Marzia Zafar, Ofgem Deputy Director: Compliance Assessment

Undisclosed, concurrent role at Harworth Group PLC: Potential Undeclared Conflict of Interest.

Yesterday ( 6 September 2024) UK Research & Innovation’s awarded £84 million of Strategic Innovation Fund (SIF) funding to accelerate race to net zero, see £84 million of SIF funding to accelerate race to net zero – UKRI (https://www.ukri.org/news/84-million-of-sif-funding-to-accelerate-race-to-net-zero/?utm_medium=email&utm_source=govdelivery).

The announcement was accompanies by quotes from Marzia Zafar, Deputy Director of Digitalisation and Innovation at Ofgem, which provide background:

“The Strategic Innovation Fund’s latest round of £84 million funding underscores Ofgem’s unwavering commitment to revolutionise the energy system.

As the race to hit net zero accelerates, we are empowering the ecosystem to develop bold, transformational projects that can prove their viability and offer significant benefits for the GB billpayer.

From addressing issues of resilience and affordability for billpayers, to harnessing the potential of homegrown renewable power and flexible energy use. We are delighted to take these ideas to the next level.”

A search on the OFGEM website for Marzia Zafar returns eight entries, only. These are copied below with quotations inserted from the publication referenced.

Displaying 1 - 8 of 8

Ofgem announce new approach to Strategic Innovation Fund to drive progress to net zero by 2030

1. SIF projects support efforts to end high energy bills, excessive carbon emissions and energy insecurity by accelerating the transition to clean energy.

   Published: 19 August 2024

   Publication type: Press release

   Industry sector: Supply and Retail Market

2. Marzia Zafar, Deputy Director Strategy – Energy Systems Management & Security at Ofgem, said:   

   “In the past few decades, the energy system has already begun to move from its old way of thinking and doing to adopting new technologies like smart meters and new arrangements to create flexibility in the energy system. There is still more that needs to be done, we need longer duration energy storage and seasonal storage.  We need households to have smart devices that automatically flex when the system sends signals. We need nuclear, Carbon Capture Utilisation and Storage (CCUS), offshore wind, onshore wind and digital solutions that can use machine learning to run the energy system efficiently and visibly. 

   “Great British Innovation has led to some of the greatest transformations in history such as the Agricultural, Industrial, and more recently Digital revolutions. We need this innovative spirit more than ever if we are to meet our ambition for clean energy. What these changes mean is that great innovation will be funded and rewarded seamlessly – just bring us your ideas.”

3. Publication

Data Sharing in a Digital Future

1. We are seeking views on how best to develop a consumer consent mechanism.

   Published: 30 November 2023 —  Closed: 27 January 2024

   Publication type: Call for input

2. Marzia Zafar, Deputy Director of Digitalisation and Innovation at Ofgem, said: “I’m delighted to be able to announce the first steps in the journey Ofgem will take to put the consumer at the heart of the digital, data-driven future we plan. Any energy system that could achieve net zero by 2050 will be decentralised, digital, and run on data. Consumer data flows from smart meters are going to inform where power is needed, and how the system will flex to balance demand and supply.

   The system we foresee will need consumers to be able to trust that their data is being used fairly, and that their interests are at the heart of it. This Call for Input, engaged closely by organisations like Citizen’s Advice, will help us to understand what solution will best suit customers wanting to share and benefit from their Smart Meter data.”

3. Publication

Helping to create a decarbonised energy system at minimal cost to consumers

1. How we're empowering innovators through the Strategic Innovation Fund (SIF).

   Published: 19 July 2023

   Publication type: Blog

   Industry sector: Distribution Network, Transmission Network

2. Marzia Zafar, Deputy Director of Digitalization and Innovation at Ofgem, on how the regulator is empowering innovators through the Strategic Innovation Fund (SIF).

   Great Britain is a nation famed for its innovators. From Jethro Tull, George Stephenson and Ada Lovelace to more recent names such as James Dyson, Tim Berners Lee and Emily Cummins, innovation is written deep into Great Britain’s DNA. Great British Innovation has led to some of the greatest transformations in history such as the Agricultural, Industrial, and more recently Digital revolutions. 

