According to a press report of 28 July 2026, Southern Water accepted that its 2025-26 reporting contained wrong financial, credit-rating and operational figures: the annual report's summary gave the loss for the year as £112.6 million while the audited income statement shows £128.3 million, understating it by £15.7 million; the going-concern section repeated an operating profit of £307.1 million instead of the audited £304.2 million; a Moody's rating was given as Baa3 with a negative outlook instead of Ba1 stable; and a wastewater permit compliance figure of 54.2% was, the company said, published in error, the correct figure being 96.45%. [src-065] [src-059]
  - Qualification: Press account of the company's answers; the record contains no correction published by the company. The report says the company did not name the failed permits or explain the revised compliance figure.
  - Response: According to the report, the company corrected several figures, including a pension actuarial gain that should have read £59.1 million and an internal sewer flooding figure (389) that it described as a pre-assurance placeholder.
- Attributed: The independent auditor's report by Deloitte LLP, the company's external auditor for the year ended 31 March 2026, states that its audit identified a number of control deficiencies, including access controls, the precision of management review controls and controls around the posting of manual journals, and that because of the deficiencies in IT controls and business-process controls it extended its substantive audit procedures and performed the audit placing no reliance on controls. According to a press report of 28 July 2026, Southern Water would not identify the affected systems, processes or remediation dates. [src-065] [src-059]
  - Qualification: The company's refusal to identify the systems and dates is the press report's account. The auditor's statement concerns the audit approach, not a qualified opinion.
  - Response: According to the press report, the company said that Deloitte placed no reliance on IT controls and that the board's "mature" control framework related to non-financial reporting. In the annual report, the auditor states that the board has commenced a review of the company's internal controls and asked management to remediate the deficiencies, and the Audit Committee states that the company continues to take steps to address the matters raised by Deloitte's audit and that remediation of the deficiencies in internal control will remain an area of key focus in the next year.
  - Outcome: The auditor's report, signed on 15 July 2026, gives the opinion that the financial statements give a true and fair view of the company's affairs at 31 March 2026 and of its loss for the year; the record contains no later report on the remediation.
- Attributed: Southern Water's annual report for the year ended 31 March 2026 states that in December 2023 the company suffered a criminal cyber attack in which data was stolen from its IT systems, including personal data of a small proportion of customers and current and former employees, and that in December 2025 the Information Commissioner's Office indicated that the incident did not reach the requirements for regulatory action and confirmed that none would be taken. The company reports no other continuing investigations and no expected regulatory penalty; the value of any civil claims remains uncertain and no provision has been made. [src-059]
  - Qualification: The Information Commissioner's Office decision is reported by the company; the regulator's own notice is not in the record.
  - Response: The annual report states that the board has continued to monitor the company's post-incident activities, and lists external assurance of the company's post-cyber-event actions among the areas on which the Audit Committee's work focused during 2025-26.
  - Outcome: According to the company, the Information Commissioner's Office confirmed in December 2025 that it would take no regulatory action; the record contains no court decision on any civil claim arising from the incident.
- Attributed: A company-information aggregator's risk indicators for Southern Water Services Limited, retrieved in October 2026, show one outstanding county court judgment (CCJ). [src-028]
  - Qualification: Aggregator listing without amount, date, court or claimant; not checked against the official register of judgments.
  - Response: The record contains no statement by the company on this judgment.
- Documented: A search of The National Archives' Find Case Law service for "Southern Water Services" in October 2026 returned 23 judgments. Besides the criminal cases, they include two High Court (Technology and Construction Court) judgments of 23 January and 9 March 2017 in a claim by two private claimants against the company ([2017] EWHC 62 (TCC) and [2017] EWHC 460 (TCC)); two High Court (Business List) judgments of 28 June and 3 September 2024 in Surrey Searches Limited & Ors v Northumbrian Water Limited & Ors, in which Southern Water Services Limited is listed ([2024] EWHC 1643 (Ch) and [2024] EWHC 2283 (Ch)); a Planning Court judgment of 23 July 2025 in a judicial review brought by Saferwaters Limited and another against the Secretary of State for Environment, Food and Rural Affairs, in which the company was represented ([2025] EWHC 1885 (Admin)); and a 2002 Upper Tribunal (Lands Chamber) decision in a claim by a private individual against the company. [src-084]
  - Qualification: The index shows parties and short excerpts, not outcomes; it is incomplete and does not routinely include county, Crown or magistrates' court judgments.

## Board and management of Southern Water

- Documented: Companies House's register of officers of Southern Water Services Limited, retrieved in October 2026, shows 91 officer entries, 80 of which are recorded as resigned. A person who held office more than once appears once for each period of office. [src-002]
- Documented: Companies House's register of officers retrieved in October 2026 lists ten current directors of Southern Water Services Limited, with these appointment dates: Malcolm Charles Cooper (23 December 2019), William David George Price (8 September 2021), Lawrence Karl Gosden (1 July 2022), Stuart Neil Ledger (3 January 2023), Christèle Delbé (31 May 2023), Professor Kerensa Jane Jennings (31 May 2023), Neil Robert Vint Corrigall (29 November 2023), Neil Craig McArthur (1 October 2024), Andrew Oswell Bede Davies (6 May 2026) and Stephen Glynn Hurrell (28 August 2026). [src-002]
  - Qualification: Listed as current on the register retrieved in October 2026; the register page carries no other date.
- Documented: Companies House's register lists six company secretaries of Southern Water Services Limited: Graham Dudley Nicholson (recorded as appointed before 1 April 1992; resigned 1 April 1994), Graham John Heyes (1 April 1994 to 24 December 1996), Kevin Gregory Hall (24 December 1996 to 30 September 2015), Joanne Statton (1 October 2015 to 24 July 2018), Richard Denley John Manning (24 July 2018 to 22 July 2026) and Sandra Faye Redding, appointed on 22 July 2026 and listed as the current secretary on the register retrieved in October 2026. [src-002]
- Documented: Companies House's register lists ten directors of Southern Water Services Limited recorded as appointed before 1 April 1992, with these resignation dates: Bruce Alexander Ogston Hewett, William John Wesley Courtney, Francis Neil Midmer and Keith Tozzi (each 1 February 1993); Raymond Francis Thomas Collett (11 May 1993); William Cutting (15 June 1995); Alastair Lumsden Smith (4 October 1996); Graham Hillier Setterfield (10 November 1997); Richard Frank Clayton (31 August 1999); and Stuart Derwent (17 March 2005). Collett appears a second time, as a director appointed on 2 May 1995 who resigned on 4 October 1996. [src-003] [src-002] [src-004]
- Documented: Companies House's register lists these directors of Southern Water Services Limited appointed between 1992 and 2002, with their appointment and resignation dates: Eric John Hutchinson (1 December 1992 to 31 May 2003), Michael John Kinski (16 December 1996 to 1 March 1998), Professor Christopher Baker Chapman (1 November 1997 to 18 November 2003), John Clement Harris (1 November 1997 to 31 March 2005), Barrie Walter Delacour (10 November 1997 to 25 April 2007), David John Stainthorpe (10 November 1997 to 30 September 2004), Ronnie Edward Mercer (1 March 1998 to 1 April 2001), Anthony James Fegan (16 July 1999 to 1 September 2004), Martin Wayne Baggs (14 May 2001 to 7 October 2005) and Richard Anthony Nelson (23 April 2002 to 7 May 2003). [src-003] [src-002] [src-004]
- Documented: Companies House's register lists these directors of Southern Water Services Limited appointed in 2003: Jean Claude Banon (7 May 2003 to 10 February 2005), Rory Malcolm Cullinan (7 May 2003 to 1 October 2004), Francois Darley (7 May 2003 to 15 March 2005), Cyril Roger Lacan (7 May 2003 to 24 February 2004), Robert Peter Thian (13 May 2003 to 23 January 2008), Joseph Bernard Mangion (two entries: 16 May 2003 to 16 July 2003, and 15 September 2003 to 30 November 2003) and David Golden (1 November 2003 to 23 June 2015). [src-002] [src-003] [src-004]
- Documented: Companies House's register lists these directors of Southern Water Services Limited appointed in 2004 and 2005: Paul de Rosen (24 February 2004 to 10 April 2006), Howard Charles Goodbourn (29 March 2004 to 7 March 2011), John Donald Black Workman (1 October 2004 to 15 October 2007), David William Alexander (10 February 2005 to 10 April 2006), Simon Michael Peter MacDonagh (15 March 2005 to 22 April 2008), John James O'Brien (15 March 2005 to 10 April 2006), Steven Marshall (19 April 2005 to 31 January 2010) and Leslie William Dawson (25 October 2005 to 26 May 2010). [src-003] [src-004] [src-002]
- Documented: Companies House's register lists these directors of Southern Water Services Limited appointed between 2007 and 2009: Phillip William Peters (22 October 2007 to 12 January 2010), Jason Demetrious Zibarras (22 October 2007 to 13 January 2010), Michael William Welton (24 January 2008 to 20 February 2012), Robert David Armstrong and Cheryl Campbell Black (each 23 May 2008 to 31 January 2015) and Surinder Singh Toor (9 February 2009 to 7 March 2014). [src-003] [src-004] [src-002]
- Documented: Companies House's register contains two director entries for Southern Water Services Limited under the name Mark Alan Walters, held under two different Companies House officer records: one from 13 January 2010 to 23 February 2011, and one from 7 March 2014 to 26 September 2017. [src-004]
  - Qualification: The two entries show the same name and the same partial date of birth (not published here) but sit under separate officer records; the register itself does not state that they are the same person.
