President: Jermyn Brooks, Transparency International, Chair Business Advisory Board
Members: María Mendiluce, World Business Council for Sustainable Development, Director Energy & Climate; Francesca Broadbent, Responding to Climate Change, Editor; Charles Donovan, Visiting Professor, EADA Business School; Sol Iglesias, Asia Europe Foundation, Director of Intellectual Exchange; Antonio Vives, Stanford University, Consulting Professor, Civil and Environmental Engineering

Introduction
The IPESD (“the Panel”) was appointed again in September 2011, with one new member, to conduct an analytical review of Abengoa’s 2010 Corporate Social Responsibility Report.

The Panel’s objectives remained:

1. improving the transparency of information about the company’s CSR, and
2. forming a judgement on the materiality of the company’s CSR Report and its responsiveness to stakeholders.

The defined scope of the Panel’s work comprised:

• A reading of the 2010 Report;
• The formulation of ten questions for response by management, following the same process and scope as in the previous year;
• A review of the company’s responses to these questions.

As in 2010, the Panel visited Abengoa’s head office to discuss the company’s sustainability strategy and its CSR reporting. Our concluding comments have therefore benefited both from explanations and written documentation received during our visit to Sevilla. The Panel did not however review the accuracy of the data included in the report, assurance of this data is provided by the company’s external auditors.

The Panel again expresses its recognition of Abengoa’s commitment to sustainability and to transparent reporting. Dialogue continues with the company on its implementation of CSR principles and how to report effectively on its related activities. The Panel remains of the opinion that reporting could be improved by concentrating more on Abengoa specific processes and performance, illustrated with examples, and less on general descriptions of environmental and social standards and regulations.

Overall comments on the 2010 report
We recognize that the report contains valuable information and provides many insights into Abengoa’s approach to incorporating CSR principles into its business.

At the same time we had hoped that the 2010 report could have been shorter than earlier reports but understand the wish of different interests within Abengoa to see their views and performance reflected in the report. We continue to believe that some themes could be referred to in the text with a website reference for those stakeholders who might be interested in specific areas of the company’s activities but which are overall deemed less material. Indeed it is this concept of what is material for the CSR reporting where in our view improvements could lie, as demonstrated in Abengoa’s answer to our question no. 8. We would encourage Abengoa to use the results of their internal and external issues matrix as a strict guideline for future reporting with a view to increasing the impact of the company’s reporting on sustainability activities.

Specific Comments on Abengoa’s responses to the Panel’s questions

The Panel does recognize a greater focus in the 2010 report on the important areas of GHG emissions and biodiversity, in line with our requests last year. We appreciate the way that Abengoa has responded to these questions on the 2010 report:

• LGHG emissions - Abengoa does not yet have a verified record of GHG emissions for more than two years and was therefore unable to show trend information as requested by the Panel. Our review will therefore want to return to this area next year.
• Biodiversity - the Panel would welcome in future cases or examples of how the company has dealt with challenges resulting from major construction projects and new sites.

In connection with our questions relating to governance concerning respect for minority interests we accept that Abengoa acted in accordance with the law. We believe that as minority interests may need more protection than provided currently under Spanish law, Abengoa might wish to introduce a consultation process in similar situations in future.

We have also suggested that a number of responses could usefully be shortened without loss of meaning for the report’s users.

Signed by the President of the IPESD
Jermyn Brooks
20 of February 2012