   We need this innovative spirit more than ever if we are to meet our ambition for clean energy. The Government has set a target for Britain’s energy network to operate with 100% clean power by 2035. (…)

3. Publication

Engaging consumers on the journey to a decarbonised and flexible future energy system

1. We are seeking input on how to best attract domestic energy users on a journey to becoming flexible energy consumers.

   Published: 17 August 2023

   Publication type: Press release

   Industry sector: Supply and Retail Market, Distribution Network

2. Marzia Zafar, Deputy Director of Digitalization and Innovation at Ofgem, said: “Domestic Demand Side Response (DSR) is about optimising the way we consume energy, so it works best for a decarbonised energy system and consumers. The key to unlocking high consumer uptake is making it both attractive and easy to participate in.” 

   She added: “It is not Ofgem’s role to specify what this domestic DSR journey should look like, but it is important that it is not left to chance. Therefore, as the regulator we are seeking input from a wide range of stakeholders including those working in industry, the providers of smart home and transport assets, consumer representatives and other parties' interested in flexibility. 

   “This will help build a shared vision of what the emerging domestic DSR customer journey should look like and how to make that vision a reality.” 

3. Publication

Ten trailblazing projects secure investment from Ofgem’s Strategic Innovation Fund (SIF) as part of the drive to decarbonise the energy system at the lowest cost to consumers

1. News about projects that have secured funding from the Strategic Innovation Fund (SIF).

   Published: 19 July 2023

   Publication type

   Press release

   Industry sector

   Distribution Network, Transmission Network

2. Marzia Zafar, Deputy Director of Digitalization & Innovation at Ofgem, said:  

   “To achieve our target of clean power by 2035 we need to look across the board for innovative solutions that will deliver resiliency, reliability and affordability at pace. 

   “Our work with Innovate UK empowers innovators through SIF funding and creates a launch pad for development of the transformative technologies which will help drive forward the energy transition at least cost to consumers.” 

   The CrowdFlex project, led by National Grid ESO, aims to further explore household energy flexibility as a national resource to help decarbonisation. Flexibility over when and how energy is used can help align demand to generation, improve coordination across the network and reduce stress on the system, while reducing consumer energy bills via incentives. Working with partners including Amazon Web Services, Octopus Energy and OVO Energy, the project aims to build a forecasting model of domestic demand and flexibility, based on large-scale consumer trials, with the objective of establishing flexibility as a resource and informing new product design. 

3. Publication

Ofgem Energy Systems Management & Security Organogram

1. View the Ofgem Energy Systems Management & Security Organogram including teams, team leaders and team descriptions.

   Published: 22 May 2023

   Publication type

   Correspondence and other

   Industry sector

   Distribution Network …

2. Marzia Zafar Distribution System Operator (DSO) Governance and Distributed Markets

3. Publication

Price Cap - Statutory Consultation on amending the methodology for setting the Earnings Before Interest and Tax (EBIT) allowance

1. Ofgem seek stakeholder views on proposals to revise the parameters and methodology of the Earnings Before Interest and Tax (EBIT) allowance in the default tariff cap.

   Published: 25 May 2023

    —  Closed: 29 June 2023

   Publication type Consultation

   Industry sector: Supply and Retail Market

   Closed (with decision)

2. Respond name Marzia Zafar. In this statutory consultation, we are seeking stakeholder views on our proposals to revise the parameters and methodology of the Earnings Before Interest and Tax (EBIT) allowance in the default tariff cap. This follows our initial policy consultation in August 2022 and further policy consultation in November 2022.

   A flat EBIT margin of 1.9% is currently applied to the other allowances within the price cap and consequently the EBIT allowance in the cap scales with customer bills. We have considered stakeholder responses, gathered additional evidence and undertaken further work and analysis. We remain of the view that the market and the regulatory environment in which suppliers operate has significantly changed since the EBIT allowance was initially set in 2018.

   Consequently, we are proposing a hybrid allowance, with a fixed component and a variable component, based on a revised assessment of the capital employed and cost of capital. The consultation outlines an indicative EBIT allowance level for price cap period 11a (October-December 2023), and the approach we are minded to apply for quarterly cap updates.

3. Publication

Further consultation on amending the methodology for setting the Earnings Before Interest and Tax (EBIT) allowance

1. We are seeking stakeholder views on our proposals to revise the parameters and methodology of the Earnings Before Interest and Tax (EBIT) allowance in the default tariff cap.