- Documented: Companies House's register lists these directors of Southern Water Services Limited appointed between 2010 and 2016: Paul John Moy (22 February 2010 to 19 May 2016), Jaron Yuen (22 February 2010 to 19 July 2011), Colin William Hood (23 February 2011 to 1 April 2014), Bronte Louise Somes (19 July 2011 to 19 May 2016), Michael Carmedy (1 November 2011 to 31 March 2016), Peter Szymon Antolik (22 February 2012 to 7 January 2015), Robert Archie Jennings (1 July 2012 to 28 February 2017), Michael Paul Sheffield (1 June 2014 to 31 March 2023), William Tame (1 January 2015 to 31 March 2019), Andrew John Truscott (7 January 2015 to 26 September 2017), Rosemary Jane Cecilia Boot (1 March 2015 to 31 March 2023), Lisa Harrington (1 April 2015 to 31 March 2018) and William Anthony Lambe (3 May 2016 to 14 December 2018). [src-003] [src-004] [src-002]
- Documented: Companies House's register lists Matthew Reginald Wright as a director of Southern Water Services Limited from 28 February 2011 to 31 December 2016. [src-004]
- Documented: Companies House's register lists these directors of Southern Water Services Limited appointed between 2017 and 2020 whose appointments have ended: Ian James McAulay (1 February 2017 to 30 June 2022); Wendy Jacqueline Barnes (26 September 2017 to 27 March 2020), Andrew Emerson Gilbert (26 September 2017 to 4 October 2018), Michael Colin Putnam (26 September 2017 to 31 July 2024) and Sara Sulaiman (26 September 2017 to 8 September 2021); Ian Raymond Francis (12 September 2018 to 12 February 2019), Gillian Lesley Guy (12 November 2018 to 31 March 2025), Sebastianus Antonius Theodorus Boelen (14 December 2018 to 31 July 2022), Kevin McCullough (18 July 2019 to 31 July 2022), Keith Geddes Lough (1 August 2019 to 16 July 2026) and Mary Katherine Fuller (15 June 2020 to 8 September 2021). Malcolm Charles Cooper, appointed in the same period on 23 December 2019, is still listed as a current director. [src-003] [src-002] [src-004]
- Documented: Companies House's register lists these directors of Southern Water Services Limited appointed from September 2021 onwards whose appointments have ended: Martin Bradley (8 September 2021 to 1 May 2022), Mark William Mathieson (8 September 2021 to 31 October 2023), Steven Richard Fraser (1 May 2022 to 8 December 2025), Nadim Ahmad (31 July 2022 to 3 January 2023) and Philip Swift (31 May 2023 to 31 March 2025). [src-002] [src-003] [src-004]
- Analysis: Companies House's register records three directors of Southern Water Services Limited appointed on 8 September 2021 (William David George Price, Martin Bradley and Mark William Mathieson) and two directorships ending that day (Mary Katherine Fuller and Sara Sulaiman). According to SWS Holdings Limited's accounts for the year to 31 March 2022, 8 September 2021 is also the date on which Macquarie Asset Management, through Mscif Wight Bidco Limited, acquired a 62.24% majority stake in Greensands Holdings Limited. This claim notes the coincidence of dates only: the register does not say who nominated these directors, although the 2025-26 annual report describes Will Price as an investor-nominated director. [src-002] [src-003] [src-004] [src-059] [src-089]
- Documented: Southern Water's annual report for the year ended 31 March 2026 states that board membership remained constant during the year apart from the departure of an investor-nominated director, Steve Fraser, leaving a smaller board of four independent non-executive directors besides the Chair, two investor-appointed non-executive directors and two executive directors. The report's board pages list Keith Lough (Chair), Lawrence Gosden (Chief Executive Officer), Stuart Ledger (Chief Financial Officer), Malcolm Cooper, Christèle Delbé, Kerensa Jennings and Neil McArthur (independent non-executive directors), Andrew Davies (independent non-executive director and Chair Designate), Will Price and Neil Corrigall (non-executive directors) and Richard Manning (Company Secretary). [src-059]
  - Qualification: The board pages reflect the position at the report's date in July 2026 (Andrew Davies joined on 6 May 2026); the statement on board size refers to the 2025-26 financial year.
- Documented: Keith Lough, a director of Southern Water since 1 August 2019, described 2025-26 as his seventh and final year as Chair; in the chair's overview of the annual report, dated 15 July 2026, he wrote that he would step down on 16 July 2026 and hand the role to Andrew Davies. The report states that Davies joined the board on 6 May 2026 as an independent non-executive director and Chair Designate and would take over from Lough as Chair on 16 July 2026. Companies House's register records Lough's directorship as ending on 16 July 2026, and the company's website, retrieved in October 2026, states that Davies became Chair on 16 July 2026. [src-059] [src-100] [src-003] [src-002]
- Documented: The 2025-26 annual report, signed in July 2026, gives Keith Lough's external appointment as senior independent director of Hunting plc, and states that immediately before joining Southern Water's board he was a non-executive member of the Gas and Electricity Markets Authority (Ofgem), where he chaired the audit and risk assurance committee, having served on that board since 2012. [src-059]
  - Qualification: The report does not date the Hunting plc appointment.
- Documented: The 2025-26 annual report states that Andrew Davies was chief executive of Kier Group plc from April 2019 to October 2025, senior independent director of Chemring Group plc between May 2016 and January 2025 and chief executive of Wates Group between January 2014 and January 2018, after 28 years with BAE Systems plc; his external appointment is chair, since 2022, of EKFB, the joint venture building the central section of HS2. The company's website, retrieved in October 2026, gives the same roles and dates his Kier tenure as 2019 to 2025. [src-100] [src-059]
- Documented: The 2025-26 annual report and the company's website state that Lawrence Gosden joined Southern Water in May 2020 and was appointed to the board on 1 July 2022, when he became Chief Executive Officer; the report adds that he had previously spent 12 years at Thames Water, where he was managing director for wastewater and later chief operating officer. Companies House's register lists him as a director from 1 July 2022. [src-002] [src-059] [src-100]
- Documented: According to the company's website, Stuart Ledger joined Southern Water as Chief Financial Officer on 3 January 2023, the date from which Companies House's register lists him as a director. The website and the 2025-26 annual report state that he was previously chief executive of Affinity Water and, for the four years before that, its chief financial officer, and that he spent nine years at Thames Water as chief financial officer of the retail business and as group financial controller. [src-100] [src-002] [src-059]
- Documented: The 2025-26 annual report states that Richard Manning joined Southern Water in July 2018 as General Counsel and Company Secretary, with overall responsibility for risk, internal audit, corporate governance and assurance, and acted as secretary to all board committees; it records that he would retire from the company at the end of July 2026 after eight years and that Sandra Redding would take over his position. Companies House's register records Manning as secretary from 24 July 2018 to 22 July 2026. [src-059] [src-002]
- Documented: The company's website, retrieved in October 2026, lists Sandra Redding as General Counsel and Company Secretary, states that she joined Southern Water in June 2026 to lead its legal, risk and compliance, audit and company secretariat teams, and says she previously served as General Counsel to Petrofac, Seadrill, Highview Power and Dragon Oil. Companies House's register records Sandra Faye Redding's appointment as secretary on 22 July 2026. [src-100] [src-002]
  - Qualification: The website does not date her earlier General Counsel roles.
- Documented: The 2025-26 annual report describes Malcolm Cooper (appointed 23 December 2019), Christèle Delbé and Kerensa Jennings (both appointed 31 May 2023) and Neil McArthur (appointed 1 October 2024) as independent non-executive directors. In the chair's overview, dated 15 July 2026, Keith Lough states that Cooper chairs the Audit Committee, has acted as senior independent non-executive director and led the search for a new Chair; that Delbé chairs the Remuneration Committee; that McArthur chairs the Health and Safety and Operational Risk Committee; that Jennings brings experience in data platforms and applications of AI; and that Lough himself chaired the Nominations Committee. The company's website, retrieved in October 2026, lists the same four as independent non-executive directors. [src-059] [src-100]
- Documented: The 2025-26 annual report lists Will Price as a non-executive director who is not independent, appointed on 8 September 2021, and the chair's overview calls him an investor-nominated non-executive director. The report states that he joined Macquarie in 2007, heads the Utilities and Networks team for Macquarie Asset Management in EMEA and is currently a director of National Gas and EP Infrastructure. The company's website, retrieved in October 2026, says instead that he heads the European Utilities team for Macquarie Asset Management and serves as a director of Southern Water, EP Infrastructure and Czech Grid Holding. [src-059] [src-100]
  - Qualification: The two company sources differ on the team he leads and on his current outside directorships (National Gas in the report, Czech Grid Holding on the website); neither dates those directorships. The report names the gas company only as 'National Gas'.
- Documented: The 2025-26 annual report lists Neil Corrigall as a non-executive director who is not independent, appointed on 29 November 2023, describes him as an operating partner for Macquarie Asset Management and gives his external appointment as non-executive director of Cadent Gas; it states that he previously served as a non-executive director of Czech Grid Holdings and earlier held leadership roles at Severn Trent plc. The chair's overview says he chairs the board's new Major Projects and WRMP Committee, and the remuneration report lists him as an investor-nominated non-executive director. The company's website, retrieved in October 2026, describes him as currently a non-executive director of Cadent Gas and Czech Grid Holdings. [src-059] [src-100] [src-002]
  - Qualification: The report describes the Czech Grid Holdings directorship as past, the website as current; neither source dates it.
- Documented: Companies House's register lists Steven Richard Fraser as a director of Southern Water Services Limited from 1 May 2022 to 8 December 2025, and the filing history records the termination notice as filed on 15 December 2025. The 2025-26 annual report calls Steve Fraser an investor-nominated non-executive director, records his departure as a director on 8 December 2025 and says he stepped down after two-and-a-half years on the board. [src-003] [src-059] [src-040]
  - Qualification: The report's 'two-and-a-half years' does not match the register, which dates his appointment to 1 May 2022; both sources give 8 December 2025 as the end date.
- Documented: In the chair's overview of the 2025-26 annual report, dated 15 July 2026, Keith Lough states that Will Price, an investor-nominated non-executive director, had signalled his intention to stand down that year; that on completion of Ofwat's new fitness and propriety processes he would be replaced by Martin Bradley, and Steve Hurrell would also join the board, as investor-nominated non-executive directors; and that Asterion Industrial Partners were expected to nominate a non-executive director following the recent equity transaction. Companies House's register lists Stephen Glynn Hurrell as a director appointed on 28 August 2026, and the company's website, retrieved in October 2026, lists Steve Hurrell as a non-executive director. [src-059] [src-002] [src-100] [src-040]
  - Qualification: On the register retrieved in October 2026 William David George Price was still listed as a current director, and no new appointment of Martin Bradley or of an Asterion nominee was listed. The report does not identify Martin Bradley further; he is taken to be the former director of that name (8 September 2021 to 1 May 2022) on the basis set out in the separate identity analysis.
- Analysis: The Martin Bradley named in the 2025-26 annual report as a future investor-nominated director is probably the Martin Bradley who was a director of Southern Water Services Limited from 8 September 2021 to 1 May 2022. Companies House's appointments record for that former director also lists directorships of Macquarie companies, including MSCIF Wight Bidco Limited and Macquarie Asset Management UK Holdings No.1 Limited; the annual report describes funds managed by Macquarie Asset Management as the principal investors in the parent company Sandstone Water Holdings Limited; and Asterion's press release of 22 June 2026 quotes a Martin Bradley as Senior Managing Director at Macquarie Asset Management. [src-059] [src-002] [src-112] [src-048]
  - Qualification: Identity inferred from the name and the Macquarie context; neither the annual report nor the press release gives an identifier, and the register retrieved in October 2026 lists no new Southern Water appointment for him.