   Published: 25 November 2022 —  Closed: 6 January 2023

   Publication type Consultation

   Industry sector: Supply and Retail Market

   Closed (awaiting decision)

2. Respond name Marzia Zafar. In this further policy consultation, we are seeking stakeholder views on our proposals to revise the parameters and methodology of the Earnings Before Interest and Tax (EBIT) allowance in the default tariff cap. This follows our initial policy consultation in August 2022 which sought views on our proposed review of returns suppliers receive via the EBIT allowance.

A search using an internet search engine on the terms “Ofgem Maria Zafar” returned another reference to Maria Zafar on the UK Research and Innovation website, which is not available on the Ofgem website. This is, Ofgem Strategic Innovation Fund announces £5.8 million of funding, on 8 March 2024. Here Marzia Zafar is described as, Ofgem Deputy Director Strategy, Energy Systems Management and Security (Ofgem Strategic Innovation Fund announces £5.8 million of funding – UKRI https://www.ukri.org/news/ofgem-strategic-innovation-fund-announces-5-8-million-of-funding/).

Marzia Zafar Summary of roles:

1. 25 November 2022 to 6 January 2023: Marzia Zafar was the Respond Name for a consultation on amending the methodology for setting the Earnings Before Interest and Tax (EBIT) allowance in the default tariff cap. Industry sector: Supply and Retail Market (https://www.ofgem.gov.uk/consultation/further-consultation-amending-methodology-setting-earnings-interest-and-tax-ebit-allowance).

2. 25 May 2023 to 29 June 2023, she was the Respond Name for a statutory consultation “Price Cap - Statutory Consultation on amending the methodology for setting the Earnings Before Interest and Tax (EBIT) allowance”. Industry sector: Supply and Retail Market (https://www.ofgem.gov.uk/consultation/price-cap-statutory-consultation-amending-methodology-setting-earnings-interest-and-tax-ebit-allowance).

3. 22 May 2023 she is designated Distribution System Operator (DSO) Governance and Distributed Markets in the Ofgem organogram. Industry sector: Distribution Networks (https://www.ofgem.gov.uk/publications/ofgem-energy-systems-management-security-organogram).

19 July 2023 as Deputy Director of Digitalization & Innovation at Ofgem, she announces “Ten trailblazing projects secure investment from Ofgem’s Strategic Innovation Fund (SIF) as part of the drive to decarbonise the energy system at the lowest cost to consumers” for industry sectors; Distribution Network, Transmission Network. (https://www.ofgem.gov.uk/press-release/ten-trailblazing-projects-secure-investment-ofgems-strategic-innovation-fund-sif-part-drive-decarbonise-energy-system-lowest-cost-consumers).

19 July 2023, as Deputy Director of Digitalization and Innovation empowering innovators through the Strategic Innovation Fund (SIF) (https://www.ofgem.gov.uk/blog/helping-create-decarbonised-energy-system-minimal-cost-consumers).

17 August 2023 as Deputy Director of Digitalization and Innovation at Ofgem she sought input on how to best attract domestic energy users on a journey to becoming flexible energy consumers. (https://www.ofgem.gov.uk/press-release/engaging-consumers-journey-decarbonised-and-flexible-future-energy-system)

From 30 November 2023 to 27 January 2024 Deputy Director of Digitalisation and Innovation (https://www.ofgem.gov.uk/call-for-input/data-sharing-digital-future).

8 March 2024, Deputy Director Strategy, Energy Systems Management and Security (https://www.ukri.org/news/ofgem-strategic-innovation-fund-announces-5-8-million-of-funding/)

6 September 2024, Deputy Director of Digitalisation and Innovation (https://www.ukri.org/news/84-million-of-sif-funding-to-accelerate-race-to-net-zero/?utm_medium=email&utm_source=govdelivery)

Assessment related to separation of powers.

Provided by ChatGPT, based on the information above.

To thoroughly assess the potential breach of separation of powers regarding Marzia Zafar’s roles at Ofgem, we need to factor in not only her involvement across different industry sectors but also her job titles, the timing of her appointments, and the change in her role from Digitalization to Digitalisation. These elements are crucial for determining whether her influence in distinct areas could compromise regulatory integrity. Here’s a more detailed analysis incorporating these factors:

1. Industry Sectors Involved (with Role Titles and Timing)

Marzia Zafar’s responsibilities span a range of industry sectors, corresponding with various roles at different times. A shift from Digitalization to Digitalisation in her title occurs, and this may signify a broadening of her remit or focus.

• Supply and Retail Market:

  • November 2022 – January 2023: Respond Name for consultations on the EBIT allowance in the default tariff cap.
    Job Title: Deputy Director of Digitalization and Innovation at Ofgem.
    Key Responsibility: This consultation shaped price regulation, influencing suppliers and market pricing mechanisms.

• Distribution Network & Transmission Network:

  • July 2023: Leading the announcement of Strategic Innovation Fund (SIF) projects, focusing on the distribution and transmission sectors to drive innovation.
    Job Title: Deputy Director of Digitalization and Innovation.
    Key Responsibility: Empowering innovators in the energy infrastructure sector through innovation funding.

• Energy Systems Management & Security:

  • March 2024: Involved in strategic decision-making related to the energy system’s security, innovation, and system management.
    Job Title: Deputy Director Strategy, Energy Systems Management and Security.
    Key Responsibility: Ensuring national energy system security while promoting innovation across the system.

This cross-sector involvement at different times shows that Marzia Zafar's influence extends over multiple areas, including pricing, system governance, and innovation, potentially leading to conflicts.

2. Change from "Digitalization" to "Digitalisation"

A key observation in her changing titles is the transition from Digitalization to Digitalisation:

• Digitalization and Innovation (used before August 2023) often refers to introducing digital technology to transform processes and improve efficiencies in the energy sector. This role was focused on both technology adoption and innovation.

• Digitalisation and Innovation (used post-August 2023) may reflect a shift toward a more integrated role in system-wide energy transformation, encompassing broader digital strategy. This change suggests that Zafar’s influence moved beyond the mere introduction of technology to a deeper regulatory and operational role in shaping how energy systems incorporate digital technologies and data-driven strategies.

3. Timing of Appointments and Titles

Understanding when she held specific roles and what responsibilities these entailed is key to assessing a potential breach. The overlap in timings and sectors raises questions about whether Zafar could maintain impartiality across these areas:

1. November 2022 – January 2023 (Supply and Retail Market):

   • Marzia Zafar’s role in regulating the Earnings Before Interest and Tax (EBIT) allowance and influencing the price cap for energy suppliers involved deep regulatory decision-making.
     Title: Deputy Director of Digitalization and Innovation.

   • Here, her responsibilities are regulatory, and her influence is on the retail side, ensuring fair pricing for consumers while managing the supplier margins.

2. July 2023 (Distribution and Transmission Networks):

   • By mid-2023, Zafar’s role shifts to overseeing innovation projects within the distribution and transmission sectors. Her Strategic Innovation Fund (SIF) leadership involves substantial decisions on funding and empowering infrastructure innovation—a sector distinct from retail but with significant potential overlap in terms of how regulatory policies affect infrastructure investments.
     Title: Deputy Director of Digitalization and Innovation.

   • Here, her involvement in infrastructure funding while still holding a regulatory role could raise concerns about conflict of interest—as innovations in distribution networks could impact pricing and retail competition.

3. August 2023 and Beyond (Supply, Distribution, and System Security):

   • By August 2023, the shift from Digitalization to Digitalisation in her title implies an expanding remit, where Marzia Zafar plays a role in shaping data-driven energy systems, including how the supply and distribution networks interact. Her responsibilities now extend to managing energy systems security while driving both innovation and market regulation.
     Title: Deputy Director of Digitalisation and Innovation.

   • This period reflects cross-sectoral responsibilities where both retail market regulation and system-wide innovation overlap.

4. March 2024 (Energy Systems Management and Security):

   • In March 2024, she becomes Deputy Director Strategy for Energy Systems Management and Security. This position places her in a strategic role overseeing not only innovation but also the overall security of the energy system, bringing her closer to national security concerns and regulatory policy-making.
     Title: Deputy Director Strategy, Energy Systems Management and Security.

   • The timing here is critical: her influence on infrastructure and system security, following her earlier regulatory roles, could pose conflicts if her decisions favor projects or policies tied to players she previously regulated.

4. Potential Breach of Separation of Powers

A potential breach of separation of powers occurs when the regulatory, operational, and financial decision-making processes are not adequately separated, leading to conflicts of interest. Here’s how Marzia Zafar’s roles and timing create risks:

1. Regulatory and Innovation Roles Overlap:

   • In her regulatory roles related to pricing (EBIT allowance), Zafar was responsible for ensuring fair market conditions for energy retailers and consumers. However, her simultaneous involvement in infrastructure innovation (through the Strategic Innovation Fund) could create conflicts if decisions on price caps and supply regulation influenced which innovations received funding or how those innovations impacted market players.