- Documented: The company's website board page, retrieved in October 2026, lists Andrew Davies as Chair; Lawrence Gosden as Chief Executive Officer; Stuart Ledger as Chief Financial Officer; Malcolm Cooper, Christèle Delbé, Kerensa Jennings and Neil McArthur as independent non-executive directors; Will Price, Neil Corrigall and Steve Hurrell as non-executive directors; and Sandra Redding as General Counsel and Company Secretary. These are the ten directors and the secretary listed as current on Companies House's register retrieved in October 2026. [src-002] [src-100]
- Documented: Companies House's filing history for Southern Water Services Limited records the appointment of Andrew Oswell Bede Davies as a director on 6 May 2026 (filed 24 June 2026), the termination of Keith Geddes Lough's directorship on 16 July 2026 (filed 17 July 2026), the termination of Richard Denley John Manning's appointment as secretary and the appointment of Sandra Faye Redding as secretary, both on 22 July 2026 (filed 4 August 2026), and the appointment of Stephen Glynn Hurrell as a director on 28 August 2026 (filed 9 September 2026). A business-registry aggregator's activity feed shows the same filing dates for the Davies, Lough, Manning and Hurrell filings. [src-028] [src-040]
- Documented: Companies House's appointment pages for the officer records linked from Southern Water's register each show one appointment in total, the Southern Water Services Limited role, for: Sandra Faye Redding (secretary from 22 July 2026), Richard Denley John Manning (secretary from 24 July 2018 to 22 July 2026), Steven Richard Fraser (director from 1 May 2022 to 8 December 2025), Sara Sulaiman (director from 26 September 2017 to 8 September 2021), Kevin McCullough (director from 18 July 2019 to 31 July 2022), Gillian Lesley Guy (director from 12 November 2018 to 31 March 2025) and Michael Paul Sheffield (director from 1 June 2014 to 31 March 2023). [src-113] [src-114] [src-118] [src-123] [src-126] [src-128] [src-134]
  - Qualification: Each page covers one officer record only; Companies House holds Redding's and Manning's SW (Finance) I PLC appointments under other records, so a count of one is not a complete list of a person's appointments.
- Documented: Companies House's register of officers of SW (Finance) I PLC (company number 13677506), retrieved in October 2026, shows seven officer entries, four of them resigned: Stuart Neil Ledger, director since 25 October 2023, and Sandra Faye Redding, secretary and director since 1 September 2026, are listed as current; Richard Denley John Manning was secretary and director from 13 October 2021 to 1 September 2026; Lawrence Karl Gosden was a director from 1 July 2022 to 25 October 2023; and Ian James McAulay was a director from 13 October 2021 to 30 June 2022. [src-079]
  - Qualification: Ledger's and Gosden's entries use the same Companies House officer records as their Southern Water Services directorships. Redding's, Manning's and McAulay's entries are held under officer records different from those on Southern Water Services' register; they are matched to the same people by identical full names and fitting dates (McAulay's two directorships both ended on 30 June 2022; Manning handed over both secretary roles to Redding in July to September 2026).

## Executive pay, the bonus ban and board fees

- Documented: Southern Water's directors' remuneration report for 2025-26 states that, for the second consecutive year, no annual bonus was payable to either executive director - the Chief Executive Officer, Lawrence Gosden, and the Chief Financial Officer, Stuart Ledger - under Ofwat's Performance Related Pay Prohibition Rule (PRPP Rule), the prohibition for 2025-26 having been triggered by a Category 1 pollution incident at Florence Farm in September 2025. According to the report, the bonus outcome would otherwise have meant payments for 2025-26 of £388,622 to the Chief Executive Officer and £240,298 to the Chief Financial Officer; the equivalent amounts foregone for 2024-25 were £396,475 and £335,442 respectively. These amounts were not paid. [src-059]
  - Qualification: The foregone amounts are the report's calculation of what the bonus plan would have paid; they were not received.
- Documented: The audited single-figure table in the 2025-26 remuneration report gives the Chief Executive Officer's total remuneration for 2024-25 as £1,378.3 thousand: base salary £500.6 thousand, benefits £111.4 thousand, pension £75.1 thousand, no annual bonus and £691.2 thousand under the long-term incentive plan (LTIP). For 2025-26 it gives £736.4 thousand: base salary £518.2 thousand, benefits £140.5 thousand (a housing allowance, a car allowance and private medical insurance) and pension £77.7 thousand, with no bonus and no LTIP amount. The report's board pages identify Lawrence Gosden as Chief Executive Officer; he has held the post since 1 July 2022. [src-059]
  - Qualification: In the retained copy the 2025-26 row is detached from its labels; it is matched to the Chief Executive Officer by the report's fixed-pay table (2025-26 base salary £518,162, benefits £140,548, pension £77,724, total fixed pay £736,434). For details of the LTIP amount the report refers to the previous year's report.
- Documented: The same audited table gives the Chief Financial Officer's total remuneration for 2024-25 as £986.7 thousand: base salary £386.9 thousand, benefits £22.9 thousand, pension £42.6 thousand, no annual bonus and £534.2 thousand under the LTIP. For 2025-26 it gives £483.1 thousand: base salary £400.5 thousand, benefits £38.5 thousand (a car, a mobility allowance, private medical insurance and a one-off payment for accrued annual leave) and pension £44.1 thousand, with no bonus and no LTIP amount. Stuart Ledger has been Chief Financial Officer since January 2023. [src-059]
  - Qualification: As for the Chief Executive Officer, the 2025-26 row is matched to the Chief Financial Officer by the report's fixed-pay table (base salary £400,496, benefits £38,533, pension £44,055, total fixed pay £483,084).
- Documented: The remuneration report states that from 1 April 2026 the Chief Executive Officer's base salary rose from £518,162 to £536,298 and the Chief Financial Officer's from £400,496 to £414,513, increases of 3.5% equal to the wider workforce award; the Chief Executive Officer's pension of 15% of salary reflects a contractual commitment from his appointment, and the maximum annual bonus opportunity for executive directors remains 150% of salary. [src-059]
- Documented: The remuneration report states that a new Long-Term Incentive Plan for the executive directors and a small number of executives runs over the 2025-30 investment period from 1 April 2025, with a maximum opportunity of 150% of salary per year; awards vest in years two to five, the first element vesting in July 2027 with payment deferred to July 2028, and are subject to the PRPP Rule. According to the report, no element of the award is recoverable from customers or funded through customer bills, the plan being funded by shareholders. [src-059]
- Documented: The 2025-26 remuneration report states that during the year the Remuneration Committee comprised three non-executive directors: Christèle Delbé, its chair, and Malcolm Cooper, both independent, and Will Price, an investor-nominated director. It met five times and took independent advice from a remuneration consultancy. [src-059]
- Documented: The audited table of non-executive directors' fees in the 2025-26 remuneration report gives, in thousands of pounds, fees plus other amounts (taxable expenses connected with board business) for 2025-26, with the 2024-25 total in brackets: Keith Lough (Chair) 290.0 plus 2.2, total 292.2 (307.5); Malcolm Cooper (Senior Independent Non-Executive Director) 80.0 plus 1.3, total 81.3 (78.3); Christèle Delbé 65.0 plus 1.6, total 66.6 (61.3); Kerensa Jennings 55.0 plus 1.0, total 56.0 (57.3); Neil McArthur 65.0 plus 9.7, total 74.7 (38.9); Neil Corrigall (investor-nominated) 55.0 plus 6.7, total 61.7 (58.7); and Steve Fraser (investor-nominated) 37.9, pro-rated to his resignation on 8 December 2025 (57.7). Will Price, an investor-nominated director, receives no fees from the company. The report states that none of the directors had disclosable interests and that no payments were made to directors by other group companies. [src-059]
- Documented: The remuneration report states that the base non-executive director fee in 2025-26 was £55,000, with supplements paid to Malcolm Cooper as Audit Committee chair (£15,000) and as Senior Independent Non-Executive Director from 1 April 2025 (£10,000), to Neil McArthur as chair of the Health, Safety and Operational Risk Committee from 1 October 2024 (£10,000) and to Christèle Delbé as Remuneration Committee chair from 1 December 2024 (£10,000). With effect from 1 April 2026 the board approved a base fee of £60,000, supplements of £15,000 for each committee chair (including the Major Projects and WRMP Committee) and for the senior independent director, and an increase in the Chair's fee from £290,000 to £300,000 from the appointment of the incoming Chair. [src-059]
- Attributed: According to a press report of 23 July 2025, ten Labour MPs representing Kent constituencies signed a letter asking Lawrence Gosden, Southern Water's chief executive, to decline a long-term incentive payment of £691,200 (reported as about £700,000), which they called 'disgraceful' and described as an attempt by the company's executives to circumvent the bonus ban. The report said he received the payment on top of a £500,000 annual salary, weeks before a new law outlawed such payments, and that Steve Reed, whom it described as energy secretary, had called the payment 'outrageous', although it was legal under the framework in place when it was granted. [src-088] [src-059]
  - Qualification: Press account of the MPs' letter and a minister's remark. The report elsewhere says the £691,200 would be received over the next two years. The amount corresponds to the £691.2 thousand LTIP figure in the chief executive's audited 2024-25 single figure in the company's remuneration report.
  - Response: A Southern Water spokesperson was quoted as saying that executive salaries and benefits are decided by the Remuneration Committee, with a majority of independent non-executive directors, following Ofwat's protocols and the law and reviewed by external consultants; that Lawrence Gosden's 2025 package includes a relocation allowance and a Long Term Incentive Plan paid by shareholders, reflecting improvements made under the company's Turnaround Plan; and that both payments represent common industry practice.
  - Outcome: The company's 2025-26 remuneration report, whose committee chair's statement is dated 15 July 2026, shows £691.2 thousand under the LTIP in the Chief Executive Officer's audited single figure for 2024-25 and mentions no decline or waiver of the payment; the record contains no statement by Lawrence Gosden on the MPs' request and does not show whether or when the amount was paid out.
- Attributed: The same press report of 23 July 2025 said that Ofwat had announced that Southern Water was one of six companies forbidden from paying senior executives traditional bonuses for failing to meet high standards, and that this rule, in force since June 2025, prevented Lawrence Gosden from receiving a further £396,475. It put his total remuneration package at £1.4 million, including £111,400 of benefits and £75,100 of pension-related benefits. [src-088] [src-059] [src-115]
  - Qualification: Press account. The £396,475 equals the 2024-25 bonus that the company's 2025-26 remuneration report records as foregone by the Chief Executive Officer under Ofwat's PRPP Rule.
  - Response: According to the report, the company said that "his bonus up to the end of March" would be paid in full because it was agreed before the ban was introduced, and that it would be funded by shareholders; the report does not say which payment that phrase refers to.
  - Outcome: On 5 November 2025 Ofwat reported that all six companies, Southern Water among them, had complied with the rule for 2024-25 by not giving their directors an annual bonus or other relevant performance-related pay; the company's 2025-26 remuneration report records the Chief Executive Officer's 2024-25 bonus of £396,475 as foregone.

## Other appointments of Southern Water's directors

- Documented: Companies House's appointments record for Malcolm Charles Cooper, retrieved in October 2026, shows 120 appointments in total. Its first page lists him as a current director of Southern Water Services Limited (appointed 23 December 2019), Local Pensions Partnership Investments Ltd (1 September 2021), Custodian Property Income REIT PLC (6 June 2022), Merlin Properties Limited (30 May 2025), Grove Court Properties (Holdings) Limited, Grove Court Properties (Beaconsfield) Limited and Gerrards House Limited (each 13 February 2026) and Scorpion Properties Ltd (2 March 2026). [src-062]
  - Qualification: Only the first page of the Companies House record was retained, so further appointments may exist beyond those listed. 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: The same record lists Cooper's former directorships of CLS Holdings Plc (22 May 2007 to 23 April 2020), Morgan Sindall Group Plc (9 November 2015 to 31 August 2024), ACT (Administration) Limited (1 May 2023 to 30 April 2025) and Morhomes Plc (2 March 2018 to 10 September 2026), and of Cadent Gas Limited (2 June 2016 to 31 March 2017) and Cadent Finance Plc (8 September 2016 to 31 March 2017; a second entry for the same company covers 3 August 2006 to 4 January 2016), alongside directorships of a number of companies bearing the National Grid name. Morhomes Plc's own officer list on the register gives the same appointment and resignation dates for Cooper. [src-062] [src-098]
  - Qualification: Only the first page of the Companies House record was retained, so further appointments may exist beyond those listed.
- Documented: Companies House's register of persons with significant control for Grove Court Properties (Holdings) Limited lists Custodian Property Income REIT PLC (company number 08863271) as its only active registrable controller, notified on 13 February 2026, with ownership of 75% or more of the shares and of the voting rights and the right to appoint or remove directors. Malcolm Charles Cooper, a director of Custodian Property Income REIT PLC since 6 June 2022, was appointed a director of Grove Court Properties (Holdings) Limited on the same day, 13 February 2026, and the officer list of Grove Court Properties (Beaconsfield) Limited also shows his appointment as a director on 13 February 2026. [src-108] [src-062] [src-099]
  - Qualification: The retained records give only these dates; they do not describe how or why control of Grove Court Properties (Holdings) Limited changed or what part, if any, Cooper played in it. The earlier registrable persons are private parties and are not named here.
- Documented: A company-information aggregator's profile of Southern Water Services Limited, retrieved in October 2026, lists companies with which Southern Water shares officers: Southern Water Capital Limited, Greensands Finance Limited, Greensands Finance Holdings Limited and Greensands Financing Plc (through Neil Robert Vint Corrigall and Stuart Neil Ledger), Grove Court Properties (Holdings) Limited and Grove Court Properties (Beaconsfield) Limited (through Malcolm Charles Cooper), National Gas Transmission Plc (through William David George Price) and Water UK (through Lawrence Karl Gosden). The profile also notes that Cooper has recently joined the two Grove Court companies and recently left Morhomes Plc, and that Kerensa Jane Jennings has recently joined Group Of Humans Limited. [src-028]
  - Qualification: The aggregator gives no roles or dates for these shared officers; roles and periods are taken from the Companies House records described in the other claims of this section.
- Documented: Companies House's appointments record for William David George Price, retrieved in October 2026, shows 51 appointments in total. Its first page lists him as a current director of MSCIF Wight Midco Limited (appointed 21 June 2021), MSCIF Wight Bidco Limited (22 June 2021), Southern Water Services Limited (8 September 2021) and Greensands Europe Limited and Southern Water (Greensands) Financing plc (both 31 October 2025). It records that on 28 September 2026 he resigned as a director of Greensands Financing Plc, Southern Water Capital Limited, Greensands Finance Limited and Greensands Finance Holdings Limited (each held since 8 September 2021) and of Greensands Junior Finance Limited, Greensands Senior Finance Limited and Greensands Investments Limited (each held since 31 October 2025), and that he was a director of Sandstone Midco Limited, Sandstone Water Holdings Limited and Sandstone Bidco Limited from 20 December 2025 to 12 August 2026. [src-049]
  - Qualification: Only the first page of the Companies House record was retained, so further appointments may exist beyond those listed. 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: The same record lists Price as a current director of MIRA Core Gas Limited (appointed 31 May 2022), of Modus Bidco Limited and Modus Midco Limited (16 January 2026) and, from 4 September 2026, of National Gas Transmission Plc and seven other companies: National Gas Metering Limited, Luppiter Consortium Limited, Luppiter Bidco Limited, GAST Pledgeco Limited, GAST Midco Limited, National Gas Transmission Holdings Limited and Humber Hydrogen Transmission System Ltd. It also lists earlier directorships of Luppiter Bidco Limited and Luppiter Consortium Limited (18 March 2022 to 15 May 2026), GAST Topco Limited, GAST Pledgeco Limited and GAST Midco Limited (16 June 2022 to 15 May 2026) and National Gas Transmission Holdings Limited (31 January 2023 to 15 May 2026). National Gas Transmission Plc's own officer list shows Price as a current director appointed on 4 September 2026. [src-049] [src-097]
  - Qualification: Only the first page of the Companies House record was retained, so further appointments may exist beyond those listed. 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments record for Neil Robert Vint Corrigall lists eight appointments, all current on the record retrieved in October 2026: director of Southern Water Services Limited from 29 November 2023 and, from 28 September 2026, of Southern Water Capital Limited, Greensands Financing Plc, Greensands Finance Limited, Greensands Finance Holdings Limited, Greensands Investments Limited, Greensands Senior Finance Limited and Greensands Junior Finance Limited. William David George Price's appointments record shows his directorships of the same seven companies ending on 28 September 2026. [src-111] [src-050] [src-049]
  - Qualification: 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held. The record does not list his directorship of Sandstone Water Holdings Limited shown on that company's officers register; a Companies House appointments page covers one officer record only.
- Documented: Companies House's appointments record for Stuart Neil Ledger, retrieved in October 2026, shows 50 appointments in total. Its first page lists him as a current director of Southern Water Services Limited (appointed 3 January 2023); of Greensands Finance Holdings Limited, Greensands Finance Limited and Greensands Financing Plc (each 27 January 2023); and of Southern Water Services Group Limited, SW (Finance) I PLC, SWS Holdings Limited, Southern Water Capital Limited, SW (Finance) II Limited and SWS Group Holdings Limited (each 25 October 2023). It lists his directorships of Southern Water (Greensands) Financing plc, Greensands Europe Limited, Greensands (UK) Limited, Greensands Junior Finance Limited, Greensands Investments Limited and Greensands Senior Finance Limited from 27 January 2023 to 14 April 2025. [src-037]
  - Qualification: Only the first page of the Companies House record was retained, so further appointments may exist beyond those listed. 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: The same record lists Ledger as a current director of Landlord Tap Limited (appointed 7 February 2014) and Rett UK (23 January 2019). Earlier he was a director of Thames Water Utilities Finance Plc from 30 September 2008 to 29 September 2017, and of four other companies bearing the Thames Water name and PWT Projects Limited until the same date; and of Affinity Water Limited (9 October 2017 to 16 December 2022), Affinity Water Holdings Limited (1 November 2017 to 16 December 2022) and other companies including Affinity Water Finance Plc and Affinity Water Finance (2004) PLC, whose directorships ended between November 2021 and December 2022. [src-037]
  - Qualification: Only the first page of the Companies House record was retained, so further appointments may exist beyond those listed. 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments record for Lawrence Karl Gosden lists 27 appointments. Two are current on the record retrieved in October 2026: director of Water UK and of Southern Water Services Limited, both from 1 July 2022. All the others are directorships held from 1 July 2022 to 25 October 2023, of Greensands (UK) Limited, SWS Group Holdings Limited, Greensands Financing Plc, SW (Finance) II Limited, Southern Water Capital Limited, Southern Water Executive Pension Scheme Trustees Limited, SWS Holdings Limited, Greensands Junior Finance Limited, Greensands Investments Limited, Southern Water (NR) Holdings Limited, Greensands Finance Limited, Greensands Finance Holdings Limited, Southern Water Investments Limited, Southern Water (NR) Limited, Greensands Europe Limited, Southern Water Industries Limited, Southern Water Services Group Limited, SW (Finance) I PLC, Greensands Senior Finance Limited, Southern Water (Greensands) Financing plc and Southern Water Limited, and of Bowsprit Holdings Limited, Monk Rawling Limited, Bowsprit Property Development Limited and Ecoclear Limited. [src-029]
  - Qualification: 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments records list three Southern Water directors as directors of Water UK (company number 03539600): Matthew Reginald Wright from 1 April 2011 to 14 March 2017, Ian James McAulay from 14 March 2017 to 30 June 2022, and Lawrence Karl Gosden from 1 July 2022 (current on the record retrieved in October 2026). Water UK's register of persons with significant control carries a statement, notified on 27 March 2017, that the company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to it. [src-109] [src-073] [src-120] [src-029]
- Documented: Companies House's appointments record for Stephen Glynn Hurrell lists 14 appointments. Current on the record retrieved in October 2026 are his directorships of Sandstone Bidco Limited, Sandstone Midco Limited and Sandstone Water Holdings Limited (each from 12 August 2026) and of Southern Water Services Limited (from 28 August 2026). Earlier he was a director of Cadent Gas Limited (31 March 2017 to 23 December 2021); of Cadent Services Limited, Cadent Finance Plc and Quadgas Finance Plc (each 15 February 2019 to 23 December 2021); of Cadent Gas Pension Services Limited (17 June 2020 to 23 December 2021); of Energy Networks Association Limited (4 March 2019 to 2 September 2019); of NGET/SPT Upgrades Limited (15 December 2022 to 27 October 2023); and of Guardian Digital Communications Limited and Guardian Digital Communications Holdings Limited (from 1 July 2013 and 28 March 2014 respectively, to 19 February 2016). He is also listed as a director of Camell Limited from 26 May 2022, with no resignation date; that company is shown as dissolved. [src-032]
  - Qualification: 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments records for Andrew Oswell Bede Davies, Christèle Delbé and Neil Craig McArthur each list a single appointment, as a director of Southern Water Services Limited: Davies from 6 May 2026, Delbé from 31 May 2023 and McArthur from 1 October 2024, each current on the records retrieved in October 2026. [src-034] [src-035] [src-036]
  - Qualification: These records cover only appointments in companies registered with Companies House; appointments held abroad would not appear in them.