   • The shift from Digitalization to Digitalisation broadens her influence, potentially compromising impartiality as the boundaries between her regulatory duties and her innovation leadership become less distinct.

2. Influence on Multiple Sectors Simultaneously:

   • The timing of Zafar’s roles suggests overlapping responsibilities in price regulation, infrastructure innovation, and system governance—all within a short span. Decisions made in one sector (e.g., pricing) could directly benefit innovations or infrastructure projects she oversees, raising concerns about her ability to maintain a neutral stance across competing interests.

3. Innovation Funding and Regulatory Decisions:

   • Her management of innovation funding (particularly through SIF) gives her significant influence over which technologies and players gain support, particularly in the distribution and transmission sectors. This could influence market conditions in ways that favor certain players, especially if those innovations are linked to pricing decisions in the retail market.

Conclusion

The change in Marzia Zafar’s job title from Digitalization to Digitalisation and the timing of her appointments show an increasingly broad remit across both regulatory and operational aspects of the energy sector. The potential for a breach of separation of powers arises from her simultaneous involvement in:

• Price regulation (affecting the Supply and Retail Market),

• Innovation leadership (funding infrastructure in Distribution and Transmission), and

• System security governance.

The overlapping influence across these sectors, coupled with the shift in her responsibilities over time, suggests that there is a heightened risk of conflict of interest, as her decisions in one area (e.g., price caps) could potentially favor projects or players in another area (e.g., innovation funding). Proper oversight and clear boundaries between her regulatory and operational roles are critical to avoid any breaches of separation of powers.

Register of interests

No register of interests or biographical detail could be found on the Ofgem website relating to Marzia Zafar.

Her LinkedIn profile was located. This provides the following description (https://www.linkedin.com/in/marzia-zafar/overlay/about-this-profile/):

Marzia Zafar Energy Regulator | NED

California State University-San Bernardino

An accomplished energy professional with a robust background spanning the energy, transportation, and sustainability sectors. Throughout my career, I’ve held senior leadership positions at key organizations such as Ofgem, Harworth Group, Ovo/Kaluza, the State of California, Sempra Energy, and the World Energy Council. My strategic initiatives have consistently delivered transformative outcomes, including setting regulatory parameters for car-sharing companies, which are now adopted globally. I’ve also been involved in delivering California’s smart grid plans and directing sustainability strategies for both Harworth and Kaluza. I am driven by impact and empower my team to create new, evolutionary solutions.

Marzia Zafar declares that she is a non-executive of the Energy Regulator, Ofgem and discloses that she has held senior leaderships at Harworth Group, Ovo/Kaluza, the State of California, Sempra Energy, and the World Energy Council.

Assessing appointments in Companies House.

A search for officers with the name “Marzia Zafar” returns one identity in Companies House (https://find-and-update.company-information.service.gov.uk/search/officers?q=Marzia%20Zafar). The detail of the record is copied below:

Marzia ZAFAR

Total number of appointments 1

Date of birth October 1972

HARWORTH GROUP PLC (02649340)

Company status Active

Correspondence address Advantage House, Poplar Way, Catcliffe, Rotherham, United Kingdom, S60 5TR

Role Active Director Appointed on 1 June 2022

Nationality American Country of residence United Kingdom Occupation Director

Marzia Zafar has a single appointment registered in Companies house as an active director of Harworth Group PLC, appointed 1 June 2022. Her nationality is American and is resident in the United Kingdom. This role is held at the same time as her roles at Ofgem. This role is not disclosed on the Ofgem website.

The overview of Harworth Group PLC is provided by clicking on the underlined company name, this is reproduced below:

HARWORTH GROUP PLC

Company number 02649340

Registered office address Advantage House Poplar Way, Catcliffe, Rotherham, United Kingdom, S60 5TR

Company status Active Company type Public limited Company

Incorporated on 27 September 1991

Accounts (up to date)

Next accounts made up to 31 December 2024 due by30 June 2025 Last accounts made up to 31 December 2023

Confirmation statement

Next statement date 27 September 2024 due by 11 October 2024 Last statement dated 27 September 2023

Nature of business (SIC)