- Attributed: According to a press report of 17 August 2026, Andrew Davies, a former chief executive of Kier Group, has been appointed to the board of Mitie as a non-executive director. [src-116] [src-100] [src-034]
  - Qualification: Only the headline and first sentence are available; the rest of the report is behind a paywall, and it gives no appointment date and does not name the Mitie company concerned. The report identifies him only as Andrew Davies, a former Kier Group chief executive; Southern Water's own biography of its chair Andrew Davies says he was Chief Executive of Kier Group plc from 2019 to 2025 and became chair on 16 July 2026, which is the basis for treating them as the same person. The Companies House appointments record for Andrew Oswell Bede Davies retrieved in October 2026 lists no Mitie appointment, only Southern Water Services Limited.
- Documented: Companies House's appointments record for Kerensa Jane Jennings lists six appointments. Current on the record retrieved in October 2026 are her directorships of Southern Water Services Limited (from 31 May 2023), Inglenook Global Ltd (from 23 April 2024) and Group of Humans Limited (from 30 June 2026). Earlier she was a director of Elysium House Ltd (3 December 2013 to 13 April 2016), Inspiring Digital Enterprise Award C.I.C. (12 May 2015 to 20 September 2019) and the Centre for the Acceleration of Social Technology (25 November 2020 to 9 January 2024). [src-063]
  - Qualification: 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments record for Matthew Reginald Wright, retrieved in October 2026, shows 41 appointments in total. Its first page lists him as a director of United Utilities Water Limited from 27 September 2007 to 25 February 2011 and of Southern Water Services Limited from 28 February 2011 to 31 December 2016. In the same period he was a director of SWS Group Holdings Limited, SWS Holdings Limited, Southern Water Services Group Limited, Southern Water Investments Limited, Southern Water Industries Limited, Southern Water (NR) Holdings Limited, Southern Water (NR) Limited and Southern Water Limited (each 14 March 2011 to 31 December 2016), of Southern Water Executive Pension Scheme Trustees Limited (8 September 2015 to 31 December 2016) and of Water UK (1 April 2011 to 14 March 2017). Afterwards he was a director of Orsted (UK) Limited from 1 June 2017 to 24 April 2020, and of Orsted S&D (UK) Limited, Orsted Power (UK) Limited, Perigus Energy ESS Mersey Limited and two INEOS E&P companies for periods between June 2017 and January 2020. Wright, Southern Water's chief executive between 2011 and 2016 according to a press report, has been charged with conspiracy to defraud the Environment Agency and Ofwat over the alleged manipulation of wastewater self-monitoring between January 2012 and December 2017; he denies any wrongdoing, and on 11 September 2026 the case was sent to Maidstone Crown Court. [src-073] [src-074]
  - Qualification: Only the first page of the Companies House record was retained, so further appointments may exist beyond those listed. The identification of the charged former chief executive with this Companies House record rests on the official descriptions of the accused as the company's former chief executive and on the press report's account of his career (joined from United Utilities in 2011, left in December 2016, then managing director of Orsted), which matches the register entries; no record gives an identifier linking the two.
  - Response: Wright denies any wrongdoing, according to a press report of 11 September 2026.
  - Outcome: On 11 September 2026 a district judge sent the case to Maidstone Crown Court, where the defendants were due to appear on 9 October 2026; the retained record contains no later step.
- Documented: Companies House's appointments record for Keith Geddes Lough lists 30 appointments. He is listed as a current director of Hunting PLC (from 23 April 2018) and as a former director of Southern Water Services Limited (1 August 2019 to 16 July 2026), Rockhopper Exploration PLC (14 January 2014 to 1 October 2023) and Capricorn Energy PLC (14 May 2015 to 1 February 2023). Earlier entries include directorships of Dart Energy and IGas Energy companies between 2004 and 2011 and of British Energy companies, TTEP Eggborough Power Ltd and EDF Energy Nuclear Generation Limited between 2001 and 2004. [src-117]
  - Qualification: 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments record for Ian James McAulay lists 19 appointments, none of them current on the record retrieved in October 2026. He was a director of Southern Water Services Limited from 1 February 2017 to 30 June 2022, of Water UK from 14 March 2017 to 30 June 2022, and from 31 March 2017 to 30 June 2022 of SWS Group Holdings Limited, SWS Holdings Limited, Southern Water Services Group Limited, Southern Water Industries Limited, Southern Water Investments Limited, Southern Water (NR) Limited, Southern Water (NR) Holdings Limited, Southern Water Limited, Southern Water Executive Pension Scheme Trustees Limited, Ecoclear Limited, Bowsprit Holdings Limited, Bowsprit Property Development Limited and Monk Rawling Limited. Before that he was a director of Pennon Group Plc, Viridor Limited, Viridor Waste Limited and Valencia Waste Management Limited from 9 September 2013 to 31 August 2016. [src-120]
- Documented: Companies House's appointments record for Sebastianus Antonius Theodorus Boelen lists two appointments: director of Southern Water Services Limited from 14 December 2018 to 31 July 2022, and director of Curium Finance Limited from 17 January 2017, with no resignation date shown; Curium Finance Limited is listed as dissolved. [src-121]
- Documented: Companies House's appointments record for Mark William Mathieson, retrieved in October 2026, shows 56 appointments in total. Its first page lists him as a former director of MSCIF Wight Midco Limited (21 June 2021 to 20 December 2024), MSCIF Wight Bidco Limited (22 June 2021 to 20 December 2024) and Southern Water Services Limited (8 September 2021 to 31 October 2023), and of National Gas Transmission Plc, National Gas Metering Limited and National Gas Transmission Holdings Limited (31 January 2023 to 15 May 2026). Listed as current are his directorships of MIRA Core Gas Limited (from 11 October 2018), Cadent Gas Limited, Quadgas Holdco Limited, Quadgas Pledgeco Limited and Quadgas Midco Limited (from 28 November 2018), Quadgas Investments Bidco Limited and Quadgas Holdings Topco Limited (from 29 January 2019), four Last Mile Infrastructure companies (from 28 October 2024) and Nadara Limited (from 1 September 2026). [src-122]
  - Qualification: Only the first page of the Companies House record was retained, so further appointments may exist beyond those listed. 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments record for Martin Bradley lists 16 appointments. Current on the record retrieved in October 2026 are his directorships of Macquarie Asset Management UK Holdings No.1 Limited (from 1 March 2022) and Macquarie Infrastructure and Real Assets (Europe) Limited (from 21 April 2022). He was a director of MSCIF Wight Midco Limited (21 June 2021 to 20 April 2024), MSCIF Wight Bidco Limited (22 June 2021 to 20 April 2024) and Southern Water Services Limited (8 September 2021 to 1 May 2022); of Cadent Gas Limited, Quadgas Finance Plc, Quadgas Holdco Limited, Quadgas Midco Limited and Quadgas Pledgeco Limited (31 March 2017 to 28 November 2018); of Quadgas Investments Bidco Limited (24 November 2016 to 29 January 2019) and Quadgas Holdings Topco Limited (20 February 2017 to 29 January 2019); of KCOM Holdco 1, 2 and 3 Limited (from May 2019 to 21 August 2020); and of DKTUK Limited (14 December 2017 to 11 November 2022). [src-111] [src-112]
  - Qualification: 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held. The record does not list his directorship of Sandstone Water Holdings Limited shown on that company's officers register; a Companies House appointments page covers one officer record only.
- Documented: Companies House's appointments record for Andrew Emerson Gilbert lists 11 appointments, none of them current: director of Southern Water Services Limited from 26 September 2017 to 4 October 2018; of Southern Water (Greensands) Financing plc, Greensands Senior Finance Limited, Greensands (UK) Limited, Greensands Junior Finance Limited, Greensands Investments Limited, Greensands Europe Limited and Southern Water Capital Limited from 1 November 2017 to 5 August 2019; of Greensands Finance Holdings Limited and Greensands Finance Limited from 31 July 2018 to 5 August 2019; and of Greensands Financing Plc from 23 October 2018 to 5 August 2019. [src-124]
- Documented: Companies House's appointments record for Mary Katherine Fuller lists five appointments: director of Southern Water Services Limited from 15 June 2020 to 8 September 2021 and of TD Bidco Limited from 16 November 2022 to 5 March 2025, and, current on the record retrieved in October 2026, director of Midsummer Place Limited (from 7 December 2021), MK Holdco Limited (from 6 March 2023) and Pacific (BC) Topco Limited (from 5 December 2024). [src-125]
  - Qualification: 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments record for Philip Swift lists four appointments: director of Southern Water Services Limited from 31 May 2023 to 31 March 2025, and current (on the record retrieved in October 2026) director of MEIF 6 Range Bidco Limited, MEIF 6 Range Holdings Limited and MEIF 6 Range Investments Limited, each from 4 April 2025. [src-127]
  - Qualification: 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments record for Michael Colin Putnam lists ten appointments. Current on the record retrieved in October 2026 are his directorships of Network Rail Limited and Network Rail Infrastructure Limited (both from 8 January 2018) and Bazalgette Tunnel Limited (from 16 July 2018). He was a director of Southern Water Services Limited from 26 September 2017 to 31 July 2024, and before that of Skanska Construction UK Limited (1 July 2001 to 8 May 2017), Skanska UK Plc (1 December 2004 to 8 May 2017) and Skanska Construction Holdings UK Limited (1 October 2009 to 8 May 2017). [src-129]
  - Qualification: 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments record for Nadim Ahmad lists 11 appointments. He is listed as a current director of Clyde Moray Ltd (from 2 July 2019). From 31 July 2022 he was a director of Southern Water Services Limited, until 3 January 2023, and of Greensands Finance Holdings Limited, Southern Water (Greensands) Financing plc, Greensands Senior Finance Limited, Greensands Europe Limited, Greensands (UK) Limited, Greensands Finance Limited, Greensands Junior Finance Limited, Greensands Investments Limited and Greensands Financing Plc, until 27 January 2023. [src-130]
  - Qualification: 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments record for Paul John Moy lists ten appointments, none of them current. He was a director of Greensands Senior Finance Limited, Greensands Europe Limited, Greensands (UK) Limited, Greensands Junior Finance Limited and Greensands Investments Limited from 12 October 2007, of Southern Water Capital Limited from 17 February 2010 and of Southern Water (Greensands) Financing plc from 28 March 2011, in each case until 20 July 2016; of Southern Water Services Limited from 22 February 2010 to 19 May 2016; and of UBS Infrastructure Fund GP UK Ltd (9 October 2006 to 11 July 2011; the company is shown as dissolved) and Phildrew Nominees Limited (28 October 2008 to 11 July 2011). [src-131]
- Documented: Companies House's appointments record for Mark Alan Walters, retrieved in October 2026, shows 67 appointments in total. Its first page lists him as a current director of Nadara Limited from 1 January 2024, after an earlier term as its director from 14 December 2017 to 1 January 2020, and as a former director of Ventient Energy Limited (14 November 2017 to 1 January 2020) and of a series of companies with wind-farm and Mobius names, almost all of them until 1 January 2020. No Southern Water directorship appears on the retained first page, so the record is matched to Southern Water's director of that name by name only. [src-132]
  - Qualification: Only the first page of the Companies House record was retained, so further appointments may exist beyond those listed. 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.
- Documented: Companies House's appointments record for Rosemary Jane Cecilia Boot, retrieved in October 2026, shows 50 appointments in total. Its first page lists her as a current director of Chapter Zero Limited (from 20 June 2019), Urban&Civic Plc (from 18 February 2021, after an earlier term from 10 May 2019 to 21 January 2021) and SDCL Efficiency Income Trust Plc (from 1 August 2025), and as a former director of Southern Water Services Limited (1 March 2015 to 31 March 2023), The Green Alliance Trust (10 December 2014 to 5 December 2023) and Triple Point Energy Transition Plc (21 August 2020 to 24 February 2025; the company is shown in liquidation). [src-133]
  - Qualification: Only the first page of the Companies House record was retained, so further appointments may exist beyond those listed. 'Current' means listed as active on the record retrieved in October 2026; an absent end date does not by itself prove a role is still held.

## Contractors and counterparties of Southern Water

- Documented: Find a Tender contract award notice 2024/S 000-036196, published on 8 November 2024, records that Southern Water Services Ltd. established a framework agreement titled 'AMP 8 Framework- Capital Strategic Delivery Partners (SDP)' (reference prj_4006), a works procurement awarded by negotiated procedure with prior call for competition and divided into three lots: Lot 1 'Capital SDP Non-Infrastructure Water', Lot 2 'Capital SDP Non-Infrastructure Wastewater' and Lot 3 'Capital SDP Infrastructure Water & Wastewater'. The notice gives the total value of the procurement as £6,200,000,000 excluding VAT. It describes the AMP8 regulatory period as running from April 2025 to March 2030 and states that the new arrangements will offer the option of running for AMP9. [src-053]
  - Qualification: The notice labels £6,200,000,000 as the 'total value of the procurement (excluding VAT)'; it does not describe the figure as a maximum or an estimate, and an award notice for a framework does not show how much work has been ordered or paid.
- Documented: Under Find a Tender award notice 2024/S 000-036196, contract no. 1 of Southern Water Services Ltd.'s AMP8 Capital Strategic Delivery Partners framework, covering lots 1 and 2 ('SDP Non Infra Water and Wastewater'), was concluded on 7 November 2024 with a group of economic operators: Costain Limited (London) and MWH Treatment Limited (Helsby). The notice gives the total value of the contract/lot as £1,881,833,333.33 excluding VAT; four tenders were received. [src-053]
  - Qualification: The notice does not state the shares of the two group members or whether the value is a maximum; it records the framework award, not work ordered or paid.
- Documented: Under the same notice, contract no. 2 of the framework, also covering lots 1 and 2 ('SDP Non Infra Water and Wastewater'), was concluded on 8 October 2024 with Kier Integrated Services Limited (Salford). The notice gives the total value of the contract/lot as £1,881,833,333.33 excluding VAT; four tenders were received. [src-053]
  - Qualification: The notice does not say whether the value is a maximum; it records the framework award, not work ordered or paid. It names the contractor only as Kier Integrated Services Limited and says nothing about its ownership.
- Documented: Under the same notice, contract no. 3 of the framework, covering lot 2 ('SDP Non Infra Wastewater'), was concluded on 8 October 2024 with Galliford Try Construction Limited (Middlesex). The notice gives the total value of the contract/lot as £907,333,333.33 excluding VAT; four tenders were received. [src-053]
  - Qualification: The notice does not say whether the value is a maximum; it records the framework award, not work ordered or paid.
- Documented: Under the same notice, contract no. 4 of the framework, covering lot 3 ('SDP Infra Water & Wastewater'), was concluded on 8 October 2024 with Morrison Water Services Limited (Stevenage). The notice gives the total value of the contract/lot as £1,524,000,000 excluding VAT; three tenders were received. [src-053]
  - Qualification: The notice does not say whether the value is a maximum; it records the framework award, not work ordered or paid.
- Documented: Find a Tender contract award notice 2024/S 000-017583, published on 6 June 2024, records that Southern Water Services Ltd. established the 'Southern Water AMP 8 Professional Services Framework' (reference prj_4007), a services framework agreement awarded by negotiated procedure with prior call for competition, in three lots: Lot 1 Asset Management Support Services, Lot 2 PMO and Project Management, and Lot 3 Technical & Engineering Support Services. The notice gives the total value of the procurement as £240,000,000 excluding VAT, lists nine contracts, each concluded on 13 May 2024, and says the framework is anticipated to run for the duration of AMP8, with an option to extend into AMP9. [src-058]
  - Qualification: The notice labels £240,000,000 as the 'total value of the procurement (excluding VAT)'; it does not describe the figure as a maximum or an estimate, and an award notice does not show how much work has been commissioned or paid.
- Documented: Under notice 2024/S 000-017583, the three contracts for lot 1 (Asset Management Support Services) of Southern Water's AMP8 Professional Services Framework were concluded on 13 May 2024 with Mott MacDonald Limited (registration number 1243967), AECOM Limited (01846493) and Ove Arup & Partners Limited (1312453). For each of the three contracts the notice gives a total value of the contract/lot of £80,000,000 excluding VAT; eight tenders were received. [src-058]
  - Qualification: The notice repeats the same figure for each contract in the lot and does not say how it is divided among the suppliers or whether it is a maximum.
- Documented: Under the same notice, the three contracts for lot 2 (PMO and Project Management) were concluded on 13 May 2024 with KPMG LLP (registration number OC301540), AECOM Limited (01846493) and Turner and Townsend Project Management Limited (02165592). For each of the three contracts the notice gives a total value of the contract/lot of £64,000,000 excluding VAT; nine tenders were received. [src-058]
  - Qualification: The notice repeats the same figure for each contract in the lot and does not say how it is divided among the suppliers or whether it is a maximum.
- Documented: Under the same notice, the three contracts for lot 3 (Technical & Engineering Support Services) were concluded on 13 May 2024 with Mott MacDonald Limited (registration number 1243967), Stantec UK Limited (01188070) and, jointly as a group of economic operators, Binnies UK Limited (3163649) and WSP UK Limited (1383511). For each of the three contracts the notice gives a total value of the contract/lot of £96,000,000 excluding VAT; eight tenders were received. [src-058]
  - Qualification: The notice repeats the same figure for each contract in the lot and does not say how it is divided among the suppliers or whether it is a maximum.
- Documented: The supplementary prospectus of 30 July 2025 for SW (Finance) I PLC's guaranteed bond programme, which Southern Water Services Limited guarantees, states in its description of the retail household price control that Southern Water's AMP8 strategy includes embedding new operational service partners and that 'SWS will be driving efficiency improvements in the Capita contract via process improvement'. [src-017]
  - Qualification: The prospectus does not describe the Capita contract's scope, value, term or contracting Capita entity; it places the reference in the section on the retail household business, which covers billing, debt management, meter reading and customer-side leakage.
- Documented: Note 34 (financial commitments) to Southern Water Services Limited's financial statements for the year ended 31 March 2026 states that in February 2021 the company entered into a contractual arrangement with Portsmouth Water Limited under which, after the reservoir has been constructed and Southern Water has laid a pipe, Portsmouth Water will supply Southern Water with 21 million litres of water a day as part of the development of the Havant Thicket Reservoir in Portsmouth Water's supply area. The contract runs from 2021 to 2100 and comprises fixed capacity charge payments and volumetric charges. The fixed contractual payments total £2,575.0 million over the period to 2100 (2025: £2,563.0 million); their present value at 31 March 2026, using a discount rate of 6.53% (the nominal return on capital allowed in the PR24 Final Determination), is £440.9 million (2025: £427.7 million). The note lists the right to receive water from Portsmouth Water Limited among the company's capital commitments. [src-059]

## Sources

- [src-094] Corporate registry source · src-094
- [src-093] Companies House filing history: SOUTHERN WATER SERVICES LIMITED (02366670), Companies House <https://find-and-update.company-information.service.gov.uk/company/02366670/filing-history?category=incorporation>
- [src-017] Company statement source · src-017
- [src-028] Corporate registry source · src-028
- [src-059] Company statement source · src-059
- [src-040] Companies House filing history: SOUTHERN WATER SERVICES LIMITED (02366670), Companies House <https://find-and-update.company-information.service.gov.uk/company/02366670/filing-history>
- [src-090] Scottish Power plc annual report and Form 20-F 2000/01, U.S. Securities and Exchange Commission (EDGAR), 2001 <https://www.sec.gov/Archives/edgar/data/1045513/000095010901501838/d591376k1.pdf>
- [src-078] Scottish Power plc annual report and accounts 2001/02, exhibit 10.2 to Form 20-F, U.S. Securities and Exchange Commission (EDGAR), 2002-08 <https://www.sec.gov/Archives/edgar/data/0001045513/000102140802011455/dex102.htm>
- [src-077] Scottish Power plc annual report on Form 20-F for the year ended 31 March 2002 (exhibit index), U.S. Securities and Exchange Commission (EDGAR), 2002-08 <https://www.sec.gov/Archives/edgar/data/0001045513/000102140802011455/d20f.htm>
- [src-091] Company statement source · src-091
- [src-092] Media source · src-092
- [src-089] Company statement source · src-089
- [src-009] Ofwat: Southern Water: Conclusions on Change of Control (November 2022), Ofwat, 2022-11 <https://www.ofwat.gov.uk/wp-content/uploads/2022/08/Consultation_Change_of_Ownership_Southern_Water.pdf>
- [src-020] Ofwat consultation on the change of ownership for Southern Water Services Limited (September 2026), Ofwat, 2026-09 <https://consult.ofwat.gov.uk/consultations/change-of-ownership-for-southern-water/user_uploads/consultation-on-change-of-ownership-for-southern-water-services-limited.pdf>
- [src-044] Companies House register of persons with significant control: MSCIF Wight Bidco Limited (13469990), Companies House <https://find-and-update.company-information.service.gov.uk/company/13469990/persons-with-significant-control>