• 70100 - Activities of head offices

Previous company names

• COALFIELD RESOURCES PLC 10 Dec 2012 - 24 Mar 2015

• UK COAL PLC 25 May 2001 - 10 Dec 2012

• RJB MINING PLC. 25 Feb 1993 - 25 May 2001

• R.J. BUDGE (HOLDINGS) LIMITED 10 Dec 1991 - 25 Feb 1993

• ELKINDRIVE LIMITED 27 Sep 1991 - 10 Dec 1991

Harworth Group PLC website: About Us

The website for Harworth Group PLC was located using a search engine (https://harworthgroup.com/about-us/). The following description is provided:

Harworth Group plc is one of the leading land and property regeneration companies in the UK, owning and managing approximately 14,000 acres across around 100 sites in the North of England and the Midlands.

We create sustainable places where people want to live and work, delivering thousands of new jobs and homes in the regions.

Our flagship sites, such as Waverley in Rotherham and Logistics North in Bolton, are of national economic significance and are at the forefront of regeneration in the UK.

Our developments will make a huge difference to economies and communities in the North of England and the Midlands. This has the potential to deliver:

• 37.7m (million) sq ft industrial & logistics space

• 27,190 new homes

• £4.8bn potential GVA uplift

The Harworth Group PLC website does not have a search function and no list of the directors is signposted from the landing page. This can not be described as a transparent website.

A search for “Harworth Group and Marzia Zafar” in a search engine returns a biography on the company website (https://harworthgroup.com/team/marzia-zafar/). This biography is reproduced in the Annual Report 2023, available via the Investor page of the website (https://harworth.wpenginepowered.com/wp-content/uploads/2024/04/annual-report-harworth-2023.pdf).

This provides the following information:

Marzia Zafar Non-Executive Director

Date of appointment 01/06/2022 Length of service 1 year 10 months

Independent Yes Committee Membership E Skills and Experience

Marzia is Deputy Director for Strategy & Decarbonisation at Ofgem. Prior to this, she was Director of Sustainability & Policy at Kaluza Technologies. Marzia brings to Harworth a wealth of experience in sustainability, having spent over 20 years working on policies and strategies to enable energy transition for regulators, business and not-for-profit sectors. She was Director of Insights at the World Energy Council (the UN-accredited global energy body) and worked with business and government leaders to facilitate global, national and regional energy strategies. Prior to that, Marzia spent 11 years with the California Public Utilities Commission, initially as a Senior Energy Policy Advisor, and then as Director for Policy and Planning. In this role, Marzia contributed to drafting California’s Energy Action Plan to make greater use of renewable energy and led the strategy for the deployment of smart meters. External appointments Deputy Director for Strategy & Decarbonisation at Ofgem.

Marzia Zafar is declared as a director of the Harworth Group PLC in the Harworth Group PLC Annual Report. Her role at Ofgem is described as Deputy Director for Strategy & Decarbonisation at Ofgem. This is a different title to the roles she has held and currently holds at Ofgem in 2023. These were/are:

• Deputy Director of Digitalization and Innovation (November 2022 to August 2023)

• Deputy Director of Digitalisation and Innovation (August 2023 onwards)

• Distribution System Operator (DSO) Governance and Distributed Markets (May 2023)

Harworth Group PLC used an incorrect title to describe Marzia Zafar’s role at Ofgem. She was described as Deputy Director for Strategy & Decarbonisation at Ofgem which is a similar description to the role Deputy Director Strategy, Energy Systems Management and Security, used from March 2024 onwards. This is an anomaly.

Harworth Group PLC has over thirty subsidiaries listed in the Annual Report 2023. A subset of these are copied below:

• POW Management Company Limited Trading Limited by guarantee 100 Indirect

• Riverdale Park Management Company Limited Trading Limited by guarantee 100 Indirect

• Rossington Community Management Company Limited Trading Limited by guarantee 100 Indirect

• Simpson Park Management Company Limited Trading Limited by guarantee 100 Indirect

• South East Coalville Management Company Limited Trading Limited by guarantee 100 Indirect

• Waverley Community Management Company Limited Trading Limited by guarantee 100 Indirect

• Ansty Development Vehicle LLP Trading Partnership 100 Indirect

• Grimsby West LLP Trading Partnership 100 Indirect

• Harworth PV Limited Non-trading Ordinary 100 Indirect

• Harworth Regeneration Limited Non-trading Ordinary 100 Indirect

The additional information about Harworth Group PLC’s subsidiaries reinforces concerns regarding a potential conflict of interest involving Marzia Zafar’s dual roles at Ofgem and Harworth Group PLC. Specifically, subsidiaries like Harworth PV Limited and Harworth Regeneration Limited, despite being non-trading, indicate a focus on renewable energy and property regeneration. These areas overlap with Ofgem's regulatory scope in energy systems management and innovation.