- [src-080] Companies House register of persons with significant control: MSCIF Wight Midco Limited (13468085), Companies House <https://find-and-update.company-information.service.gov.uk/company/13468085/persons-with-significant-control>
- [src-081] Companies House register of persons with significant control: Macquarie Infrastructure and Real Assets (Europe) Limited (03976881), Companies House <https://find-and-update.company-information.service.gov.uk/company/03976881/persons-with-significant-control>
- [src-015] Companies House register of persons with significant control: Greensands Junior Finance Limited (06335757), Companies House <https://find-and-update.company-information.service.gov.uk/company/06335757/persons-with-significant-control>
- [src-027] Company statement source · src-027
- [src-042] Corporate registry source · src-042
- [src-051] Corporate registry source · src-051
- [src-043] Corporate registry source · src-043
- [src-033] Corporate registry source · src-033
- [src-026] Corporate registry source · src-026
- [src-025] Corporate registry source · src-025
- [src-022] Companies House filing history: Sandstone Water Holdings Limited (16482350), Companies House <https://find-and-update.company-information.service.gov.uk/company/16482350/filing-history>
- [src-001] Companies House register of persons with significant control: SOUTHERN WATER SERVICES LIMITED (02366670), Companies House <https://find-and-update.company-information.service.gov.uk/company/02366670/persons-with-significant-control>
- [src-005] Companies House register of persons with significant control: SWS Holdings Limited (04324499), Companies House <https://find-and-update.company-information.service.gov.uk/company/04324499/persons-with-significant-control>
- [src-006] Companies House register of persons with significant control: SWS Group Holdings Limited (04324498), Companies House <https://find-and-update.company-information.service.gov.uk/company/04324498/persons-with-significant-control>
- [src-007] Companies House register of persons with significant control: Southern Water Services Group Limited (04374956), Companies House <https://find-and-update.company-information.service.gov.uk/company/04374956/persons-with-significant-control>
- [src-008] Companies House register of persons with significant control: Southern Water Investments Limited (04650294), Companies House <https://find-and-update.company-information.service.gov.uk/company/04650294/persons-with-significant-control>
- [src-010] Companies House register of persons with significant control: Southern Water Capital Limited (04608528), Companies House <https://find-and-update.company-information.service.gov.uk/company/04608528/persons-with-significant-control>
- [src-011] Companies House register of persons with significant control: Greensands Finance Limited (11493345), Companies House <https://find-and-update.company-information.service.gov.uk/company/11493345/persons-with-significant-control>
- [src-012] Companies House register of persons with significant control: Greensands Finance Holdings Limited (11493352), Companies House <https://find-and-update.company-information.service.gov.uk/company/11493352/persons-with-significant-control>
- [src-013] Companies House register of persons with significant control: Greensands Investments Limited (06301867), Companies House <https://find-and-update.company-information.service.gov.uk/company/06301867/persons-with-significant-control>
- [src-014] Companies House register of persons with significant control: Greensands Senior Finance Limited (06335773), Companies House <https://find-and-update.company-information.service.gov.uk/company/06335773/persons-with-significant-control>
- [src-016] Companies House register of persons with significant control: Sandstone Bidco Limited (16482992), Companies House <https://find-and-update.company-information.service.gov.uk/company/16482992/persons-with-significant-control>
- [src-018] Companies House register of persons with significant control: Sandstone Midco Limited (16482495), Companies House <https://find-and-update.company-information.service.gov.uk/company/16482495/persons-with-significant-control>
- [src-021] Companies House register of persons with significant control: Sandstone Water Holdings Limited (16482350), Companies House <https://find-and-update.company-information.service.gov.uk/company/16482350/persons-with-significant-control>
- [src-023] Confirmation statement (CS01) of Sandstone Water Holdings Limited (16482350), Companies House <https://find-and-update.company-information.service.gov.uk/company/16482350/filing-history/MzUyNDAzODQ4NGFkaXF6a2N4/document?format=pdf&download=0>
- [src-031] Companies House register of persons with significant control: SW (Finance) I PLC (13677506), Companies House <https://find-and-update.company-information.service.gov.uk/company/13677506/persons-with-significant-control>
- [src-045] Company statement source · src-045
- [src-106] Companies House register of persons with significant control: SW (Finance) II Limited (13677558), Companies House <https://find-and-update.company-information.service.gov.uk/company/13677558/persons-with-significant-control>
- [src-107] Companies House register of persons with significant control: Southern Water (NR) Holdings Limited (04772485), Companies House <https://find-and-update.company-information.service.gov.uk/company/04772485/persons-with-significant-control>
- [src-064] Companies House register of persons with significant control: Southern Water Limited (02366620), Companies House <https://find-and-update.company-information.service.gov.uk/company/02366620/persons-with-significant-control>
- [src-082] Companies House register of persons with significant control: Alter Domus (UK) Limited (07562881), Companies House <https://find-and-update.company-information.service.gov.uk/company/07562881/persons-with-significant-control>
- [src-066] Administrators' statement of proposals (AM03), Greensands (UK) Limited (06366235), Companies House <https://find-and-update.company-information.service.gov.uk/company/06366235/filing-history/MzQ3MzMxNTEwOGFkaXF6a2N4/document?format=pdf&download=0>
- [src-030] Companies House filing history: Greensands (UK) Limited (06366235), Companies House <https://find-and-update.company-information.service.gov.uk/company/06366235/filing-history>
- [src-052] Notice of administrator's appointment (AM01), Greensands (UK) Limited (06366235), Companies House <https://find-and-update.company-information.service.gov.uk/company/06366235/filing-history/MzQ3MzE3MDg5NWFkaXF6a2N4/document?format=pdf&download=0>
- [src-029] Companies House officer appointments: Lawrence Karl Gosden, Companies House <https://find-and-update.company-information.service.gov.uk/officers/huNqR5cgW3cavySLnWEbjSG0rdk/appointments>
- [src-103] Find Case Law search results for "Greensands", The National Archives, Find Case Law <https://caselaw.nationalarchives.gov.uk/search?query=Greensands&per_page=50>
- [src-057] SWS Holdings Limited & Anor, Re [2025] EWHC 2690 (Ch), The National Archives, Find Case Law, 2025-10-09 <https://caselaw.nationalarchives.gov.uk/ewhc/ch/2025/2690>
- [src-037] Companies House officer appointments: Stuart Neil Ledger, Companies House <https://find-and-update.company-information.service.gov.uk/officers/cPT3Tpm3pnbBOTj9X47bnOGRI40/appointments>
- [src-104] Company statement source · src-104
- [src-038] Return of allotment of shares (SH01) of Sandstone Water Holdings Limited (16482350), Companies House <https://find-and-update.company-information.service.gov.uk/company/16482350/filing-history/MzUzOTMwNzE2MWFkaXF6a2N4/document?format=pdf&download=0>
- [src-039] Companies House register of charges: SOUTHERN WATER SERVICES LIMITED (02366670), Companies House <https://find-and-update.company-information.service.gov.uk/company/02366670/charges>
- [src-065] Media source · src-065
- [src-115] Ofwat: New bonus rule blocks £4m in first year of operation, Ofwat, 2025-11-05 <https://www.ofwat.gov.uk/potential-bonuses-blocked-by-new-rule/>
- [src-048] Company statement source · src-048
- [src-095] Media source · src-095
- [src-041] Non-opposition to a notified concentration, Case M.12488 – Asterion / Macquarie / Southern Water (Official Journal C, 28 July 2026), Publications Office of the European Union (EUR-Lex), 2026-07-28 <https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX%3A52026M12488%2801%29>
- [src-024] Prior notification of a concentration, Case M.12488 – Asterion / Macquarie / Southern Water (Official Journal C, 1 July 2026), Publications Office of the European Union (EUR-Lex), 2026-07-01 <https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ%3AC_202603488>
- [src-019] Ofwat consultation page: change of ownership for Southern Water (2026), Ofwat, 2026-09 <https://consult.ofwat.gov.uk/consultations/change-of-ownership-for-southern-water/>
- [src-111] Companies House register of officers: Sandstone Water Holdings Limited (16482350), Companies House <https://find-and-update.company-information.service.gov.uk/company/16482350/officers>
- [src-049] Companies House officer appointments: William David George Price, Companies House <https://find-and-update.company-information.service.gov.uk/officers/Km_zqmHiiNw4kXsKyHrG-YuOKGQ/appointments>
- [src-110] Companies House officer appointments: Adrian Peter Page, Companies House <https://find-and-update.company-information.service.gov.uk/officers/htq44u7syrJmb-IPlzrKvjO_Srg/appointments>
- [src-046] CNMV register of venture capital management companies: Asterion Industrial Partners, SGEIC, S.A. – board of directors, Comisión Nacional del Mercado de Valores <https://www.cnmv.es/portal/consultas/ecr/gestora.aspx?nif=A88155247&vista=4&fs=14%2F09%2F2026>
- [src-047] CNMV register of venture capital management companies: Asterion Industrial Partners, SGEIC, S.A. – significant shareholdings, Comisión Nacional del Mercado de Valores <https://www.cnmv.es/portal/consultas/ecr/gestora.aspx?nif=A88155247&vista=7>
- [src-070] Corporate registry source · src-070
- [src-071] Corporate registry source · src-071
- [src-069] Corporate registry source · src-069
- [src-060] Boletín Oficial del Registro Mercantil no. 138 of 2020, Madrid section (BORME-A-2020-138-28), Agencia Estatal Boletín Oficial del Estado, 2020-07 <https://www.boe.es/diario_borme/txt.php?id=BORME-A-2020-138-28>
- [src-101] Corporate registry source · src-101
- [src-061] Corporate registry source · src-061
- [src-087] Corporate registry source · src-087
- [src-102] Boletín Oficial del Registro Mercantil no. 228 of 26 November 2024, Madrid section (BORME-A-2024-228-28), Agencia Estatal Boletín Oficial del Estado, 2024-11-26 <https://www.boe.es/borme/dias/2024/11/26/pdfs/BORME-A-2024-228-28.pdf>
- [src-085] Southern Water Services Ltd, R v [2014] EWCA Crim 120, The National Archives, Find Case Law, 2014-01-23 <https://caselaw.nationalarchives.gov.uk/ewca/crim/2014/120>
- [src-086] Millmore & Ors v Environment Agency [2019] EWHC 443 (Admin), The National Archives, Find Case Law, 2019-01-29 <https://caselaw.nationalarchives.gov.uk/ewhc/admin/2019/443>
- [src-105] Environment Agency v Southern Water Services Limited: sentencing remarks, Crown Court at Canterbury, Courts and Tribunals Judiciary, 2026-07-17 <https://www.judiciary.uk/wp-content/uploads/2026/07/Environment-Agency-v.-Southern-Water-Services-Limited-Sentencing-Remarks.pdf>
- [src-067] Environment Agency: Record £90m fine for Southern Water following EA prosecution, Environment Agency (GOV.UK), 2021-07-09 <https://www.gov.uk/government/news/record-90m-fine-for-southern-water-following-ea-prosecution>
- [src-055] Matthew Wright, R (on the application of) v Medway Magistrates' Court [2026] EWHC 1842 (Admin), The National Archives, Find Case Law, 2026-07-22 <https://caselaw.nationalarchives.gov.uk/ewhc/admin/2026/1842>
- [src-056] Environment Agency: Southern Water fined £7.1 million for sewage pollution, Environment Agency (GOV.UK), 2026-07-17 <https://www.gov.uk/government/news/southern-water-find-71m-for-sewage-pollution>
- [src-072] Environment Agency: Southern Water admits sea pollution, Environment Agency (GOV.UK), 2026-04-27 <https://www.gov.uk/government/news/southern-water-admits-sea-pollution>
- [src-075] Environment Agency: Southern Water fined £2.4m for Kent pollution, Environment Agency (GOV.UK), 2026-09-22 <https://www.gov.uk/government/news/southern-water-fined-24m-for-kent-pollution>
- [src-076] Environment Agency: Southern Water pleads guilty to River Test pollution, Environment Agency (GOV.UK), 2026-07-15 <https://www.gov.uk/government/news/southern-water-pleads-guilty-to-river-test-pollution>
- [src-054] Environment Agency: EA commences criminal proceedings against Southern Water, Environment Agency (GOV.UK), 2026-07-22 <https://www.gov.uk/government/news/ea-commences-criminal-proceedings-against-southern-water>
- [src-074] Media source · src-074
- [src-068] Ofwat PN 21/19: Ofwat confirms Southern Water will pay £126m following investigation, Ofwat, 2019-10-10 <https://www.ofwat.gov.uk/pn-21-19-ofwat-confirms-southern-water-will-pay-126m-following-investigation/>
- [src-083] Ofwat: Notice of decision to accept section 19 undertakings from Southern Water Services Limited (February 2026), Ofwat, 2026-02 <https://www.ofwat.gov.uk/wp-content/uploads/2026/02/Notice-of-Ofwats-decision-to-accept-section-19-undertakings-from-Southern-Water-Services-Limited.pdf>
- [src-004] Companies House register of officers: SOUTHERN WATER SERVICES LIMITED (02366670), page 3, Companies House <https://find-and-update.company-information.service.gov.uk/company/02366670/officers?page=3>
- [src-073] Companies House officer appointments: Matthew Reginald Wright, Companies House <https://find-and-update.company-information.service.gov.uk/officers/eLR-sbgjcv73yKxBzsCfCvq2wgw/appointments>
- [src-119] Drinking Water Inspectorate: prosecution and caution record, Drinking Water Inspectorate <https://www.dwi.gov.uk/press-media/prosecution-and-caution-record>
- [src-096] Media source · src-096
- [src-084] Find Case Law search results for "Southern Water Services", The National Archives, Find Case Law <https://caselaw.nationalarchives.gov.uk/search?query=%22Southern+Water+Services%22&per_page=50>
- [src-002] Companies House register of officers: SOUTHERN WATER SERVICES LIMITED (02366670), Companies House <https://find-and-update.company-information.service.gov.uk/company/02366670/officers>
- [src-003] Companies House register of officers: SOUTHERN WATER SERVICES LIMITED (02366670), page 2, Companies House <https://find-and-update.company-information.service.gov.uk/company/02366670/officers?page=2>
- [src-100] Company statement source · src-100
- [src-112] Companies House officer appointments: Martin Bradley, Companies House <https://find-and-update.company-information.service.gov.uk/officers/2OclZMVjv-G76dRNAH8J0nabezI/appointments>
- [src-113] Companies House officer appointments: Sandra Faye Redding, Companies House <https://find-and-update.company-information.service.gov.uk/officers/aDbGM8OsmBLuSUyIA5K6FSNxNCI/appointments>
- [src-114] Companies House officer appointments: Richard Denley John Manning, Companies House <https://find-and-update.company-information.service.gov.uk/officers/vSwiK6IHbpsnp6U85VBvnioUUBw/appointments>
- [src-118] Companies House officer appointments: Steven Richard Fraser, Companies House <https://find-and-update.company-information.service.gov.uk/officers/mU1Kjg_JYcTyvrpPe5LP_3kMMms/appointments>
- [src-123] Companies House officer appointments: Sara Sulaiman, Companies House <https://find-and-update.company-information.service.gov.uk/officers/iYoR10Zd0tMJLvDcswmc3EgC8EE/appointments>
- [src-126] Companies House officer appointments: Kevin McCullough, Companies House <https://find-and-update.company-information.service.gov.uk/officers/xpPtbw8fl_5OuLVarHoO1dFrBQI/appointments>
- [src-128] Companies House officer appointments: Gillian Lesley Guy, Companies House <https://find-and-update.company-information.service.gov.uk/officers/l1vhssgoPh5pgStGKqNvODFOuT4/appointments>
- [src-134] Companies House officer appointments: Michael Paul Sheffield, Companies House <https://find-and-update.company-information.service.gov.uk/officers/5cCuwuD5q6F0afnE6d0q6Xx9VCE/appointments>
- [src-079] Companies House register of officers: SW (Finance) I PLC (13677506), Companies House <https://find-and-update.company-information.service.gov.uk/company/13677506/officers>
- [src-088] Media source · src-088
- [src-062] Companies House officer appointments: Malcolm Charles Cooper, Companies House <https://find-and-update.company-information.service.gov.uk/officers/wke1YpOSkqRJWZ-3MfAvvPkrto0/appointments>
- [src-098] Companies House register of officers: Morhomes Plc (10974098), Companies House <https://find-and-update.company-information.service.gov.uk/company/10974098/officers>
- [src-108] Companies House register of persons with significant control: Grove Court Properties (Holdings) Limited (00549088), Companies House <https://find-and-update.company-information.service.gov.uk/company/00549088/persons-with-significant-control>
- [src-099] Companies House register of officers: Grove Court Properties (Beaconsfield) Limited (00679817), Companies House <https://find-and-update.company-information.service.gov.uk/company/00679817/officers>
- [src-097] Companies House register of officers: National Gas Transmission Plc (02006000), Companies House <https://find-and-update.company-information.service.gov.uk/company/02006000/officers>
- [src-050] Companies House officer appointments: Neil Robert Vint Corrigall, Companies House <https://find-and-update.company-information.service.gov.uk/officers/mRQGjYVMN63KYEpFqZypilUfHFk/appointments>
- [src-109] Companies House register of persons with significant control: Water UK (03539600), Companies House <https://find-and-update.company-information.service.gov.uk/company/03539600/persons-with-significant-control>
- [src-120] Companies House officer appointments: Ian James McAulay, Companies House <https://find-and-update.company-information.service.gov.uk/officers/8ipa6X54aY-Jt8oAbTL8rjpizQU/appointments>
- [src-032] Companies House officer appointments: Stephen Glynn Hurrell, Companies House <https://find-and-update.company-information.service.gov.uk/officers/bEyEnGlWV7qhUw-Mwbi6gdTDusc/appointments>
- [src-034] Companies House officer appointments: Andrew Oswell Bede Davies, Companies House <https://find-and-update.company-information.service.gov.uk/officers/7Px8VOE88u5_9_eR_ieDOOhkT0c/appointments>
- [src-035] Companies House officer appointments: Christèle Delbé, Companies House <https://find-and-update.company-information.service.gov.uk/officers/8rmH99a2z6P6x3EqslUdpMbW-p0/appointments>
- [src-036] Companies House officer appointments: Neil Craig McArthur, Companies House <https://find-and-update.company-information.service.gov.uk/officers/2g2Yfo2semVMLzTtVgP7RFfxHnA/appointments>
- [src-116] Media source · src-116
- [src-063] Companies House officer appointments: Kerensa Jane Jennings, Companies House <https://find-and-update.company-information.service.gov.uk/officers/6YuT76eaEaGn280LjkqagFdlZRY/appointments>
- [src-117] Companies House officer appointments: Keith Geddes Lough, Companies House <https://find-and-update.company-information.service.gov.uk/officers/sTQ0gkl6apTdvZ7oWdQOGWWyACk/appointments>
- [src-121] Companies House officer appointments: Sebastianus Antonius Theodorus Boelen, Companies House <https://find-and-update.company-information.service.gov.uk/officers/EkWsIyjtz4GdLl_sVTYMJiuoYWQ/appointments>
- [src-122] Companies House officer appointments: Mark William Mathieson, Companies House <https://find-and-update.company-information.service.gov.uk/officers/h2CPkdu49Jc0ljjnFVd7G5x_Mzg/appointments>
- [src-124] Companies House officer appointments: Andrew Emerson Gilbert, Companies House <https://find-and-update.company-information.service.gov.uk/officers/IlRWnm0lHvcqIe_wUlqYp56X9OU/appointments>
- [src-125] Companies House officer appointments: Mary Katherine Fuller, Companies House <https://find-and-update.company-information.service.gov.uk/officers/BkRIJRy0D_Km-27p2ld0c2xHLug/appointments>
- [src-127] Companies House officer appointments: Philip Swift, Companies House <https://find-and-update.company-information.service.gov.uk/officers/t_4OYUi7mwvBuh_uTm6VC0bt60c/appointments>
- [src-129] Companies House officer appointments: Michael Colin Putnam, Companies House <https://find-and-update.company-information.service.gov.uk/officers/goACYF2WDcjC6vrtOrxQ2_RGmQY/appointments>
- [src-130] Companies House officer appointments: Nadim Ahmad, Companies House <https://find-and-update.company-information.service.gov.uk/officers/mhP2SoH184Q4mqQVswWe6Kqwjm8/appointments>
- [src-131] Companies House officer appointments: Paul John Moy, Companies House <https://find-and-update.company-information.service.gov.uk/officers/8pttmiScuElCnBhHmEOs_dNYUHc/appointments>
- [src-132] Companies House officer appointments: Mark Alan Walters, Companies House <https://find-and-update.company-information.service.gov.uk/officers/9kZMIJ-hsOx322KtIyBfyT6zOqs/appointments>
- [src-133] Companies House officer appointments: Rosemary Jane Cecilia Boot, Companies House <https://find-and-update.company-information.service.gov.uk/officers/gm64SNjKk1gGaHb16ClFu93Roro/appointments>
- [src-053] Find a Tender notice 036196-2024: Southern Water AMP8 Capital Strategic Delivery Partners – contract award notice, Find a Tender service (notice by Southern Water Services Limited), 2024-11-08 <https://www.find-tender.service.gov.uk/Notice/036196-2024>
- [src-058] Find a Tender notice 2024/S 000-017583: Southern Water AMP8 Professional Services Framework – contract award notice, Find a Tender service (notice by Southern Water Services Limited), 2024-06-06 <https://www.find-tender.service.gov.uk/Notice/017583-2024>