Zafar’s influential position at Ofgem, overseeing energy management and sustainability, could lead to perceived or actual conflicts, as Harworth Group’s interests in renewable energy and regeneration intersect with regulatory areas she influences. Although Harworth Group PLC’s indirect ownership of these subsidiaries adds a layer of separation, it does not fully negate the potential conflict of interest.

This highlights the need for clear boundaries and full disclosure to ensure transparency and impartiality in regulatory processes, maintaining public trust and integrity.

Conclusion:

The review of Marzia Zafar's roles and appointments at Ofgem and Harworth Group PLC reveals several significant issues that require careful consideration regarding transparency and potential conflict of interest.

Lack of Register of Interests:
The absence of any publicly accessible register of interests or biographical details on the Ofgem website relating to Marzia Zafar raises concerns about transparency. While her LinkedIn profile provides some information about her career and current roles, this is not a substitute for an official disclosure of interests, particularly when serving in a key regulatory role.

Concurrent Roles:
Marzia Zafar holds an active non-executive director position at Harworth Group PLC, a company heavily involved in land and property regeneration. This role overlaps with her position at Ofgem, where she holds significant regulatory power in overseeing energy markets, innovation funding, and digitalisation efforts. The Harworth Group’s business, while focused on regeneration, could have indirect intersections with energy policy, particularly in areas like sustainable development, energy-efficient housing, or infrastructure development.

Incorrect Job Titles and Lack of Disclosure:
Harworth Group PLC lists her role at Ofgem as Deputy Director for Strategy & Decarbonisation, a title that does not correspond with any of her actual titles at Ofgem during 2023. This discrepancy could lead to confusion and may suggest a lack of clarity in how her responsibilities at Ofgem are being represented to outside entities. Additionally, the Harworth Group’s annual report inaccurately reflects her current job title at Ofgem, suggesting potential oversight in properly disclosing her roles and responsibilities.

Timing of Roles and Overlap:
The concurrent holding of these roles, especially at a senior level within both Ofgem and a private corporation, raises concerns about the separation of powers. At Ofgem, Zafar has held high-level strategic roles with responsibilities that span critical areas of energy system governance, innovation, and digitalisation. Her involvement in innovation funding and shaping the future of energy systems while holding an executive position at a company engaged in large-scale regeneration could be viewed as a potential conflict of interest, especially if the company were to benefit from energy policies or regulations enacted under her influence.

Harworth Group’s Indirect Ownership of Subsidiaries and Renewable Energy Focus:
Although Harworth Group PLC holds shares in its subsidiaries indirectly, this does not entirely eliminate the potential conflict of interest. The parent company still benefits from the activities of its subsidiaries, including those engaged in renewable energy such as Harworth PV Limited and Harworth Regeneration Limited. Given Zafar’s regulatory role at Ofgem, there is still a risk that her influence could indirectly benefit Harworth Group’s subsidiaries in ways that may not align with the separation of powers between her public and private sector responsibilities.

No Public Disclosure at Ofgem:
The absence of any reference to her role at Harworth Group PLC on the Ofgem website raises concerns about full and transparent disclosure of external appointments. This omission undermines confidence in the separation of her regulatory duties at Ofgem from her commercial interests at Harworth.

In conclusion, while Marzia Zafar's expertise in the energy sector is evident, the lack of transparency regarding her external appointments, the incorrect titles listed in corporate disclosures, and the potential overlap of her responsibilities in both public and private sectors raise important issues around conflict of interest and separation of powers. The indirect nature of Harworth Group PLC’s ownership does not sufficiently mitigate these concerns, and proper disclosure mechanisms, along with clear boundaries between her roles at Ofgem and external entities like Harworth Group PLC, are necessary to ensure accountability and avoid any perception of bias or undue influence.

Further analysis is required to determine if Harworth Group PLC directors hold multiple identities in Companies House. Preliminary checks indicate that they do, which suggests that certain interests may be omitted from audits and should instead be included for comprehensive consideration.

ChatGPT assisted with some of this analysis.